Privacy Policy

Information you Provide to Us

We collect personal information you provide us, such as when you use our website, express interest in applying to SYA, apply to SYA and otherwise enroll, update or add information to your account/file, sign up for email or direct mail, or otherwise contact us or engage with us, including over a web form, the telephone, mail to us, online chat, social media, or in person at events or otherwise.

Please remember that any information that is disclosed in public comments, forums, or other areas enabling other users to submit comments becomes public information, is not maintained or treated as confidential, and that you should exercise caution when deciding to disclose your personal information.

Information you provide to us may include but is not necessarily limited to the following:

• Identifiers
  • Contact information, such as name, physical address, phone number, email address, and emergency contact information.
  • Family and other social information, such as information about personal and familial relationships and dynamics.
     
• Educational information
   
• Information relating to education, such as school(s) attended, transcripts, school activities, scholarly work, course selections, and disciplinary records.
   
• Academic, non-academic, and curricular and extra-curricular education related information, such as prior and existing performance and performance evaluation, curricular, educational and developmental needs and plans, involvement and participation in classroom, non-classroom, and other SYA related activities, conduct, discipline, and other education related information.
   
• Audio and Visual Information
  • Photographs, audio, and/or video recordings you have sent us for identification or use in SYA files.
  • Photographs, audio, and/or video recordings of you while abroad or at SYA events.
     
• Sensitive personal information, including:
  • Information about your race, ethnic origin, national origin, citizenship, immigration status, gender, date of birth, and passport number or national identity card details.
  • Information about your health and medical conditions (e.g., disability and dietary needs), including medical records.
  • Financial information, including financial account information necessary for collection and payment of tuition and other costs, fees and expenses, financial aid information, and payment information related to donations, including credit or debit card type, expiration date, card number, billing address.
     
• Donation information
  • Donation and pledge amount, and other information related to the donation and gifts

Information Automatically Collected Online

In addition to information that you choose to submit to us, we and/or our service providers may automatically collect and/or store certain information when you visit or interact with our website, open or click on emails we send you, or interact with our advertisements. This information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone, or other device whenever you visit or interact with our website.

We also allow certain third parties to place online tracking on our website following an internal approval process and only as permitted by SYA. The information collected from this tracking is used for analytics and advertising purposes, to assess the performance of the website, and to allow you to use and access the website. Please note that this Policy does not cover usage of your information collected by these third-party companies. You will need to contact these third-party companies directly for more information about their privacy policies and your choices regarding the information they collect.

Information we collect online may include but is not necessarily limited to the following:

• Information collected via online communications
  • Contents of communications, e.g., webchats, emails, text messages, letters, and/or phone calls.
     
• Device information
  • IP address, URL address, unique device identifiers, geolocation, device and/or browser settings, and other information regarding your interactions with our website.
     
• Cookies
  • To enhance your online experience with us, our website may now or in the future use "cookies." Cookies are text files that our web server may place on your hard disk to store your preferences or help us improve our services. Cookies make it easier for you to use our services by saving your preferences so that we can use these to improve your next and subsequent visits to our services.
    
    You can set your browser to notify you when you receive a cookie, allowing you to accept/reject the cookie and to delete it when you leave our website. However, if your browser does not accept cookies, you may not be able to take advantage of all of the features of our website.
    
    For more information about cookies and how to control and delete cookies in various browsers, you can visit https://aboutcookies.org/. This website is not affiliated with us.
     
• Pixels, Web Beacons
  • A Web Beacon is a small tag (which may be invisible to you) that may be placed on our website’s pages and messages. We or third-party partners may use invisible pixels or beacons on our website to count how many users access or use certain pages, features, or content. This information is collected and reported in the aggregate. We may use this information to improve our current service offerings, develop new services, and target information to you that may be helpful and useful to you based upon your use of our services.
     
