PRIVACY POLICY

Business and Website Privacy & Cookies Notice

We've created this policy, which covers how Aspire USA;

  • Collect
  • Use
  • Disclose
  • Transfer
  • Store

…your data.

1. Introduction and General Terms

Aspire USA is committed to protecting your personal information when you are using Aspire USA services. We want our services to be safe and enjoyable environments for our clients and contacts. This Privacy and Cookies Policy relates to our use of any personal information we collect
from you via the following online services:

any Aspire USA website that links to this Privacy and Cookies Policy;social media or official Aspire USA content on other websites;mobile device and Applications ("Apps").

It also relates to our use of any personal information you provide to us by phone, SMS, email, in letters and other correspondence and in person.

In order to provide you with the full range of Aspire USA services we sometimes need to collect information about you.

This Privacy and Cookies Policy explains:

what information Aspire USA may collect about you;
how Aspire USA will use information we collect about you;
when Aspire USA may use your details to contact you;
whether Aspire USA will disclose your details to anyone else;
your choices regarding the personal information you provide to us;
the use of cookies on Aspire USA websites and how you can reject cookies;
how you can change the way we hold and use your personal information.

Whenever you provide personal information, we are legally obliged to use it in line with all applicable laws concerning its protection, including the Data Protection Act 1998 and the General Data Protection Regulations (referred to collectively in this Privacy and Cookies Policy
as the "data protection regulations").

Aspire USA websites contain hyperlinks to websites owned and operated by third parties. These third-party websites have their own privacy policies and are also likely to use cookies so we urge you to review their policies separately. They will govern the use of personal information you submit when visiting those websites, which may also be collected by cookies. We do not accept any responsibility or liability for the privacy practices of those third-party websites and your use of them is at your own risk.

2. Who are we?

Aspire USA provide university admissions and sport scholarship servicesto talented sports men and women looking to study and play sport at American universities and colleges.

3. What information will Aspire USA collect about me?

When you participate in, access or sign up to any of Aspire USA's services, activities or online content we may receive personal information about you. This can consist of information such as your name, email address, postal address, telephone or mobile number, gender or date of birth.

4. How will Aspire USA use the information it collects about me?

Aspire USA will use your personal information for a number of purposes including:

to provide our services, activities or online content, to provide you with information about them and to deal with your requests and enquiries;
to analyse the information you supply as well as your activity on our (and other) services so that we can offer a more relevant, tailored service where we provide personalised services;
to use IP addresses and device identifiers so we can identify the location of users, block disruptive use, establish the number of visits from different countries and determine whether or not you are accessing the services from the UK;
for analysis and research purposes so that we can improve the services offered by Aspire USA. This can include using geo-demographic information from external sources where this helps us;
we may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.

Where Aspire USA proposes using your personal information for any otheruse we will ensure that we notify you first. Please see section 18 for details.

5. Your Aspire USA Contact Request

If you fill out one of our online contact forms your details will be added to our CRM system so we can effectively manage your enquiry. You will be contacted regarding your enquiry using the information you submit on the form.

If you choose you will be added as a subscriber to our newsletter emails. You can unsubscribe from these at any point using the unsubscribe link at the bottom of those emails.

6. When will Aspire USA contact me?

Aspire USA may contact you:

in relation to any correspondence we receive from you or any comment or complaint you make about Aspire USA products or services;
in relation to any services you are using;to update you on any material changes to Aspire USA's policies and practices;
and for marketing purposes, as set out in section 7.

7. Will I be contacted for marketing purposes?

Aspire USA will only send you marketing communications where you have agreed to this. We offer occasional emails, to let you know about AspireUSA events and services. We may personalise the message content based on any information you have provided to us and on your use of Aspire USA
platforms.

We may use information we hold about you to show you relevant advertising on third-party sites (e.g. Facebook, Google, Instagram, Snapchat and Twitter).

8. Will Aspire USA share my personal information with anyone else?

We will keep your information within Aspire USA except where disclosure is required or permitted by law (for example to government bodies and law enforcement agencies, including for child protection reasons) or as described in this section and section 9.

We will only use your information within Aspire USA. However, we may share with third-party sites (e.g. Facebook, Google, MailChimp, credit reference suppliers, Instagram, Snapchat and Twitter) some data, with appropriate security measures, to show you relevant advertising on third-party sites, as set out in section 7.

9. Offensive or inappropriate content on Aspire USA websites

If you post or send content which we consider offensive, inappropriate or objectionable anywhere on or to Aspire USA websites or otherwise engage in any disruptive behaviour Aspire USA may remove that content and/or block access.

