The Fund for American Studies
TFAS programs are not designed to appeal to minors under the age of 13 and we do not knowingly attempt to solicit or receive any personal information from children. To the extent that minors under the age of 13 do use a TFAS website and TFAS is able to determine the age of website users by their submissions to, or communications with TFAS web sites, TFAS will not knowingly collect personal information from such minors without their parent’s or guardian’s verifiable consent.
1. COLLECTION AND USE OF PERSONAL INFORMATION
TFAS conducts academic programs in the United States and internationally to help instill in young people an appreciation for the American form of government and the free-enterprise system.
Personal information is any information relating to an identified or identifiable natural person. We collect personal information from you when you apply to a TFAS program or fellowship, apply for a scholarship, complete a recommendation or nomination form, or register to attend a conference, seminar or lecture series.
The personal information we collect from you may include (depending on if applying to a program): name, mailing address, gender, phone number at school, cell number, email address, address away from school, school address, emergency contact information (name, address, phone number, email), birthdate, U.S. citizenship status, countr(ies) of citizenship, permanent resident status, information related to visa requirements and other documents to ensure compliance with U.S. laws, ethnicity, Social Security Number, city, state and country of birth, driver’s license number, address on your driver’s license, state issuing your driver’s license, information about your applications to other TFAS programs, how you heard about TFAS, whether you heard about TFAS from a listing of other organizations, whether you are a member of an honor society, a list of names of professors and alumni if you heard about TFAS from them, school name and degree level, majors and minors, grade point average, the date you started school and your graduation date, your year in school, academic schedule, other colleges attended and your grade point average, school transcript, resume, writing samples, information about any academic, social probation, suspension or dismissal from school, and information about any felony convictions.
If you apply for a scholarship, TFAS will collect information from you about your FAFSA, financial information gathered for the purposes of administering the scholarship, including but not limited to information about any grants or loans, merit-based scholarships and grants, and athletic scholarships, whether you have any siblings in college, your parents’ annual income, your total cost of attendance at your school, your sources of education funding broken down, your Student Aid Report of Tax Return, your Financial Aid Award Summary of Grant/Scholarship, your award letter, and your scholarship statement.
Once collected, TFAS will use this personal information for the following purposes:
1. As part of the assessment and award processes for applications to the TFAS programs to which you applied.
To contact successful candidates during the year of their program and/or scholarship award for the purposes of necessary progress reporting.
2. To contact you throughout the duration of the TFAS program and/or scholarship.
3. To fulfill and/or deliver products and services such as event registration, administer awards and honors, and in various other interactions.
4. As part of the scholarship application and award process.
5. To enable future contact, post-graduation, in order to maintain communications with TFAS program alumni.
6. To conduct internal assessments of TFAS programs; additionally, such personal information, in a consolidated and aggregate form, may be used in publicly distributed statistical descriptions and studies of the TFAS constituency.
7. To communicate with you about TFAS and other items we believe will be of interest to you.
8. To help us understand trends, and gender and age differences with respect to perspectives about and usage of programs and the creation of new program offerings.
TFAS applicants, students and other constituents may add, correct, or update their personal information contacting us phone at: 202.986.0384 (or by e-mail at admissions@TFAS.org).
2. SHARING WITH THIRD PARTIES
TFAS may disclose your personal information as part of the program and scholarship assessment and award processes. TFAS will minimize the amount of personal information we disclose to that which is directly relevant and necessary to accomplish the specified purpose. We do not sell, rent or otherwise disclose your personal information to third parties for their marketing and advertising purposes.
TFAS does not sell or rent postal or email lists containing personal information of European Union (“EU”) and European Economic Area (“EEA”) data subjects.
TFAS may publicly recognize program participants and/or scholarship awardees.
TFAS may ask third party processors to assist us or we may disclose your personal information to selected third party processors (such as agents or sub-contractors) for the purposes outlined above. The third party processor in question will be obligated to use any personal information they receive in accordance with our instructions.
