Privacy Policy

PUTNEY STUDENT TRAVEL
(www.goputney.com)

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.

6. 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).

6a. 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.

6b. 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 dsar@goputney.com

Only you 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.

6c. 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.

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.