Where Aspire USA considers that you may be in breach of any applicable laws, for example on hate speech, Aspire USA may disclose your personal information to relevant third parties, including to law enforcement agencies or your internet provider. Aspire USA would only do so in circumstances where such disclosure is permitted under applicable laws, including data protection regulations.

10. What if I am a user aged under 16?

If you are aged 16 or under, please get your parent/guardian's permission before you provide any personal information to Aspire USA.

11. How long will Aspire USA keep my information?

We will hold your personal information for as long as is necessary for the relevant activity, or as long as is set out in any relevant contractyou hold with Aspire USA.

12. Can I delete my data?

You can request that Aspire USA delete any personal information we hold about you at any time by contacting dataprivacy@Aspireusa.uk.com with your request. Alternatively, you can write to the Data Privacy Team.

13. Can I find out what personal information Aspire USA holds about me?

Under the data protection regulations, you have the right to request a copy of the personal information Aspire USA holds about you and to have any inaccuracies corrected. We will use reasonable efforts consistent with our legal duty to supply, correct or delete personal information
about you in our files.

If you are within the UK, please address requests and questions about this or any other question about this Privacy and Cookies Policy to the Data Privacy Team (Email: dataprivacy@Aspireusa.uk.com).

Please note, we reserve the right to charge an administrative fee if your request is manifestly unfounded or excessive.

If we feel we need to establish your identity, we may ask for proof of such before providing any personal data.

14. Web browser cookies

a) What is a Cookie?

A cookie is a small amount of data, which often includes a unique identifier, that is sent to your computer, tablet or mobile phone (all referred to here as a "device") web browser from a website's computer and is stored on your device's hard drive. Each website can send its own cookie to your web browser if your browser's preferences allow it. Many websites do this whenever a user visits their website in order to track online traffic flows. Similar technologies are also often used within
emails to understand whether the email has been read or if any links have been clicked. If you continue without changing your settings, we'll assume that you are happy to receive all cookies on the Aspire USA website. However, you can change your cookie settings at any time.

On Aspire USA websites, cookies record information about your online preferences and allow us to tailor our websites to your interests.

During the course of any visit to a Aspire USA website, the pages you see, along with a cookie, are downloaded to your device. Many websites do this, because cookies enable website publishers to do useful things like find out whether the device (and probably its user) has visited the website before. This is done on a repeat visit by checking to find and using the cookie left there on the last visit.

b) How does Aspire USA use cookies? Information supplied by cookies can help us to understand the profile of our visitors and help us to
provide you with a better user experience. Aspire USA uses this type of information to help improve the services it provides to its users. Certain areas of Aspire USA websites may use cookies for a specific reason.

c) Third-party cookies in embedded content on Aspire USA pages. Please note that during your visits to Aspire USA websites you may notice some cookies that are not related to Aspire USA or Aspire USA's contractors. We sometimes embed content from social media and other third-party
websites. These may include YouTube, Vimeo, Google Maps, Twitter, Facebook, SoundCloud, Vine, Instagram, Pinterest and Flickr. As a result, when you visit a page containing such content you may be presented with cookies from these websites and these third-party cookies may track your use of the Aspire USA website. Aspire USA does not control the dissemination of these cookies and you should check the relevant third party's website for more information. If you continue
without changing your settings, we'll assume that you are happy to receive all cookies on the Aspire USA website. However, you can find out about changing your cookie settings here. Where Aspire USA embeds content from social media and other third-party websites some websites may use Google Analytics to collect data about user behaviour for their own purposes. Aspire USA does not control this. For more information, see the Google webpage "How Google uses data when you use our partners' sites or apps".

d) Aspire USA cookies and how to reject cookies

Below are details of cookies set by services we use to better understand the use of the Aspire USA owned websites. We use this data to continuously improve our service we offer.

Cookie: Google Analytics

Name: _ga, _gid

Purpose: These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information (in an
anonymous form that does not identify a visitor) including the number of visitors to the site, where visitors have come to the site from and the pages they visited. This helps us to improve the way our website works, for example by making sure users are finding what they need easily.

More info: Click here for an overview of privacy at Google. To opt out of being tracked by Google Analytics across all websites visit the Google site.

It is important to note that if you change your settings and block certain cookies you may not be able to take full advantage of some features of Aspire USA services, and we might not be able to provide
some features you have previously chosen to receive.

e) Other information collected from web browsers

Your web browser may also provide Aspire USA with information about your device such as an IP address and details about the browser that you are using. Where requesting specific service it may be possible for you to choose to provide Aspire USA with access to your device's location
through the web-browser. We use information provided by your browser or by the link that you have clicked to understand the webpage that directed you to Aspire USA and this may be captured by performance cookies.