Non-exhaustively, third parties who we may share personal information with include:
A. suppliers and sub-contractors for the performance of any contract we enter into with them, for example email service providers, such as MailChimp, the app provider for the program/scholarship submitting process, or IT service providers such as software developers, website hosts or cloud storage providers;
B. insurers and banks;
C. in some cases, we may share your information with a parent or legal guardian if necessary to complete the application or scholarship process, report certain information as allowed by law, or in the event of an emergency;
D. third parties who help us organize and administer our programs, scholarships, and events;
E. financial companies that process payments on our behalf;
F. professional advisors such as accountants, auditors and lawyers;
G. your university or school, or TFAS university partners (if you are receiving credits);
H. potential internship sites to during the placement process;
I. parties assisting us with research to monitor the impact/effectiveness of our work and services;
J. regulatory authorities, such as tax authorities;
K. other higher education organizations in order to assist with transfers and tracking;
L. third parties to the extent we are required to do so by law, court order, or subpoena. In the case of international applicants, we may share your information with the United States government or appropriate agencies; and/ or
M. in our sole judgment, such disclosure is necessary to protect the health, safety, or property of any person.
TFAS engages third parties to mail or email information to you, including items you may have purchased. TFAS does not reveal your personal data to third parties for their independent use unless: (1) you request or authorize it; (2) it is in connection with TFAS -hosted or TFAS co-sponsored events.
TFAS reserves the right to disclose information, including personal information obtained from you, when disclosure is required by law or in a good-faith belief that such action is necessary to: (a) conform to legal requirements or comply with legal process served on TFAS; (b) protect, establish or defend the rights or property of TFAS including in connection with any (prospective) legal proceedings; (c) protect the personal safety of TFAS officers, personnel, members, volunteers, or members of the public in appropriate circumstances; (d) buy or sell any business or assets, in which case we will disclose your personal information to the prospective buyer or seller of such business or assets; (e) assist with auditing purposes; or (f) permit us to pursue available remedies or limit the damages that we may sustain.
3. OPT IN/OPT OUT
TFAS reserves the right to offer either an opt in or opt out option depending on the situation and the type of information being collected. Any individual may decline to provide personal information requested by TFAS. In this case, TFAS may be unable to process your application for the specific program or scholarship applied for. Applicants can stop the application process by sending an email message to admissions@TFAS.org or by telephoning 202.986.0384, or by writing to TFAS, 1706 New Hampshire Ave, NW, Washington, DC 20009.
4. LAWFUL BASES
Under certain laws, we are required to rely on one or more lawful grounds to collect and use the personal information that we have outlined above. We consider the grounds listed below to be relevant:
a. Legal obligation
Where the processing of your personal information is necessary for us to comply with a legal obligation to which we are subject e.g. because we have to provide information to tax authorities.
b. Contractual relationship
Where it is necessary for us to use your personal information in order to perform a contract to which you are a party (or to take steps at your request prior to entering a contract).
c. Legitimate interests
We rely on this basis where applicable law allows us to collect and use personal information for our legitimate interests and the use of your personal information is fair, balanced and does not unduly impact your rights. For instance, it is in our legitimate interest to use personal information about our members to provide membership services.
When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).
We may obtain your consent to use your personal information in certain circumstances e.g. to send you email marketing. We will ensure that when we obtain your consent you are free both to give it and to decline to give it. Additionally, you may always withdraw your consent at any time without any further detriment to you. In the case of a data subject who is under the age of majority in their state or country of residence, consent must be given or authorized by the data subject’s parent or legal guardian.
e. Processing is necessary to protect the vital interests of the data subject or of another person.
5. RIGHTS TO PERSONAL INFORMATION
Upon request via postal mail, email, or telephone, TFAS will provide data subjects (as defined in the General Data Protection Regulation) with a summary of any personal information retained by TFAS regarding the data subject. Individuals may modify, correct, change, or update personal information that TFAS has collected through the Sites or may initiate the removal of their personal record from TFAS’s database by contacting TFAS through a form on the TFAS website or by contacting us by phone at: 202.98.0384 or by e-mail at admissions@TFAS.org.
Please note that we will honor your requests to exercise your rights to the extent possible and required under applicable law. Certain of these rights may only be available to you if you are located in the UK, the EEA or the EU when you access our website or apply for the program and/or scholarship.
