Privacy Policy

Effective Date: April 23, 2019

This Privacy Notice is provided by the Trustees of Phillips Academy (“Andover”, “we” or “us”) to inform you about how we collect, use, maintain and disclose information collected from users (each, a “User”, or “you”) of the Services.

BY PROVIDING YOUR PERSONAL DATA TO ANDOVER OR OTHERWISE USING OUR SERVICES, YOU AGREE TO THE TERMS OF THIS PRIVACY NOTICE AND OUR WEBSITE.

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1. SCOPE AND DEFINITIONS

When we say “Services,” we mean:

  • The websites owned and controlled by us that link to this Privacy Notice, including http://www.andover.edu (“Sites”);
  • Prospective student and employee application processes (“Application Activities”); and
  • Alumni/ae and prospective student activities, including events we host, surveys and social media, telephone and email campaigns we engage in (“Marketing Activities”).

When we use the term “Personal Data,” we mean any information that can be used to identify you, directly or indirectly, as an individual person.

We collect Personal Data about the following types of individuals:

  • Alumni/ae and family of alumni/ae;
  • Prospective students, family members of prospective students and recommenders of prospective students;
  • Individuals applying for or inquiring about employment with us;
  • Visitors to our Sites and users of any digital services we provide; and
  • Any other individuals who interact directly with Andover or its business partners.

Please note that this Privacy Notice does not cover or apply to our processing of information about students, including academic records, or information about employees or contractors.

Andover may provide additional privacy notices to individuals at the time we collect their data. For example, we often provide a specific privacy notice to participants in research studies during the consent process that describes our privacy practices in connection with the study. This type of an “in-time” notice will govern how we may process the information you provide at that time.

2. THE INFORMATION WE COLLECT AND USE

We collect and use Personal Data from Users in the following ways:

a) Data Provided By You

We collect and use Personal Data that you provide to us in the following ways:

  • Communications. If you communicate with us through the website or by email, mail, phone, text, chat, or any other paper or electronic form, we collect your contact information, such as your name, address, email address and phone number, the content of the communication and the metadata associated with the communication. We use this information to investigate and respond to your inquiries and to communicate with you.
  • Newsletters. If you are registered to receive a newsletter, we collect your contact information, applicable interests and communication preferences. We use this information to manage our communications with you. If you wish to stop receiving email messages from us, please see the “Privacy Preferences" section below.
  • Application. In order to apply to Andover as a prospective student, we collect contact information, demographic information, such as geographic location, date of birth, gender, and application content, including academic history, standardized test scores, information obtained during admission interviews, short answers and essays, parental statements and consent forms, recommendations, and financial aid information. We use application information to contact the relevant parties with information regarding the application or to request additional information, to evaluate the applicant’s eligibility for admission, and facilitate and administer admissions-related events and initiatives.
  • Registration. If you register for an account to request a campus tour or schedule an interview, we collect your name, contact information, date of birth and account password. We use this information to administer your account, process and facilitate your request for a tour or interview and to communicate with you about your requests.
  • Research. We conduct research to understand how our operations and Services impact our alumni/ae and to compare to other academies in the marketplace. We may use personal data you provide as a prospective student or alum, or other personal data you directly provide to us to assist in such research. We use this information for academic research purposes, to benchmark our performance against competitors and to improve our facilities, operations and Services.
  • Employment Applications. If you submit an application for employment, we collect your contact and demographic information, education, background and work history, employment interests, information obtained during interviews and any other information you choose to provide. We use this information to evaluate your eligibility and candidacy for employment, to communicate with you before, during and after the relevant application process and to facilitate the application process and any hiring steps needed prior to employment.
  • Events. If you register for or attend any Andover event, such as an alumni/ae event, lecture, seminar, workshop or open house event, we collect your contact and demographic information, including education information and professional credentials. We use this information to register you in the program, prepare and administer the event, contact you about the event and to inform you about future events that may be of interest to you.
  • Donors. If you wish to make a gift to Andover, we collect your name, contact information and payment details, including the amount and recurrence of the gift. We use this information to process your gift, communicate with you regarding your gift and to maintain our internal records and accounts. If you wish to modify your recurring gift, please contact us using the information located in the “Contact Us” section below.
b) Data We Obtain from Third Party Sources