If you have any concerns about the way that we use cookies or respect your settings, then please contact us at dataprivacy@Aspireusa.uk.com

15. Do Not Track (DNT) browser setting

DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked such as by third-party ad networks, social networks and analytic companies. This website does not currently respond to DNT requests.

16. Aspire USA Developed Apps

When you download or use Aspire USA apps on your mobile device or TV information may be accessed from or stored to your device. Most often this is used in a similar way to a web browser cookie such as by enabling the app to 'remember' you or provide you with the content you
have requested.

Your web browser or device may also provide Aspire USA with information about your device such as a device identifier. Device identifiers such as the device ID, IP address, MAC address, IMEI number or app ID (a unique identifier relating to the particular copy of the app you are
running) may be collected automatically.

Information collected automatically

The Application may automatically collect information related to:

The device running the Application, including any unique device identifier, IP address, operating system the device uses.
The date and time the Application is used
The location of the device when the Application is used

Use of automatically collected information

This type of data would only be used by us in aggregated and anonymised form in order to provide information that helps us understand the use of our Applications and to improve the Applications we create.

User Provided information

If our Application requires you to provide and share personal information or needs to access other information on your device or to access information used by other applications on your device then we will require you to register with us and provide positive acceptance of this Policy. Many of our Applications will not collect or use this type of information. Where registration is required if you do not accept the Policy then the functionality of the Application may be restricted.

Examples of personal information include:

Name, age, gender, your contact details;
Credit card details (only where the Application provides opportunities for purchasing);
Your contact lists or preferences in other applications;
Your use of other applications;
Images, comments and other materials on your device or in other applications accessed by your device (e.g. profile pictures, preferences) and used by the application.

Use of user provided information

We will only use this type of information:

for purposes implicit in the intended use of the Application;
and/or in anonymised and aggregated form for more detailed analysis of the use of the Application; and/or for internal operations, including troubleshooting problems, data
analysis, testing, research, improvements to the Application;
and/or to contact you regarding important information or required notices; and/or
to contact you regarding marketing promotions unless you have opted out of this in your registration details.

Sharing of your information

We will not provide access to your information to third parties for commercial gain. Except as below we will not disclose or share your information. We may disclose user provided and automatically collected information:

as specifically requested by you from within the Application;
as required by law, such as to comply with a court order, or similar legal process;
when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
with our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set out in this Policy;
In connection with a corporate transaction involving the Application, such as the purchase or sale of a business unit, an acquisition, merger, sale of assets, or other similar event.

Storing your information

Your information may be stored and processed in any country and may include outsourced cloud facilities. In this regard, or for purposes of sharing or disclosing data as described in this Policy, we reserve the right to transfer information outside of your country. By using the Application, you consent to any such transfer of information outside of your country. We will retain user provided data for as long as you remain registered to use the Application and for a reasonable time thereafter. We will retain automatically collected information for up to 24 months and thereafter may store it in aggregate.

If you'd like us to delete user provided data that you have provided via the Application because you no longer wish to use the Application then you should de-register your account with us; simply removing the Application from your device will not automatically delete your
information.

Please note that some or all of the User Provided Data may be required in order for the Application to function properly.

Safeguarding the confidentiality of your information is a priority for us. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, due to the inherent nature of the internet and related technology no security system can prevent all potential securitybreaches.

Third-party links

Occasionally, at our discretion, our Applications may include or offer third-party products or services or provide links to other organisationsor services. These third parties have separate and independent privacy policies. We have no responsibility or liability for the content and activities of these linked applications, however, to protect the integrity of our applications, we welcome feedback regarding any breach of privacy policies by those third parties.

Age

Many of our Applications will be suitable for children (under 16) and will not require user provided personal information.

Where an Applications requires registration with us (and hence access to user provided information) we will ask for the user's age and appropriately restrict the information the Application can access or
share.

17. Changes to Aspire USA's Privacy and Cookies Policy

This Privacy and Cookies Policy may be updated from time to time so you may wish to check it each time you submit personal information to Aspire USA. The date of the most recent revisions will appear on this page. If you do not agree to these changes, please do not continue to
use Aspire USA websites to submit personal information to Aspire USA. If material changes are made to the Privacy and Cookies Policy, for instance affecting how we would like to use your personal information, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes).

18. Contacting Aspire USA about this Privacy and Cookies Notice

If you have any questions or comments about this Privacy and Cookies Notice please contact: Data Privacy Team

Email: dataprivacy@Aspireusa.uk.com

 

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