Putney Student Travel

(www.goputney.com)

PRIVACY POLICY

Our relationship with you is very important to us. We are sensitive to protecting the private information that you provide to us. We also want you to have the opportunity to receive interesting and useful information about Putney Student Travel Incorporated (“Putney”) and about related products and services. We may make changes to this policy periodically, which we will post here.

BY USING THIS SITE OR ANY OF OUR SERVICES, YOU (I) SIGNIFY YOUR IRREVOCABLE ACCEPTANCE OF THIS PRIVACY POLICY; AND (II) REPRESENT THAT YOU ARE EITHER AN EMANCIPATED MINOR, POSSESS LEGAL PARENTAL OR GUARDIAN CONSENT, OR AT LEAST 18 YEARS OF AGE AND ARE FULLY ABLE AND COMPETENT TO ENTER INTO THE TERMS, CONDITIONS, OBLIGATIONS, AFFIRMATIONS, REPRESENTATIONS, AND WARRANTIES SET FORTH IN THIS PRIVACY POLICY, AND TO ABIDE BY AND COMPLY WITH THIS PRIVACY POLICY.

Here are details on how we use the information you provide us:

1. Name, Address, Contact, Surveys and Billing Information

When you fill out a form or submit an online application, you may be asked to enter your name, mailing address, e-mail address, phone number, billing information and/or other personal information. Putney may share this personal information with companies who provide services such as information processing, fulfilling catalog orders, providing pre-/post- and on-program services, managing and enhancing customer data and conducting customer research or satisfaction surveys. These companies are obligated to protect your information. Putney does not sell your personal information to third parties.


2. Website Use and Navigation Information

Each time a user visits our website, certain use and navigation information is collected by our servers. This information is aggregate and anonymous. It gives us information such as the number, frequency and duration of visits to each web page which we use to improve the content and navigation features of our website. A third-party cookie may also be placed on your computer which will collect information about your visit to this and other websites in order to provide advertisements about goods and services of interest to you. Usage of such cookies is not linked to any personally identifiable information. You can refuse cookies by turning them off in your browser.


3. Voluntary Surveys

We periodically survey our catalog requesters and program participants for their academic and travel interests in order to help us improve the types of travel programs we offer. In conducting these surveys, we may ask for certain personal information so that we can identify and, if requested, contact you. Participation in these surveys is completely voluntary.


4. Contests and Promotions

When you enter a contest or other promotional feature on our website, we may ask for personal information so that we can administer the contest and notify winners. Participation in these contests is completely voluntary.


5. Sharing and Disclosure of Information Putney Collects

Except as otherwise described in this Privacy Policy, Putney will not disclose personal information to any third party unless we believe that disclosure is necessary:
(1) to conform to legal requirements or to respond to a subpoena, search warrant or other legal process received by Putney, whether or not a response is required by applicable law;
(2) to enforce the Putney Program Standards and Policies or to protect our rights; or
(3) to protect the safety of members of the public and users of the website. Putney reserves the right to transfer personal information to a successor in interest that acquires rights to that information as a result of the sale of Putney or substantially all of its assets to that successor in interest.

Declining Email
At any time, you may request to discontinue receiving e-mails from Putney by following the opt-out instructions included at the bottom of e-mails and informing us of your preference.


Linked Internet Sites
Occasionally, at our discretion, we may include or offer links to third party products or services on our website. These third party sites have separate and independent privacy policies. Putney is not responsible for the privacy practices or content of other such sites. This Privacy Policy applies solely to information collected by Putney.
Privacy Policy Questions


In you have any questions about this Privacy Policy, please call us at (802) 387-5000 or email us at webmaster@goputney.com.

California Residents

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Putney Student Travel (“PST”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”) when you visit the Smithsonian Student Travel (“SST”) website or subscribe to receive SST services (collectively, our “Services”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

  • Category A – Identifiers
    Examples: Name, postal address, Internet Protocol address, email address, Social Security number, driver’s license number, passport number, or other similar identifiers.
  • Category B – Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
    Examples: Name, signature, Social Security number, address, telephone number, fax number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, bank account number, credit card number, debit card number, or any other financial information, physical illness, mental illness or disabilities.
  • Category F – Internet or other similar network activity
    Examples: Access history and information on your interaction with our application.
  • Category I – Professional or employment-related information
    Examples: Occupation, employer information.
  • Category J – Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))
    Examples: Education level, school attended.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, through information we ask from you when our clients or their agents subscribe and engage our Services.
  • Directly and indirectly from you when using our Services or visiting our website. For example, usage details collected automatically in the course of your interaction with our platform or website. 

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To provide you with email alerts and other notices concerning our Services, or updates to your application process.
  • To improve our Services to you.
  • For testing, research, analysis and product development.
  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

 

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

  • Category A: Identifiers.
  • Category B: California Customer Records personal information categories.
  • Category F: Internet or other similar network activity
  • Category J: Non-public education information.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Service providers.

In the preceding twelve (12) months, we have not sold any personal information.

 

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

 

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).

     

Deletion Request Rights

You have the right to request that we delete any of your personal information we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  7. Comply with a legal obligation.
  8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

     

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email at ccpa@smithsonianstudenttravel.org

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

 

Response Timing and Format

We endeavor to respond to a verifiable consumer request within fifteen (15) days of its receipt.  If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to the registered email associated with the account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you use of our Services.
  • Provide you a different level or quality of Services.

     

Changes to Our Privacy Notice

We reserve the right to amend this Privacy Notice at our discretion and at any time. The date this Privacy Notice was last updated is identified at the bottom of this page. You are responsible for periodically visiting the Smithsonian Student Travel website and this Privacy Notice to check for any changes.

Contact Information

If you have any questions or comments about this Privacy Notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, you may contact us via email at ccpa@smithsonianstudenttravel.org

The CCPA portion of this Privacy Policy was last updated 11/30/2020