We collect Personal Data from the following third-party sources:

  • Business Partners and Service Providers: We collect information about Users from our business partners and service providers, including application management providers, standardized test administrators, website operators, references and recruiters. The information may include contact information, demographic information, health and medical information, educational and professional history, institutional affiliations, background checks and performance reviews. We use this information to administer and facilitate Application Activities, Marketing Activities, coordinate events and programs, conduct market research and to identify potential employment candidates.
  • Publicly Available Sources: We collect information about individuals from publicly available sources, such as our operations on social media platforms (for example, Facebook, Twitter, and Instagram) or publicly available research. This information enables us to conduct market research about the academy and industry trends, analyze public interactions with Andover, identify promoters and detractors and improve our programs, events, and other offerings.
c) Data We Collect Automatically

We use various technologies to collect other types of data about the device or browser you use to navigate our Sites, including:

  • Web Logs. As is true of many websites and email communications, we gather certain information automatically and store it in log files. This information may include IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and/or clickstream data. We use this data to analyze trends on our Sites, manage and administer the content, for security and availability of the Sites, improve the performance of the Sites, and for fraud protection and to protect our rights and the rights and safety of individuals.
  • Cookies and Other Data Collection Technologies. We and our service providers use cookies, scripts and similar technologies to manage the Sites and to collect information about you and your use of our Sites. These technologies help us to recognize you, customize or personalize your experience and analyze the use of our Sites to make them more useful to you. These technologies may also allow us to aggregate demographic and statistical data and provide this information to our service providers to facilitate their provision of services. Most Internet browsers allow you to remove or manage cookie functions and adjust your privacy and security preferences. For information on how to do this, access the “help” menu on your Internet browser, or access http://www.aboutcookies.org/how-to-control-cookies. Please note, however, that disabling our cookies may result in your inability to take full advantage of all of the features of our Sites.
  • Google Analytics: We use “Google Analytics” to collect information about use of this site. Google Analytics collects information such as how often users access the Services, what pages they access when they do so and what other sites they used prior to coming to the Services. We use the information we get from Google Analytics only to improve the Services. To learn more about the use of data collection technologies by Google for analytics and to exercise choice regarding those technologies, please visit the Google Analytics Opt-Out browser add-on page.
d) Other Uses of Personal Data

In addition to the uses described above, the Services may collect and use Users’ Personal Data for the following purposes:

  • To develop, maintain, improve and operate the Services;
  • To personalize the User experience;
  • To communicate with you to provide technical or administrative support;
  • To conduct, manage and grow our organization;
  • To conduct research on industry trends, engagement activities or to develop new resources;
  • To prevent, investigate and provide notice of fraud, unlawful or criminal activity, unauthorized access to or use of Personal Data, the Sites or our data systems, and to meet legal, regulatory, judicial and institutional policy obligations;
  • To investigate and resolve disputes and security issues and to enforce our Terms of Use; and
  • For any other lawful, legitimate business purpose.

4. HOW WE SHARE AND DISCLOSE PERSONAL DATA

We share Personal Data in the following ways:

  • Service Providers. We share Personal Data with third-party service providers who perform services on our behalf, such as application management providers, website operators, data storage and analytics providers, recruiters, background check providers, event coordinators, market research providers, and technology providers (including technology support providers, email communications providers and web operators and developers).
  • Regulatory or Legal Requirements, Safety and Terms Enforcement. We may disclose Personal Data to governmental regulatory authorities as required by law, including in connection with monitoring, review and approval of our tax-exempt status, in response to their requests for such information or to assist in investigations. We may also disclose Personal Data to third parties in connection with claims, disputes or litigation, when otherwise required by law, or if we determine its disclosure is necessary to protect the health and safety of you or us, to protect against fraud or credit risk, or to enforce our legal rights or contractual commitments that you have made.
  • Business Transfers. We may disclose Personal Data as part of an organizational business transaction, such as a merger, acquisition, joint venture, financing, or sale of organizational assets and may transfer Personal Data to a third party as one of the business assets in such a transaction. We may also disclose Personal Data in the event of insolvency, bankruptcy, or receivership.

