Date: October 15, 2018
Society for Science & the Public (“the Society”) wants to ensure that visitors, subscribers, members, alumni, donors, volunteers and everyone with whom we have a relationship understands what data we collect, how we use it, and what we do to keep it private when they use the Society’s websites with the following domain names (each, a “Website,” and, collectively, the “Websites.”):
1. Collected Information
Personal data, or personal information, is any information about an individual from which that person can be identified. It does not include data where a person’s identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which may include the following categories:
- Identity Data includes first name, last name, username or similar identifier, address, city, state, zip code, email address, date or year of birth, school, grade level, and awards. Optionally, for entrants in the Intel ISEF, the Regeneron STS and Broadcom MASTERS. Identity Data may also include: race, gender, or ethnicity.
- Contact Data includes mailing address, delivery address, email address and telephone numbers.
- Transaction Data includes details about services you have obtained from the Society, including registrations.
- Technical Data includes Internet Protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access Society Website.
- Profile Data includes your username and password, registrations, and sign-ups by you.
- Usage Data includes information about how you use Society Websites and services.
- Marketing and Communications Data includes your preferences for receiving marketing from the Society and your communication preferences.
The Society does not collect most Special Categories of Personal Data about you (this includes details about your religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses. Race or ethnicity are optional for some of the application systems related to our education programs. In the event that we do collect special categories of data, we will ask for your consent first.
Do not share any Special Categories of Personal Data with us unless we ask for such personal data.
2. How Is Your Personal Data Collected?
We use different methods to collect data from and about you including:
- Direct Interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by mail, phone, email or otherwise. This includes personal data you provide when you:
- register for an event, etc.;
- create an account on our website;
- subscribe to one of our programs; or
- give us feedback (when you Contact Us).
- Automated Technologies or Interactions. As you interact with our Websites, the Society may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.
- Third Parties or Publicly Available Sources. The Society does not collect information about you from third parties.
3. If You Fail to Provide Personal Data
Where the Society must collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to allow you to register for an event). In this case, the Society may have to cancel a service you have with us but we will notify you if this is the case at the time.
4. How We Use Your Personal Data
The Society will only use your personal data in order to carry out our mission as a non-profit organization. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract, we are about to enter into or have entered into with you, such as our obligations to you in connection with your rights when participating with programs or events.
- Where it is necessary for our legitimate interests (or those of a Third Party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- Generally, we do not rely on consent as a legal basis for processing your personal data, unless we ask for special categories of data (such as race or ethnicity).
5. Purposes for Which We Will Use Your Personal Data
The Society has set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact the Privacy Officer if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you for an account or membership||(a) Identity|
|Performance of a contract with you|
|To process and deliver your registration or activities (events, programs, etc.) or membership benefits, including:|
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (to recover debts owed to us)
|To manage our relationship with you which will include:|
(a) Notifying you about changes to our policies or terms of service
(d) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our operations and the Websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity|
|(a) Necessary for our legitimate interests (for running our operation, provision of administration and IT services, network security, to prevent fraud etc.)|
(b) Necessary to comply with a legal obligation
|To use data analytics to improve our Websites and visitor experiences||(a) Technical|
|Necessary for our legitimate interests (to keep our Websites updated and relevant)|
You do not have to provide any personal information, other than Technical Data, to read the content of our Websites. However, there are many instances where an individual may provide the Society with Identity Information. These include but are not limited to: students applying to participate in an education program (e.g. Regeneron Science Talent Search), an individual subscribing to one of our publications (e.g. Science News) or other communications (e.g. enewsletter or eblast), an individual who is a member/volunteer or who is interested in volunteering/becoming a member, an individual who claims and maintains a profile and/or claims a digital achievement badge in the Alumni Network or an individual who makes a donation or purchases a gift membership. For entrants in the Intel ISEF, the Regeneron STS and Broadcom MASTERS, the Society may ask for additional Identity Information including, race, gender, and ethnicity, but providing this information is optional (this varies based on the application).
When a User makes a donation or gift membership, become a member or renews a membership, the process requires that User to complete a credit card transaction in which additional information will be needed (i.e., card type, number, security code and expiration date). Credit card payment processing is handled by a Third Party and neither the Society nor this Third Party stores any credit card information. (See “Processing Information” section below)
To post comments on Society Websites, Users must register with and provide personal information to a Third-Party provider. The personal information provided to the Third-Party provider is governed by Disqus, https://help.disqus.com/terms-and-policies/disqus-privacy-policy.
The following guidelines set forth the Society’s practices for handling your personal information in more detail:
a. Education Program Applicants, Entrants, Volunteers, Teachers, Finalists, Observers, and Guests
The Society currently administers programs that typically engage students ages 13 and older. Any student providing information as part of an application, whether or not selected for a program, will have their information used for consideration of entry to the program and to send communications about the applied-for program and other Society programs, membership and publications.
