Privacy & Information Practices Policy
Effective starting 11 July 2018
We at Rare Book School (RBS) take your privacy and the security of your personal information seriously. This policy describes the information we may collect, the ways in which this information may be used and/or shared, and how you can correct or change this information.
We offer a range of educational programs, events, scholarships and fellowships, and online content as part of our mission to strengthen global communities of the book and to advance the study of cultural heritage. We also fundraise to support our nonprofit mission. We refer to all of these programs and associated fundraising activities as “programs” in this policy.
This policy also explains your choices about how we use your information. Your choices include how you can object to certain uses of information and how you can access and update certain information. In order to carry out our programs, we may collect and use information, some of which may be considered personal data in your country. Please note that you may choose not to provide us with certain information; by doing so, however, you may not be able to fully participate in RBS programs. By continuing to engage with RBS programs through our website(s), you agree to this policy, and certify that you understand the privacy implications of participating in RBS programs. Where necessary under applicable law, we may seek your consent by other means, such as by asking you to click on a button or to change a setting. Where we do so, we will also offer you a way to revoke your consent.
- Information we collect
- How we use information we collect
- How we share information we collect
- How we store and secure information we collect
- How to access and manage your information
- Cookie and tracking notice
- Other important privacy information
Information we collect
Information you provide to us
You provide information directly to us by applying for and/or registering for RBS programs, purchasing items through the RBS online store, making a donation to RBS, signing up for the RBS mailing list, or otherwise engaging with RBS-controlled websites or social media accounts.
We collect information about you when you register for an account in myRBS, create or modify your profile, set preferences, apply for RBS courses, &c. For example, you provide your contact information, emergency contact information, employment and education history, statement of interest and other relevant information when applying for RBS courses through myRBS. Similar types of information may be collected when you apply for RBS scholarships or fellowships, sign up for RBS programs using web forms on the RBS website or using third-party compliant service providers, or otherwise proactively engage with RBS programs.
Content you provide through our websites: Our programs include websites owned or operated by RBS. We may collect other content that you submit to these websites, which include social media accounts operated by us (Facebook, Twitter, YouTube, SoundCloud, &c.).
Payment information: We collect payment and billing information when you register for certain RBS programs. You may also provide payment information, such as payment card details, which we collect via secure payment processing services. We do not store any payment card details on our servers. We use PCI-compliant e-commerce transaction platforms to process payments securely.
Information we collect automatically
We use Google Analytics to keep track of certain information about you when you visit and interact with the primary RBS website, using analytics techniques that scrub the information to exclude information that might identify you. This information includes but is not limited to web pages you visit; the links and buttons you click on; search terms entered; and duration of visits.
Device and connection information: We collect anonymous information about your computer, phone, tablet, or other devices you use to access the RBS website. We also collect information through your device, such as about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data.
Information from other sources
We may receive information about you from third-party partners, such as advertising, philanthropy, and research partners who provide us with information about your potential interest in and engagement with RBS programs.
How we use information we collect
Below are the specific purposes for which we use the information we collect about you.
To provide educational programs: We use information about you to carry out RBS courses and programs, including to process applications for courses, programs, and scholarships/fellowships; authenticate you when you log into myRBS; provide support and online content via the RBS website; create name tags, labels, and other publications for use during RBS courses and programs; process purchases through our online store, tuition payments, &c.
For development and stewardship: We may send fundraising requests to people who have expressed an interest in RBS programs. As a donor to Rare Book School, your generosity makes our mission possible. We will not share, rent, or sell your personal information. We may use your data to manage your donation or membership and keep a record of your relationship with us. We may use your information and analyze our database to understand and steward our donors, their preferences, and their level of potential donations, to improve our programs, including messages, advertisements, fundraising appeals, events, and meetings we think will interest you. If you do not wish to receive fundraising solicitations, please contact our Development office at email@example.com.
To communicate with you about RBS programs: We may use your contact information to send communications via email and/or postal mail. General newsletters and announcements about RBS programs are sent using our mailing list provider, MailChimp. You may unsubscribe from these communications at any time using the “unsubscribe” link included in any RBS email sent via MailChimp. Communications relating to specific RBS programs to which you have applied—including but not limited to courses or scholarship/fellowship programs—are part of RBS programs and in most cases you cannot opt out of receiving these communications from individual RBS staff members or via our myRBS system.
To provide support: We may use your information to resolve technical issues you encounter, to respond to your requests for assistance, and otherwise to assist you in using RBS websites.
With your consent: We may use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured alumni/donor stories to promote RBS, with your permission.
Legal bases for processing (for EEA users):
If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the programs you use and how you use them. This means we collect and use your information only where:
- We need it to facilitate the RBS programs to which you have applied;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote RBS, or to protect our legal rights and interests;
- You give us consent to do so for a specific purpose; or
- We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we have a legitimate interest to do so, you have the right to object to that use, though this may mean that you will no longer receive communications from RBS.