You have the right to:
a. Ask us for confirmation of what personal information we hold about you, and to request a copy of that information. If we are satisfied that you have a legal entitlement to see this personal information, and we are able to confirm your identity, we will provide you with this personal information.
b. Withdraw your consent at any time if we have relied on consent as the lawful ground to use your personal information.
c. Request that we delete the personal information we hold about you, as far as we are legally required to do so.
d. Object to the processing of your personal information where we: (i) process on the basis of the legitimate interests ground; (ii) use the personal information for direct marketing; or (iii) use the personal information for statistical purposes.
f. Ask for the provision of your personal information in a machine-readable format to either yourself or a third party, provided that the personal information in question has been provided to us by you, and is being processed by us: (i) in reliance on your consent; or (ii) because it is necessary for the performance of a contract to which you are party; and in either instance, we are processing it using automated means.
g. Ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate use.
Please note that you also have the right to lodge a complaint with your local data protection authority (if applicable) about how we use your personal information. Please always consider raising your concern with us first by contacting us using the contact details below.
6. KEEPING PERSONAL INFORMATION SECURE
Information provided to TFAS via its Websites and Radius Application System is transmitted via a secure server with commercial encryption software. Those not able to use a secure server may opt to transmit the information another way, via phone, fax, or postal mail.
We maintain physical, technical and administrative safeguards and procedures to safeguard the security and integrity of your personal information. Although TFAS takes these measures to safeguard against unauthorized disclosure of a user’s personal information, TFAS cannot control Internet transmissions and cannot guarantee or warrant that personal information transmitted to TFAS will be uncompromised in all circumstances.
7. DATA RETENTION
Your personal data is stored by TFAS on its servers, and on the servers of the cloud-based database management services the TFAS engages, located in the United States. For unsuccessful applicants, TFAS retains your personal information for as long as necessary to complete the program assessments, awards and scholarships processes. TFAS retains data for the duration of the attendee’s or student’s relationship with TFAS and for a period of time thereafter to allow individuals to recover accounts, to analyze the data for TFAS’s own operations, and for historical and archiving purposes associated with TFAS’s history as an association. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact TFAS using the methods below.
Individuals may also ask TFAS to anonymize their record by contacting us by phone at: 202.986.0384 or by e-mail at admissions@TFAS.org. If there is no legitimate purpose for TFAS to keep such personal information, TFAS will anonymize the individual’s record.
INTERNATIONAL DATA TRANSFERS
Where we collect personal information within the EEA, we have taken steps to ensure that the personal information is handled in compliance with European data protection and privacy legislation.
If you are located in the EEA, you should be aware that your personal information will be transferred to the US. In such cases, where your personal information is transferred from the EEA to the US, we will take all reasonable steps necessary to ensure that appropriate safeguards designed to protect your personal information are implemented.
8. COOKIES AND OTHER TECHNOLOGIES
A “cookie” is a file that a website stores in a user’s computer for future reference. Individuals may set their browsers to reject cookies; however, there are TFAS services that will not function unless the user accepts the TFAS cookie. For example, when a user returns to that TFAS service, the cookie will identify the user as a previous visitor. Information supplied through an TFAS cookie is used only by TFAS to help enhance services provided and is not shared with others.
“Cookies” and “beacons” may also be utilized by the third parties that we contract with to provide certain functions. You may block or disable cookies or other trackers by changing the settings on your browser, but doing so may prevent you from accessing certain functionalities on the Sites.
9. THIRD PARTY WEBSITES AND SERVICES
TFAS provides links to other websites, including social media websites, that are not controlled by or contracted to TFAS. A link from the TFAS website is not an endorsement of any company, organization, individual, or viewpoint. TFAS is not responsible for the privacy practices or the content of those sites. You should review third party privacy policies in connection with visiting other sites. TFAS also contracts with 3rd party service providers for web or program transactional services.
10. CHANGES TO POLICY
TFAS reserves the right, at any time, to add to, change, update, or modify this Policy, simply by posting such addition, change, update, or modification on this Site. Any such addition, change, update, or modification will be effective immediately upon posting on the Site. When significant changes are made to the Policy that will directly impact how personal information is collected or used, TFAS will notify you by additional means where possible, such as posting a notice on the Site or sending you an e-mail, or some other prominent mechanism. Users should review the Policy regularly to learn about other changes.