All other participants (non-applicants) that engage with our Education Programs (i.e. educators, volunteers, judges, etc.) are asked to provide personal information that identifies them. Such information may include, but is not limited to, your name, address, phone number, or email address.
b. Subscribers, Members, Donors, “Friends” and Other Commercial Activity
From time to time, the Society may rent subscriber information to Third Party organizations. If Users would like to be removed from such lists, see section 9 below for more information.
c. E-mail Communications and Opt-Out Preferences
The Society sends e-mail communications to current and past members, program participants, volunteers, subscribers, digital badge earners and other individuals or organizations upon request. Every bulk e-mail includes an “unsubscribe” link that allows the recipient to decline all future email communication from the Society. Removal from all lists may take up to five business days to complete. Replying directly to the email, rather than using the unsubscribe form, may require additional time to process.
The only instance where an “unsubscribe” link would not be included at the bottom of an e-mail sent as direct correspondence from a Society staff person. Please respond directly back to that individual staff person if you would prefer to be removed from future communications of that type or all types.
d. Internal Uses
The information that the Society collects is generally used for internal purposes such as processing donations, providing our publications and services and fulfilling requests for information. The Society may also collect information about Website Users in order to assist in determining which parts of the Websites visitors find most valuable. This allows the Society to continually improve the services it provides. For example, the Society may track the URL that a User visited before coming to a Society Website. Additionally, the Society may track Users’ IP addresses and use Users’ IP addresses to help diagnose problems with the Society’s servers and to administer the Websites.
The Society protects data using technical measures to minimize the risks of misuse, unauthorized access, unauthorized disclosure, loss or theft, and loss of access. Some of the safeguards we use are data encryption, firewalls, and data access authorization controls. Therefore, the security mechanisms used to protect data are checked and updated regularly to provide effective protection against abuse.
We use SSL (Secure Socket Layers) encryption to protect the connection between the Society’s Websites and a browser. We have additional and comprehensive security measures in place when a User accesses the Society’s Websites by implementing a multilayer security approach for protection as well as firewalls to prevent unauthorized access.
For confidentiality and security, we use IDs and passwords to secure personal information. It is important for Users to protect their ID, password, and any personal information. Users should not disclose personal information (especially passwords) to anyone. When a User is finished using our services, they should log out from their account. If a User shares their computer, whether in a public or private setting, the User should sign off and close the browser when finished.
7. Cookies or Other Tracking Technology
A cookie is a small data file that is written to a computer’s hard drive or mobile device by the web browser. A cookie file can contain and/or automatically collect information, such as a user identification code or IP address that a website will use to track the pages and number of times a User has visited. The data read from these cookies may be linked to personally identifying and non-personally identifying information. Third party cookies enable Third Party features or functionality to be provided on or through the Website (e.g. advertising, videos and website analytics services).
Users may instruct their Internet browsers to opt out of accepting a “persistent” cookie and rather accept only a “per-session” cookie, but will need to login each time they visit the Society’s Websites to enjoy the Websites’ full benefits. If the User declines the attachment of any cookie, the User may not have access to the full benefits of the Website. Registration enables the Websites to better determine a User’s interest areas and provide the most relevant information.
The Society may also use web beacons, clear gif technology, action tags or other technologies to collect aggregate website visitation data by tracking how Users navigate to and through the Websites. We also include web beacons in our e-mail messages, including newsletters, in order to count how many e-mail messages have been delivered or opened. Web beacons cannot be declined when delivered using a regular web page, but they can be refused when delivered by e-mail. If a User does not wish to receive web beacons by email, they will need to disable HTML images or select text only for emails received with their email software.
We may use a web analytics service such as Google Analytics, New Relic, and HotJar to record and analyze activity on our Websites. These cookies collect information that is used either in aggregate form to help the Society understand how our Websites are used, the effectiveness of our marketing campaigns, or to help us customize our Websites and applications in order to enhance the user experience. The Websites or any such service may track browsing across web sites that use the same service, may collect statistical data and/or IP address.
The Website’s web and ad servers log information about a User’s IP address, browser type and the current URL the User is requesting. This information is always provided by a User’s browser and automatically logged by most websites. These log files are stored in a secure location and used in our internal analysis of traffic patterns within our Websites.
8. EEA Individuals: Marketing and Third-Party Sharing
This section applies to EEA individuals only.
a. Our Own Marketing. All of our own marketing to members and registrants is done in connection with the individuals’ membership or registration opportunities (programs, events, etc.) and each individual will have the opportunity to Opt-Out from such marketing.
If the Society markets to non-members or non-registrants, we will do so only upon receiving consent from such non-members or non-registrants and in accordance with applicable privacy laws. In any event, non-members and non-registrants will have the opportunity to Opt-Out from such marketing.
b. Third Parties’ Marketing. The Society generally does not share your personal data with any Third Party for the Third Parties’ marketing purposes. If we ever do share your personal data with a Third Party for the Third Party’s own marketing purposes, we will obtain your prior consent before we do so (for example, if you attend an event and you consent to us sharing your contact information with a sponsor of that event).
c. Opting Out. You can ask the Society to stop sending you marketing messages at any time by e-mailing email@example.com. Please allow a reasonable time for the Society to respond to your request.