How we share information we collect
Sharing as part of RBS programs
Certain personal information is shared in order to carry out RBS programming. For example, course applications and associated information are shared with course instructors; scholarship/fellowship applications are shared with selection committee members. Information related to registered course attendees may be shared with institutions hosting RBS programs as required by their security policies or requirements. The names and job information of course attendees/program participants are used to generate participant lists, name tags, and associated program materials. Participants may choose to omit their job title and contact information from the RBS Student’s Vade Mecum by changing their preferences in myRBS.
Sharing with third parties
We may share information with third parties that help us develop and implement RBS programs.
Partners: As outlined above, we may provide information about program participants to host institutions as required by their security policies or requirements. We may also provide contact information (name, email, and course title) to local booksellers; participants may opt out of this by changing their preferences in myRBS.
Links to third-party sites: The RBS website may include links that direct you to other websites or services whose privacy practices may differ from ours. If you submit information to any of those third party sites, your information is governed by their privacy policies.
Compliance with enforcement requests and applicable laws; enforcement of our rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet United States national security requirements; (b) enforce our agreements, policies and terms of service; (c) protect the security or integrity of our products and services; (d) protect Rare Book School or the public from harm or illegal activities; or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
How we store and secure information we collect
Information storage and security
Our websites and associated data are stored on servers located in the Commonwealth of Virginia. We also use cloud data hosting service providers in the United States to host certain information we collect and store, and we use technical measures and industry best practices to secure your data.
While we implement safeguards designed to protect your information, no security system is 100% impenetrable. We cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.
How long we keep information
How long we keep information we collect about you depends on the type of information in question.
Account information: We retain your myRBS account information, course and scholarship applications, and payment/donor history on a permanent basis, as necessary to comply with our legal obligations, to resolve disputes, to support our operations, to document organizational history, and to continue to develop and improve our programs. If your account is deactivated, some of your information will remain visible to RBS staff.
How to access and manage your information
You have certain choices available to you when it comes to your information.
Your choices: You have the right to request a copy of your information, to object to our use of your information (including for development and communications purposes), or to request the deletion or restriction of certain information. Below, we describe the tools and processes for making these requests. You can exercise some of these choices by logging into your myRBS account and using settings available within your account. For all other requests, you may contact us as outlined below.
Limitations: Your request and choices may be limited in certain cases. If fulfilling your request would reveal information about another person, or if you ask to delete information which we are required by law or have compelling legitimate interests to keep, for example, we may be unable to carry out your request in full. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work, or where you feel your rights were infringed.
Access and update your information: We give you the ability to access and update certain information about you from within your myRBS account. If you need to make updates beyond those which can be updated from within myRBS, please contact us as outlined below.
Deactivate your account: If you no longer wish to use myRBS, we can deactivate your account. Please contact us as outlined below to request deactivation of your account.
Delete your information: The ability to delete your information may depend on the RBS program(s) with which you have engaged. In some cases we may not be able to completely delete your information due to legitimate use. In those cases, we will make the best attempt to hide or anonymize your information. Please note, however, that we may need to retain certain information for record-keeping purposes, to complete transactions, or to comply with our legal obligations.
Request that we stop using your information: In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we do not have the appropriate right to do so. Where you have given us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place. You can also opt out of our use of your information for development purposes, by contacting us as provided below. When you make such requests, we may need time to investigate and facilitate your request. If there is delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved.
Opt out of communications: You may opt out of receiving newsletters and announcement emails from us by using the “unsubscribe” link within each email sent via MailChimp, updating your email preferences within your myRBS account, or by contacting us as provided below to be removed from our mailing list. Even after you opt out of receiving mass communications from us, you will continue to receive emails regarding any RBS programs to which you have applied.
Turn off cookie controls: Relevant browser-based cookie controls are described below.
Cookies and other tracking technologies
Rare Book School and our third-party partners, such as our analytics, communications, and application-platform partners, may use various technologies to collect information, including cookies and web beacons.
How do we use them?
How can you opt out?
You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from websites you visit. If you do not accept cookies, however, please note that certain features of the RBS website or other RBS-controlled websites may not function at full capacity.
Other important privacy information
Our policy toward children
RBS programs are not directed to individuals under 13. We do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact us.
European Union minors’ privacy: Where General Data Protection Regulation applies, we do not knowingly collect personal data from children under age 16 (or such lower age permitted under applicable local law not being lower than age 13).
Your information is managed by Rare Book School. If you have questions or concerns about how your information is handled, please direct your inquiry to firstname.lastname@example.org and it will be routed to the appropriate staff member. Our main office phone number is 434-924-8851.
You may also write to us by postal mail at:
Rare Book School
114 Alderman Library
University of Virginia
Charlottesville, VA 22904