4. PRIVACY PREFERENCES

If you have opted in to our email communications (or where permitted by law, if you have provided us or we have obtained your contact information for the purposes of marketing communications), you may choose to opt-out of receiving further commercial messages from us by following the unsubscribe instructions in the email you received. Please note that you may continue to receive certain transactional or administrative email communications from us.

5. REGION-SPECIFIC DISCLOSURES:

If you are located in the European Economic Area (“EEA”) or Switzerland, the following disclosures apply to the processing of your Personal Data.

a) Data Subject Rights: In certain cases, you may have a right to:

  • Access. The right to access and obtain a copy of Personal Data about you, as well as information relating to its processing;
  • Rectification. The right to correct or update any Personal Data about you that is inaccurate or incomplete;
  • Restriction of Processing. The right to restrict or limit the ways in which we process Personal Data about you;
  • Objection to Processing. The right to object to the processing of Personal Data about you;
  • Erasure. The right to request the deletion or erasure of Personal Data about you;
  • Portability. The right to obtain a copy of Personal Data about you in an easily accessible format and the right to transmit that Personal Data to another controller;
  • Withdrawal of Consent. Where the purpose of our processing of Personal Data about you is based on consent, you may also have the right to withdraw your consent to such processing.

To submit a request, please contact us as set forth in the Contact Us section below. We will respond to your request within a reasonable timeframe.

If you withdraw your consent to the processing of Personal Data about you, you may not have access to all (or any) of the Services, and we might not be able to provide you all (or any) of the Services. In some cases, withdrawing your consent may require you to close your registered account and discontinue the use of certain services. Please note that, in certain cases, we may continue to process Personal Data about you after you have withdrawn consent or requested that we delete Personal Data about you if we have a legal basis for the purpose of such processing. For example, we may retain certain information if we need to do so to comply with an independent legal obligation, or if it is necessary to do so to pursue our legitimate interest in keeping our services safe and secure.

If you have any complaints regarding our privacy practices, you may have the right to lodge a complaint with your national data protection authority.

b) Legal Basis of Processing

We process your Personal Data for the purposes described above on the basis of lawful grounds, including:

Consent
If Andover relies on consent for the processing of Personal Data, we will provide transparent notice of the purposes for which we seek such consent at the time we collect your Personal Data.

If Andover wishes to process any special categories of Personal Data as set out in Article 9(1) of the EU’s General Data Protection Regulation, Andover may obtain your explicit consent for such processing.

For information on how to withdraw consent, please see the “Privacy Preferences” section above.

Contractual Necessity
Andover processes Personal Data to fulfill our contracts with our donors, business partners and service providers, such as for rendering payment or communicating with business contacts.

Legal Obligation
Andover may process Personal Data as specifically required by applicable legal obligations, such as laws and regulations that require Andover to process Personal Data for purposes of obtaining charitable approvals.

Legitimate Interests
Andover may process Personal Data subject to its own legitimate interests, such as to develop, administer and support our Sites, Application Activities and Marketing Activities; to operate, evaluate and improve our organization; to facilitate and manage alumni/ae and prospective student programs; to promote research; to support our recruitment activities; cybersecurity; enforcing our legal rights; or to facilitate a sale of assets or merger or acquisition.

It may be also necessary for Andover to process Personal Data to establish, exercise or defend against fraud, illegal activity, and claims and other liabilities, including by enforcing the Terms of Use that govern the Services we provide.

c) Data Retention

We will retain your Personal Data for as long as is necessary for the purposes set out herein unless a longer period is required under applicable law, or is needed to resolve disputes or protect our legal rights or otherwise to comply with legal obligations.

  • Where we are processing Personal Data based on our legitimate interests, we generally will retain the data for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of the data subjects.
  • Where we are processing Personal Data based on your consent, we generally will retain the information for the period of time necessary to carry out the processing activities to which you consented, subject to your right, under certain circumstances, to have certain of your Personal Data erased.
  • Where we are processing Personal Data based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship.

d) International Data Transfers

Information collected through our Services is maintained in the United States. The countries to which we transfer Personal Data may not have the same data protection laws as the country in which you initially provided the information. By submitting Personal Data to Andover, you agree that Andover may maintain the information in the U.S. and share the Personal Data as described in this Privacy Notice.

