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Privacy Policy

Manhattan Studies Institute

 Privacy Policy Notice

 1. INTRODUCTION

  This privacy notice provides you with details of how we collect and process your personal data through your use of our sites https://manhattanstudies.biz, http://manhattanstudies.org , https://hypertraining.net including any information you may provide through our site when you purchase a product or service, sign up to our newsletter or take part of our free access or competition.

 By providing us with your data, you warrant to us that you are over 13 years of age.

  Manhattan Studies Institute is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

  We have appointed a Data Protection Officer who is in charge of privacy related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out below.  

 

Contact Details

 Our full details are:

 Full name of legal entity: Manhattan Studies Institute (MSI)

 Name or title of Data Protection Officer: Alex Stefan 

Email address: astefan@manhattanstudies.org

Postal address: 48 Wall St, 11th floor, New York, New York, 10005

Phone number: 646-397-1655

  If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information your EU supervisory authority for data protection issues, please find your supervisory authority . We should be grateful if you would contact us (Data Protection Officer) first if you do have a complaint so that we can try to resolve it for you.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at office@manhattanstudies.org OR update on http://manhattanstudies.org

  1. WHAT DATA DO WE COLLECT ABOUT YOU

 Personal data means any information capable of identifying an individual. It does not include anonymised data.

 We may process certain types of personal data about you as follows:

  • Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.
  • Contact Data may include your billing address, delivery address, email address and telephone numbers.
  • Financial Data may include your bank account and payment card details.
  • Transaction Data may include details about payments between us and other details of purchases made by you.
  • Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
  • Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
  • Usage Data may include information about how you use our website, products and services.
  • Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.

We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.

Sensitive Data

 We need to collect Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

 We need to collect the following sensitive data about you in order to receive admission for US Embassy Interview and to be registered on SEVIS

We need to collect Complete Application File, consisting of:  

  • Application Form (request by email the admission package)
  • High school diploma - legalized (notarized) copy
  • High school & all previous colleges/universities attended transcripts - must be received eight weeks before student program start date
  • Certificates from any corporate education training programs or professional development
  • Language certificate (TOEFL: 79 IBT, IELTS: 5.0)* or official letter from English professor attesting English proficiency or Enroll in our in-house English Evaluation
  • Resume (CV) in English
  • Medical certificate (vaccinations for measles, mumps, and rubella)
  • Medical Insurance
  • 3 photos (passport size) or electronic version 
  • Passport Copy
  • Financial Statement or Affidavit of Support for all expenses (tuition and accommodation)

 We require your explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication asking for you to confirm your consent to this processing.

 Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

  1. HOW WE COLLECT YOUR PERSONAL DATA

We collect data about you through a variety of different methods including:

  1. Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
  • order our products or services;
  • create an account on our site;
  • subscribe to our service or publications;
  • request resources or marketing be sent to you;
  • enter a competition, prize draw, promotion or survey; or
  • give us feedback.
  • Personal information you give to us:
  1. Student/Membership

When you become an MSI member, we collect information about you including (but not limited to) your name, your employer’s name, your work address (including your country location), and your email address. We may also collect your personal email address, a personal mailing address, and a mobile phone number. We ask members to voluntarily provide additional information in their membership profile, such as information about their educational background, number of years in privacy, and the like. Members may edit their profile at any time to change, add, or remove personal information.

We process your personal information for membership administration, to deliver member benefits to you, and to inform you of MSI-related events, content, and other benefits or opportunities associated with your MSI membership. The MSI may also use this information to help the MSI understand our members’ needs and interests to better tailor our products and services to meet your needs.

Members often participate in local/online Hyper-training meetings. These meetings are organized by volunteers and take place at various locations that donate their space for the meetings. The MSI collects registration information from MSI members and their guests, which it shares with the Hyper-training chairs and location hosts for purposes of verifying registration and to ensure only registered guests are allowed attendance.

 

  1. Live events and web conferences

The MSI hosts many events throughout the year. These include in-person conferences like the Global Privacy Awareness and the Data Protection Community, for example, as well as live web conferences (collectively “events”). If you register for one of our events and you are a member/student, we will access the information in your member/student account to provide you with information and services associated with the event. If you are not a member and you register for one of our events, we will collect your name and contact information, which we will store in our database(s) and use to provide you with information and services associated with the event.

If you are a presenter at one of our events, we will collect information about you including your name, employer and contact information, and photograph, and we may also collect information provided by event attendees who evaluated your performance as a presenter. We may also make and store a recording of your voice and likeness in certain instances.

