Privacy Policy
Last Modified: September 8, 2020
Welcome to www.heterodoxacademy.org, an online platform promoting the goal of open inquiry, viewpoint diversity and constructive disagreement in institutions of higher learning (the “Website”) operated by Heterodox Academy, a District of Columbia not-for-profit company (“HxA”, “we”, “our”, or “us”). This privacy policy (this “Privacy Policy”) is intended to inform you about how HxA collects and uses personal information from or about you that can be used to uniquely contact, identify, or locate you (“PI”) and other information in operating the Website.
How does the Website work?
The Website enables anonymous visitors to the Website (“Visitors”) to learn more about us and the services we provide, and Visitors who are at least eighteen (18) years of age and not a minor in their state of residence, to submit certain of their PI to us to become one of our registrants (“Registrants”) in various capacities, including without limitation to make donations or to submit a request to become a “Friend” or “Member” of HxA, and to register for certain of our activities and events. The terms “you”, “your” and “yours”, when used herein refer to either Registrants and Visitors or to both Registrants and Visitors collectively, as applicable.
Your use of the Website is subject to HxA’s Terms of Use for the Website, which can be found at Terms of Use.
You may be able to make general use of the Website without providing any PI to HxA. However, you will need to provide us with certain PI in order to use certain of the Website’s functionality, such as becoming a Registrant.
By using the Website, you consent to the collection and use of your PI and other information by HxA as described in this Privacy Policy.
If you are located in the European Economic Area (the “EEA”), the UK and Switzerland, our “Data Subjects in the EEA, the UK and Switzerland” Section (located at the end of this Privacy Policy) provide additional information about your use of the Website and your rights as data subjects residing in Switzerland, the UK or the EEA, which includes all countries in the European Union, Liechtenstein, Iceland and Norway.
How can the terms of this Privacy Policy be modified?
We reserve the right to change how we handle and use the information that we collect through the Website, and to modify this Privacy Policy, at any time in our sole discretion. Please review this Privacy Policy periodically to be aware of all such modifications. A current version of this Privacy Policy is accessible via the footer of the Website’s homepage.
What type of PI does HxA collect from you and how do we use it?
Registrants must provide certain PI to HxA in order to register with us, including without limitation a Registrant’s name, address, email, and payment information (if a donation is being made). We may also ask you for general statistical, information about yourself, and your interests.
We intend to use all such information collected through the Website or otherwise from you for multiple purposes, including for our own research and decision-making purposes. We also will use such information to keep you informed about our events and other activities by sending you emails, by reaching you by phone and for hard-copy mailings. And we will use your email addresses for our email marketing (weekly newsletter, donor newsletters, etc.). If you would no longer like to receive information, newsletters, or other promotional messages from us, please click the link at the bottom of any such email you receive from us and follow the instructions or email us at admin@heterodoxacademy.org.
Certain of your PI (other than for your payment information, if applicable) will be published in our directory of members and friends which is publicly available, including through the Website. And we will videotape or otherwise record certain of our events or activity, or third-party events or activities, and use the resulting footage for promotional purposes, and your likeness and image may appear and be used in connection with such recordings or otherwise if you participate in any such an event or activity.
Registrants may also register to participate in various activities operated by third parties, including without limitation panel webinars, discussions, classes, and workshops, or to take surveys or other information-sharing activities. Registrants understand HxA is not responsible for and has no control over such activities and the parties conducting such activities. Therefore, please keep in mind that any PI or other information that you provide such third parties in the course of your participation in such activities or otherwise will not be subject to the terms of this Privacy Policy but rather to the terms of whatever privacy policy or other terms such the third party may offer if any.
How else do we use your PI?
HxA or entities working on our behalf may use your PI to help fulfill your requests in connection with your use of the Website and/or your participation in our activities, or to help us or third parties communicate with you about different resources offered as part of the Website or our activities, or otherwise. For example, we may transfer information collected at registration, including your PI, to service providers, payment processors, and other third parties who assist us in running the Website and/or in processing your registration at an event or payment.
Under what other circumstances may we release PI?