• Third-Party Analytics
  • We may use third-party analytics tracking technologies and tools to collect information about how you use our website, such as the frequency of visits, pages viewed, traffic data, location, referring and exit pages, and error information. These tools may also collect device information, discussed above. These tools examine website activities to prepare usage reports, and this information helps us improve our website and enhance user experience. Tracking information will be shared with the third-party analytics provider, which may use that information for its own purposes, potentially including marketing or advertising. While the tracking information we collect through such tools is not sufficient on its own for SYA to identify you, the third-party analytics provider may be able to combine it with other data it has to identify you.

If you would like to limit the ability of tracking technologies and tools to track your activity on our website, you can either configure your preferences for cookie settings on our website, or disable cookies in your Internet browser settings, although doing so may impact the performance and effectiveness of our website or other websites. Additionally, Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the preferences or settings page of your web browser. However, these features are not yet uniform, so we do not currently respond to such features or signals. Therefore, if you select or turn on a “do not track” feature in your web browser, we and our third-party providers may continue collecting information about your online activities as described in this Policy.

Information Provided by Third Parties

We may receive personal information about you directly from a third party, such as an educational institution with which you are or have been affiliated, including those a student is currently attending and those a student attends while abroad. We may also receive information from a health clinic, hospital, medical provider, or service provider that you authorize to provide such information to us. We use that information to provide our services to you. To the extent that you wish for us to stop receiving information from any third party, please contact the third party directly. To the extent you have inquiries or requests with respect to SYA’s use of your information, please contact us as described above.

Additionally, we may receive information from certain service providers that collect information from you on our behalf and at our direction. For example, we use the third party payment services of FACTS and Finalsite for tuition payments and Stripe and GiveCampus for donations. We do not have access to your full credit card number, PayPal, Venmo, Apple Pay, or Google Pay data stored by FACTS, Finalsite, Stripe or GiveCampus but may receive truncated credit card number or other identifying information from them. For more information on how payments are handled, and to understand the data security and privacy protections afforded to such information, please refer to FACTS privacy policy; Finalsite privacy policy; Stripe privacy policy; and GiveCampus privacy policy.

We primarily use personal information (including sensitive personal information) we collect from and about you to fulfill the requested services or otherwise manage our relationship. We may also use your information as otherwise necessary for the performance of our duties in carrying out our mission, vision, and values, our strategic plan, and our policies, as well as to fundraise, and for other legitimate business purposes. Further, we may use your information as necessary to comply with our obligations under applicable law, because you have provided consent for us to do so, and/or to protect your interests and/or the interests of others. We may use anonymized and aggregated information that may be created or derived from your personal information or usage of our services for any business purpose.

Specifically, we may use your information for the following purposes:

• Recruiting and/or admitting you as a student with SYA
   
• Facilitating academic matters, including for:
  • The provision of our teaching, learning, and research services (e.g., registration, assessment, attendance, managing progress, discipline investigations, certification, and graduation).
  • Maintaining student records.
  • Assessing your eligibility for financial aid.
  • Connecting students with host families, extracurricular activities, and medical providers.
     
• Providing support of our core services in non-academic matters, including:
  • Safeguarding and promotion of students’ welfare.
  • Ensuring students’ safety and security.
  • Managing student housing.
  • Managing the use of social media.
     
• Administering finances, such as tuition, fees, and financial aid.
   
• For marketing and promotional purposes, for example photographs, audio, and/or video recordings of you may be used in marketing and promotional materials.
   
• Providing other administrative functions, such as:
  • Carrying out research and statistical analysis.
  • Carrying out audits to ensure compliance with our regulatory and legal obligations.
  • Providing operational information.
  • Promoting our services.
  • Preventing and detecting crime.
  • Dealing with disciplinary actions.
  • Dealing with complaints and inquiries.
     
• To communicate with you.
   
• Send marketing or advertising communications by email and postal mail.
   
• To monitor and evaluate the performance and effectiveness of SYA, including by training our employees or monitoring their performance.
   