We keep a record of your participation in MSI events as an attendee or presenter. This information may be used to provide you with membership and certification services (such as, for example, keeping track of your Continuing Privacy Education (CPE) credits, or to tell you about other events and publications). It may also be used to help the MSI understand our members’ needs and interests to better tailor our products and services to meet your needs.

In association with attending one or more of our conferences, you will have the option to download the “MSI Events App” to help you navigate the conference and plan your schedule. The MSI Events App may require the device identifier associated with your device but does not collect or use any other personal data.

Some of our events are sponsored. The MSI provides an attendee list to sponsors, co-sponsors and exhibitors of our events. The MSI may also allow sponsors, co-sponsors and/or exhibitors to send you material by mail once per sponsored event, in which case the MSI engages a third-party mailing house and does not share your mailing address directly with the sponsor/exhibitor. If you do not wish to have your information included in an attendee list or to receive information from sponsors, co-sponsors and/or exhibitors, you can express your preferences when you register for events or you may contact the MSI DPO directly at office@manhattanstudies.org.

 

  1. Publications

The MSI offers a great deal of content for our members/students. In addition to producing original content, the MSI also subscribes to news feeds and blogs produced by others, which we often link to from our website. This means you may find yourself on the MSI website or reading an email from the MSI publications team and we will offer you a link to another organization’s website where you will find content on privacy or data protection that we find relevant and useful to you. At these times, you will be leaving the MSI website. The MSI is not responsible or liable for content provided by these third-party websites or personal information they may happen to gather from you.

You may wish to subscribe to the MSI’s publications without becoming a member of the MSI. For example, many people sign up to receive the MSI’s Daily Dashboard even though they are not MSI members. To receive MSI newsletters by email, you will need to create a “profile” with us which involves providing the MSI with at least your first name and last name, an email address, and the country in which you live. The MSI does not share this information with any third party other than to store the information in our cloud-hosted databases.

You may manage your MSI subscriptions by subscribing or unsubscribing at any time. Please note that if you have set your browser to block cookies, this may have an impact on your ability to unsubscribe. If you have any difficulties managing your email or other communication preferences with the MSI, please contact us at office@manhattanstudies.org.

The MSI uses Google Analytics to track how often people gain access to or read our content. We use this information in the aggregate to understand what content our members find useful or interesting, so we can produce the most valuable content to meet your needs.

We also conduct surveys that we use to produce original research on the privacy profession. We do not track individuals but look at information in the aggregate only. Participation in surveys is voluntary.

 

  1. Training/ Online certification programs

If you participate in MSI training, you may sign up directly through the MSI in which case we collect your name and contact information directly from you. You may, alternatively, sign up for training – or be signed up for training – by or through a third party such as one of our training partners, or your own employer. We may also use independent contractors to conduct the training and third parties to provide the training venue. Your personal information will be stored in our database (hosted by cloud service provider) and may also be shared with our training partners, trainers, and/or the venue hosting the event (to verify your identity when you arrive). The MSI’s training partners, trainers, and training venue hosts have agreed not to share your information with others and not to use your personal information other than to provide you with MSI products and services.

 

  1. Certification

When you sign up to take one of the MSI’s certification exams, we will collect your name and contact information. We will also collect and store information you provide to us about your need for special accommodations. This information may be shared with our computer-based exam hosting service. The computer-based exam hosting service may also share with us information you provide to them to verify your identity in taking the exam. The MSI will collect your exam results and, in conjunction with maintaining your certification(s), your record of participation in continuing privacy education. Only authorized employees within the MSI have access to your certification exam scores and personal information pertaining to any special accommodations you may request.

 

  1. Your correspondence with the MSI

If you correspond with us by email, the postal service, or other form of communication, we may retain such correspondence and the information contained in it and use it to respond to your inquiry; to notify you of MSI conferences, publications, or other services; or to keep a record of your complaint, accommodation request, and the like. As always, if you wish to have the MSI “erase” your personal information or otherwise refrain from communicating with you, please contact us at office@manhattanstudies.org.

Note: if you ask the MSI not to contact you by email at a certain email address, the MSI will retain a copy of that email address on its “master do not send” list in order to comply with your no-contact request.

 

  1. Purposes for processing your data

As explained above, the MSI processes your data to provide you with the goods or services you have requested or purchased from us, including membership services, events, publications and other content, certification, and training. We use this information to refine our goods and services to better tailor them to your needs and to communicate with you about other services the MSI offers that may assist you in your career or otherwise help you do your job as a privacy professional.