9. Non-EEA Individuals: Marketing and Third-Party Sharing
If you are not an EEA individuals, the Society contracts with Third-Party companies to provide certain services on a User’s behalf. These services include credit card processing, printing services, mail and email distribution and processing and other customer support services. Information provided to Third-Party service providers is strictly limited to the services required or as required by law.
The Society may use a User’s personally identifiable information to provide the User with promotional information about programs, services, events and publications offered by the Society or select Third-Parties, including sponsors and their advertising and public relations agencies. The Society may also share information with its sponsors and their advertising and public relations agencies. These Third Parties may have their own opt-out options in which you will be able to directly opt-out. Otherwise you can opt-out by contacting the Society.
From time to time, the Society may rent subscriber information to Third Party organizations. The Society closely reviews every request for information by Third-Parties to help ensure they are trustworthy and reputable, as determined by the Society in its discretion.
A User may opt-out of such sharing with Third-Party organizations or modify communication preferences at any time by e-mailing firstname.lastname@example.org, by calling (202) 785-2255 or by mailing Society for Science & the Public, Attention: Privacy Officer, 1719 N St NW, Washington, D.C. 20036.
The Society may also use aggregate data that is not personally identifiable in discussions, presentations or reports to current or potential grantors. This data may include demographic, geographic or other broadly representative data.
The Society will divulge any information collected from a User on the Websites when required to do so by law.
In the event that the Websites or substantially all of our assets are acquired, merged or reorganized, your information may be transferred to another party.
10. Cardholder Data
A User may be asked to provide credit card information to complete a transaction. It is our policy to have the transaction processed by a Third-Party payment processor. The Society does not collect, access, store or process any credit card information. For more information about the Third Parties we use for processing, please visit www.stripe.com or www.authorize.net.
11. Third Party Links/Advertisements
12. California Residents: Your California Privacy Rights
In addition to the Privacy Rights provided for generally in these policies, California residents have the right to request by mail, e-mail or telephone communication, that the Society disclose for the immediately preceding calendar year the categories of personal information shared with Third Parties and the names and addresses of such Third Parties including the nature of the Third-Parties businesses. Users who are California residents and would like to make this request should contact the Society by e-mailing our Privacy Officer email@example.com, by calling (202) 785-2255 or by mailing Society for Science & the Public, Attention: Privacy Officer, 1719 N St NW, Washington, DC 20036
13. Account Holders/Registrants: To Access or Correct Your Information
14. Data Retention
We will retain the information provided to us and information automatically collected through the Websites for as long as a User account or membership is active or as needed to provide our publications and services for a reasonable time thereafter. User’s personal information will remain in the Alumni Network indefinitely unless Users’ instruct the Society to delete their profiles or otherwise opt-out. We will retain and use Users’ information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. At any time, we may store non-personal information in the aggregate. If a User is an EEA individual, the User may request that the Society deletes certain personal data, as explained in Section 16 below.
Minors under the age of 18 may request and obtain removal of certain content or information posted on our Websites by sending an email to firstname.lastname@example.org. Please be advised that our removal of your post(s) does not ensure complete or comprehensive removal of the content or information you have posted on our Websites.
Minors under the age of 16 who reside in the EEA will be required to have the holder of parental consent authorize the information required to participate in our programs. Additional information will be required at such times to confirm the data that has been submitted by the User or on the User’s behalf.
16. EEA Individuals
a. Legal Rights. Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data the Society holds about you and to check that we are lawfully processing it.
- Request correction of the personal data that the Society holds about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask the Society to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons for which you will receive a notification, if applicable, at the time of your request.
- Object to processing of your personal data on the grounds that the Society relies on a legitimate interest (or those of a Third Party) that you feel impacts your fundamental rights and freedoms. You also have the right to object to the Society processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask the Society to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a Third Party. The Society will provide to you, or a Third Party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where the Society relies on consent to process 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, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
b. What We May Need From You. The Society may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
c. Time Limit to Respond. The Society tries to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
d. International Transfers. The Society processes your data in the United States. If we transfer your data to a Third Party outside the European Economic Area (EEA) we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. Alternatively, we may transfer data to a Third Party if they are part of the Privacy Shield, which requires the Third Party to provide similar protection to personal data shared between the Europe and the United States. For further details, see European Commission: EU-US Privacy Shield.
Please contact the Privacy Officer if you want further information on the specific mechanism used by the Society when transferring your personal data out of the EEA.
e. Right to Lodge a Complaint. In the event of a dispute regarding your rights hereunder, you may have the right to make a complaint with your local authorities. The Society would, however, request a chance to address your concerns first because your privacy is important to us.