• To maintain and improve the academic, administrative, financial, and human resource management of the SYA program.
   
• To promote diversity, equity, and inclusion throughout SYA.
   
• To seek advice on our legal rights and obligations and to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other students or faculty, visitors to SYA, or anyone else who could be harmed by such activities.
   
• To maintain and service your account/file, provide customer service, and obtain data analytics.
   
• To identify and repair errors that impair existing intended website functionality.
   
• To promote security and integrity (for example, detecting security incidents, detecting and protecting against fraudulent and deceptive activity, and prosecuting those responsible).
  • For the prevention and detection of fraud or crime.
  • In order to assist with investigations (including criminal investigations) carried out by the police and other responsible authorities.
     
• Where it is necessary for emergency medical purposes.
   
• Where it is necessary to protect your or another person’s vital interests.

We do not sell personal information to third parties.

Except as necessary or appropriate to provide services, SYA does not disclose your personal information to any third party. We may disclose personal information with certain third parties who we engage to help us run our programs and perform the services, including for the following purposes and in the following circumstances.

• SYA Affiliates
  • We may share your personal information within the SYA organization and affiliates, for example, but not limited to, online academic and educational providers.
     
• SYA Campuses Abroad
  • Student information relating to their identifiers, academic information, and medical information is shared with the campus hosting the study abroad program. The host campus abroad may, as necessary to support the program, share relevant information with other third parties, including but not necessarily limited to the following: host families, medical personnel, and extracurricular or athletic program service providers.
     
• Schools and Families
  • We may share student academic reports and program information with sending schools and parents or guardians where appropriate.
     
• Third-Party Service Providers
  • For the purpose of operating our programs, we may transfer your personal information to our third-party service providers who use that information only to conduct SYA business. For example, these service providers may handle SYA credit card processing, invoicing, data management, email distribution, information analysis, promotions management, marketing, internal and external website hosting, software, and other services for SYA. We only provide our service providers with the information they need to perform their services and work with them to respect and protect your information.
     
• Images
  • Share daily life images and videos with SYA's sending schools, the SYA community, SYA website and social media, printed promotional materials.
     
• Legal Requirements and Security
  • If required to do so by Data Privacy Law, any other law, rule, or regulation, legal process or warrant, or order of any court or governmental agency or authority.
  • To enforce our policies, or to protect our or others' rights, property, or safety.
  • To assist in fraud protection or investigation.
  • To child safety and public health agencies, authorities, and officials.
  • To professional service providers, including attorneys, accountants, tax professionals, financial advisers, public relations and media advisers, and consultants, if doing so is necessary or appropriate to obtain professional services from them.
     
• Where You Direct Us To
  • If directed to do so by the individual about whom the personal information pertains, the parents or legal guardians of the student about whom the personal information pertains, and that individual’s or student’s legal representatives.
     
• Site Monitoring
  • Web analytics providers who monitor and analyze the use of our services (including Google Analytics). For more information about Google Analytics, please visit www.google.com/policies/privacy/partners.
     
• Organizational Transfers
  • In connection with a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation of SYA. If we are subject to a merger or acquisition with/by another organization, we may share information with the other organization in connection with the transaction, and your personal information may be transferred to such organization upon completion of the transaction. Such acquiring organization right to use your personal information shall be limited to the terms of this Policy unless additional Policy is provided to you.

The following chart details which categories of personal information we collect and process, as well as which categories of personal information we disclose to third parties, including service providers and vendors, for our operational business purposes, including within the 12 months preceding the date this Policy was last updated. We do not "share" personal information for purposes of cross-context behavioral or targeted advertising.

SYA processes personal information for several different purposes and legal bases, including in order to fulfill our statutory, contractual, common law, and other commercial and legal relationships and duties, including providing services; in connection with your or another person’s vital interest; and in connection with public interest.