 

  1. Payment card information

You may choose to purchase goods or services from the MSI using a payment card. Typically, payment card information is provided directly by users, via the MSI website, into the PCI/DSS-compliant payment processing service to which the MSI subscribes, and the MSI does not, itself, process or store the card information. Occasionally, members or customers ask MSI employees to, on their behalf, enter payment card information into the PCI/DSS-compliant payment processing service to which the MSI subscribes. We strongly encourage you not to submit this information by email. When MSI employees receive payment card information from customers or members by email, fax, phone, or mail, it is entered as instructed and then deleted or destroyed.

 

  1. Personal information we get from third parties

From time to time, the MSI receives personal information about individuals from third parties. This may happen if your employer is a corporate member of the MSI and signs you up for training, certification, or membership. One of our third-party training partners may also share your personal information with the MSI when you sign up for training, certification or membership through that training partner.

 

  1. What happens if you don’t give us your data

You can enjoy many of the MSI’s services without giving us your personal data. Much of the information on our website is available even to those who are not MSI members. You can even enter only the minimal amount of information (name and contact information) to your MSI member profile if you wish, and you can edit your profile at any time. Some personal information is necessary so that the MSI can supply you with the services you have purchased or requested, and to authenticate you so that we know it is you and not someone else. You may manage your MSI subscriptions and you may opt-out of receiving marketing communication at any time.

 

  1. Automated technologies or interactions

 As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our cookie policy for further details.

 

  • Technical Data from the following parties:

    Aweber, Google AdWords

 

  • analytics providers such as Google Analytics based outside the EU;

 

  • advertising networks [such as Facebook, Google AdWords based outside the EU]; and

 

  • search information providers [such as Google, Facebook based outside the EU].

 

  1. HOW WE USE YOUR PERSONAL DATA

 

We will only use your personal data when legally permitted. The most common uses of your personal data are:

 

  • Where we need to perform the contract between us.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

 

Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at office@manhattanstudies.org

 

 

  1. Purposes for processing your personal data  

 

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

 

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at office@manhattanstudies.org if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity

 

Type of data

 

Lawful basis for processing 

 

To register you as a new customer

 

(a) Identity

(b) Contact

 

Performance of a contract with you

 

 

 

 

 

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

 

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests to recover debts owed to us

 

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

 

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services

 

To enable you to partake in a prize draw, competition or complete a survey

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business

 

To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

(a) Identity

(b) Contact

(c) Technical

 

(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise

(b) Necessary to comply with a legal obligation

 

To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

 

Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy

 

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

 

(a) Technical

(b) Usage

 

Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy

 

To make suggestions and recommendations to you about goods or services that may be of interest to you

 

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

 

Necessary for our legitimate interests to develop our products/services and grow our business

 

 

  1. Marketing communications 

 

You will receive marketing communications from us if you have:

 

  • requested information from us or purchased goods or services from us; or
  • if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
  • in each case, you have not opted out of receiving that marketing. 

 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

  

You can ask us or third parties to stop sending you marketing messages at any time   by emailing us at office@manhattanstudies.org  at any time.

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

 

  1. Change of purpose  

 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at office@manhattanstudies.org .

 

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

 

We may process your personal data without your knowledge or consent where this is required or permitted by law.

 

  1. DISCLOSURES OF YOUR PERSONAL DATA

 

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

 

  • Other companies in our group who provide IT and system administration services and undertake leadership reporting.
  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

 

  1. INTERNATIONAL TRANSFERS

  

We share your personal data within our group of companies which involves transferring your data outside the European Economic Area (EEA).]  

  

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

 

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

 

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

 

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
  • Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Please email us at office@manhattanstudies.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Transferring personal data from the EU to the US

The MSI has its headquarters in the United States. Information we collect from you will be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. The IAPP relies on derogations for specific situations as set forth in Article 49 of the GDPR.

In particular, the MSI collects and transfers to the U.S. personal data only: with your consent; to perform a contract with you; or to fulfil a compelling legitimate interest of the MSI in a manner that does not outweigh your rights and freedoms. The MSI endeavours to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with the MSI and the practices described in this Privacy Policy. The MSI also minimizes the risk to your rights and freedoms by not collecting or storing sensitive information about you.

 

  1. DATA SECURITY

 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

  1. DATA RETENTION

  

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

  

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

 

In some circumstances you can ask us to delete your data: see below for further information.

 

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

  1. YOUR LEGAL RIGHTS

 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

 

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at office@manhattanstudies.org.

  

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

  

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

  

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

  1. THIRD-PARTY LINKS

 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

  1. COOKIES

 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see MSI COOKIE POLICY.