PUTNEY STUDENT TRAVEL
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.
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
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
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:
- 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.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- 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 email@example.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.
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.
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