If and to the extent necessary and not prohibited by Data Privacy Law, SYA also may process personal information for one or more of the following reasons: comply with local, state, federal, or foreign laws, rules, or regulations; comply with a civil, criminal, judicial, executive, legislative, agency, or other regulatory inquiry, investigation, subpoena, summons, or other legal process; cooperate with a law enforcement agency or authority concerning conduct or activities that SYA in good faith believes may violate a local, state, federal, or foreign law, rule, or regulation; investigate, establish, exercise, prepare for, or defend any allegation or claim concerning conduct that SYA in good faith believes may violate a SYA rule or policy or a local, state, federal, or foreign law, rule, or regulation; protect an interest that is essential for the life or physical safety of the individual, Student, or another person; detect, respond to, prevent or protect against illegal or unlawful activity, fraud, harassment, malicious or deceptive activities, identity theft, or other any other security incident; create, evaluate, develop, improve, enhance, and otherwise manage the services; and engage in other educational, academic, curricular, extra-curricular, business, operational, financial, technological, and other activities that are or should be reasonably aligned with the expectations of individuals, reasonably anticipated based on your relationship with SYA, or otherwise compatible with the processing of personal information in furtherance of providing the services.

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. Any transmission of personal information is at your own risk.

We will retain your personal information only for as long as is necessary for the legitimate business purposes set out in this Policy. We will retain and use your personal information to the extent necessary to comply with our legal, accounting, or reporting obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. Additionally, we may continue to store your personal information contained in our standard back-ups.

Factors that may be relevant to determining how long we keep personal information include:

• The purposes for which we collected it;
   
• The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you are an active student with us or keep using our services) and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise;
   
• Your preferences and how you engage with our sites and services;
   
• Any applicable legal or regulatory requirements; and
   
• Whether we need the information for our business purposes, or to protect our rights (for example, in actual or potential litigation).

Depending upon the US state or country in which you reside, you may have specific rights under applicable law, including the right to access, correct, or delete the personal information we hold about you. Only you, or someone legally authorized to act on your behalf, may make a verifiable request related to your personal information. Please understand that we may verify your request and may require you to provide some information to enable us to carry out such verification. We may not be able to 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 if we have reasons to have doubts about  your identity.

If we refuse to take action on a request to exercise your rights, in accordance with applicable law you may appeal our refusal to us within a reasonable period of time. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions, within the time period specified in the applicable state law. If the appeal is denied, we will also provide you with information about how to contact your Attorney General to submit a complaint.

Additional Information for Residents of Certain US States

Depending on which state you live in, you may have certain rights with respect to personal information that we have collected and used under certain circumstances. Where an applicable US state privacy law or similar legal requirement applies to the processing of your personal information, your rights may include the following:

• The right to review and access your personal information.
   
• The right to receive a copy of your personal information in a usable format and transmit it to a third party (known as the right of data portability).
   
• The right to request us to erase your personal information when we no longer need such data in connection with our services (subject to certain exceptions that may apply under applicable law).
   
• The right to opt out of sales of your personal information.  Note: SYA does not sell your personal information.
   
• The right to correct any inaccuracies related to your personal information.
   
• The right to limit the use and disclosure of your sensitive personal information.
   
• The right to opt-in for sensitive data processing.
   
• The right to opt-out of being profiled using automated decision-making technology based on your work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. Note: SYA does not use automated decision-making technology.
   
• The right to opt out of targeted advertisements selected based on personal information from your activities over time and across nonaffiliated websites or online applications.
   