6. THIRD-PARTY WEBSITES

Users may find links to third-party sites and content included in the Services. We do not control such links, sites or content and are not responsible for the practices employed by websites linked to or from the Services. In addition, these links, sites or content may be constantly changing, and may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to the Services, is subject to that website’s own terms and policies.

Our Sites also include features like buttons and widgets hosted by other companies (for example, the Facebook “share” button). Some of these features collect Personal Data or other information such as your IP address and your actions on our website. This Privacy Notice does not apply to the practices of these third parties. We encourage you to review the privacy notices of those third parties to learn about their Personal Data and privacy practices.

7. CHANGES TO THIS PRIVACY NOTICE

This Privacy Notice is subject to occasional revisions. We will notify you of changes by posting the new Privacy Notice on the Sites and updating the effective date of the Privacy Notice. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the Personal Data we collect. You acknowledge and agree that it is your responsibility to review this Privacy Notice periodically and become aware of modifications.

The updated Privacy Notice will be effective as of the “Effective Date” date listed at the top of the Privacy Notice.

Contacting Us

If you have any questions about this Privacy Notice or your Personal Data, please contact us at:

Business Office, Phillips Academy
180 Main Street
Andover, MA 01810

Email Address: Privacy@andover.edu

Phillips Academy Cookie Notice

Effective April 23, 2019

CONSENT

By using the Phillips Academy (“Andover”) website (located at www.andover.edu) and any other website (including mobile-optimized websites) owned or controlled by Andover and which link to this Cookie Notice (collectively, the “Website”), you consent to the use of cookies in accordance with this Cookie Notice.

COOKIES

Cookies are small amounts of data which your web browser stores on your device at the request of certain websites. Cookies are then sent back to the originating web domain on your subsequent visits to that domain. Most web pages contain elements from multiple web domains so when you visit the website, your browser may receive cookies from several sources.

Cookies are useful because they allow a website to recognize a user’s device. Cookies allow you to navigate between pages efficiently, remember preferences and generally improve the user experience. They can also be used to tailor advertising to your interests through tracking your browsing across websites.

There are two primary types of cookies that are used, session cookies and persistent cookies. Session cookies are deleted automatically when you close your browser and persistent cookies remain on your device after the browser is closed (for example to remember your user preferences when you return to the site). Each cookie typically falls into one of several categories.

TYPES OF COOKIES ANDOVER USES

We describe the categories of cookies Andover and its service providers use below.

Strictly Necessary Cookies

These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, Website pages you have asked for cannot be provided.

Performance Cookies

We make use of analytics cookies to analyze how our visitors use our Website and to monitor Website performance, including those by Google Analytics. This allows us to provide a high quality experience by customizing our offering and quickly identifying and fixing any issues that arise. For example, we might use performance cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages. We might also use these cookies to highlight site services that we think will be of interest to you based on your usage of the website. To learn more about the use of data collection technologies by Google for analytics and to exercise choice regarding those technologies, please visit the Google Analytics Opt-Out browser add-on page.

Website Functionality Cookies

We make use of cookies to provide you with certain functionality. For example, to recognize the platform from which you access the site, and to allow authenticated access to certain sections of the site. These cookies are not used to track your browsing on other sites.

DISABLING COOKIES

If you do not agree to the use of cookies that are not strictly necessary, most browsers allow you to control cookie tracking, typically under the sections "Help" or "Internet Options", or you can visit AboutCookies.org for more information. Please note that some of the Website services may not function properly if cookies are disabled. You may also opt out of third-party cookies where available by using the links provided in this Cookie Notice.

THIRD-PARTY WEBSITES

Please note that this Cookie Notice does not apply to, and we are not responsible for, the cookie practices of third-party websites that may be linked to this Website.

CHANGES TO THE COOKIE NOTICE

We may update this Cookie Notice and we would encourage you to review the notice from time to time to stay informed of how we are using cookies.