• The right to opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. Please note that we do not use your personal information to profile you in any way that produces legal or similarly significant effects>

If you are a resident of a US state where one or more of these rights are granted to you under applicable law, and you wish to exercise any such rights listed above, please contact our Registrar and School Operations Manager as follows:

Name: Grace Saravia
Address: 120 Water Street, Suite 310, North Andover, MA01845
Phone number: 978.725.6828 ext. 134
Email address: gsaravia@sya.org

Additional Information for European Residents

Users residing in the European Economic Area may have rights under the General Data Protection Regulation (“GDPR”) and other applicable privacy laws. To the extent the GDPR applies to our organization, SYA is a data “Controller” and you are a “Data Subject” with certain protected privacy rights concerning your personal data. If and to the extent we transfer personal information of individuals in the European Union to the United States, we take steps to make sure that appropriate safeguards are in place to protect your personal information and comply with applicable law. By submitting your personal information on our site and participating in any SYA programs or services, you consent to the transfer to and the processing of your personal information in the United States. 

You may have the following rights under the GDPR:

• The right to access - the right to request copies of your personal information.
   
• The right to rectification - the right to request that we correct any information you believe is inaccurate. This includes the right to request us to complete information you believe is incomplete.
   
• The right to erasure - the right to request that we erase your personal data, under certain conditions.
   
• The right to restrict processing - the right to request that we restrict the processing of your personal data, under certain conditions.
   
• The right to object to processing - the right to object to our processing of your personal information, under certain conditions. 
   
• The right to data portability - the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you would like to exercise any of these rights, please contact our Registrar and School Operations Manager as follows:

Name: Grace Saravia
Address: 120 Water Street, Suite 310, North Andover, MA01845
Phone number: 978.725.6828 ext. 134
Email address: gsaravia@sya.org

We do not knowingly collect personally identifiable information from anyone under the age of 13 without the consent of the child’s parent or guardian, and we do not target the services to children under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with personal information without your consent, please contact us though one of the methods listed under “How to Contact Us” above. If we become aware that we have collected personal information from Children without verification of parental consent, we take reasonable steps to remove that information from our servers

You can opt out from receiving future marketing communications from us at any time by using the unsubscribe function in the email you receive from us or contacting us as set forth under “How to contact us” above. Please allow sufficient time for your preferences to be processed. Even if you opt out of receiving marketing messages, we may still contact you for administrative purposes like confirming or following up on an application, asking for feedback, or other notifications regarding your participation in SYA’s services. If you later opt back into getting marketing communications from us, we will remove your information from our opt-out databases.

Our services contain links to third-party websites. If you click on one of those links, you will be taken to websites we do not control. This Policy does not apply to the information practices of those third-party websites. You should read the privacy policies of third-party websites carefully. We are not responsible for the content, privacy policies, actions, or security of third-party websites.

SYA does not use automated decision making or profiling in the processing of personal information and does not make decisions that affect you based on automated decision making or profiling using personal information.

Agreement to Receive Text Messages
By providing your mobile number, you agree that SYA may send you periodic SMS or MMS messages containing but not limited to important information and updates.
 ● You will receive up to 4 messages per month.
● You may unsubscribe at any time by texting the word STOP to the message you recieve. You may receive a subsequent message confirming your opt-out request.
● For help, send the word HELP to syaadmissions@sya.org.
● Message and data rates may apply.
● United States Participating Carriers Include AT&T, T-Mobile®, Verizon Wireless, Sprint, Boost, U.S. Cellular®, MetroPCS®, InterOp, Cellcom, C Spire Wireless, Cricket, Virgin Mobile and others.
● T-Mobile is not liable for delayed or undelivered messages.
● You agree to notify us of any changes to your mobile number and update your account with us to reflect this change.
● Data obtained from you in connection with this SMS service may include your cell phone number, your carrier’s name, and the date, time and content of your messages, as well as other information that you provide. We may use this information to contact you and to provide the services you request from us.
● By subscribing or otherwise using the service, you acknowledge and agree that we will have the right to change and/or terminate the service at any time, with or without cause and/or advance notice. If you have any questions please contact SYA at syaadmissions@sya.org .
Will I be charged for the text messages I receive?
Though SYA will never charge you for the text messages you receive, depending on your phone plan, you may see some charges from your mobile provider. Please reach out to your wireless provider if you have questions about your text or data plan.