In addition to sharing your PI with third parties as described above, we may also release your PI to other third parties if we believe that such release is necessary (a) to comply with the law (e.g., a legal process or a statutory or regulatory authorization or requirement) or a court order, (b) in order to apply or enforce the Terms of Use or otherwise protect our interests, (c) in order to protect you, other Visitors or Registrants, or us from fraudulent, abusive, or unlawful use of the Website or from other harm, or (d) if we reasonably believe that a danger to any person or property requires the disclosure of such PI.
Our rights under this Privacy Policy may be automatically assigned by us, in our sole discretion, to a third party or parties whose activities are consistent with our non-profit mission, and such an assignment will inure to the benefit of our successors, assigns and/or licensees.
What other information does HxA collect through the Website?
We may also collect anonymous and aggregate information from you about your preferences in navigating the Website by using cookies, action tags and other methods. Cookies are small text files that identify your computer and can track your behavior across multiple platforms. We may use cookies to, among other things, monitor usage of the Website, customize features of the Website, identify your computer’s or other device’s operating system and browser, and complete transactions. An action tag is a small, graphic image on a webpage that is designed to allow the website owner or a third party to monitor who is visiting a website by collecting the IP address of the computer to which the tag is sent, the URL of the webpage that the tag comes from and the time at which such webpage was viewed. Action tags may be associated with cookie information. We may also use such anonymous and aggregate information for promotional and other business purposes.
Please see our Cookie Notice for additional information.
Google Analytics and Web Beacons
We use Google Analytics, a web analysis service provided by Google, in order to better understand your use of the Website and how we can improve it. Google Analytics collects information such as how often users visit a website, what pages you visit when you do so, and what other websites you used prior to coming to such website. Google Analytics collects only the IP address assigned to you on the date you visit a website, rather than your name or other directly identifying information. We do not combine the information collected through the use of Google Analytics with your personal information. Although Google Analytics plants a persistent cookie on your web browser to identify you as a unique user the next time you visit a website, the cookie cannot be used by anyone but Google. Google Analytics uses its cookie(s) and the information Google Analytics collects to track your online activities over time and across different websites when you use our Website, and other websites. Google’s ability to use and share information collected by Google Analytics about your visits to the Website is governed by the Google Analytics Terms of Service and the Google Privacy Policy. Google utilizes the data collected to track and examine the use of the Website, to prepare reports on its activities, and share them with other Google services. To more fully understand how Google may use the data it collects on the Website, please review “How Google Uses Information From Sites or Apps That Use Our Services” (located here).
Do I have the ability not to be identified by HxA?
Yes. If you do not want to be identified by us, you can set your browser to warn you before accepting cookies and refuse cookies when your browser alerts you to their presence. You can also adjust the settings in your browser to refuse all cookies. If you do not want us to have any of your PI, do not submit any of your PI to us. Please keep in mind that if you refuse cookies you may not be able to use certain Website functionality, including without limitation using our registration mechanism to become a Registrant.
Do we use social media platforms?
Any submission that you submit to any of our pages contained on a social media platform or on the Website by e-mail, posting, messaging, uploading, downloading, or otherwise is done at your own risk and without any expectation of privacy. We cannot control the actions of other users of a social media platform and we are therefore not responsible for any submissions contained on a social media platform.
How and where do we store information?
HxA takes steps consistent with commercially reasonable industry standards to secure PI collected from you from loss, misuse, unauthorized access and destruction while under our control. However, please note that despite our efforts to protect information provided to us, we cannot guarantee that such information will not be lost, disclosed or accessed by accidental circumstances or by the unauthorized acts of others.
If you are visiting the Website from outside of the United States of America, please be aware that your PI may be transferred to, stored or processed in the United States, where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to protect your privacy. By using any portion of the Website, you understand and consent to the transfer of your information to our facilities in the United States and those third parties with whom we share it as described in this Privacy Policy.
Does HxA provide links to other websites?
HxA may provide links to other websites or resources of possible interest to you. The collection and use of your PI and other information by such websites shall be subject to the policies and procedures of such websites and not those contained in this Privacy Policy. The information collected by our service providers or other third parties working on our behalf, including without limitation payment provider platforms in consummating donations you may have made by means of the Website or otherwise in the course of assisting us, is subject to the privacy policies of such third parties and is not subject to this Privacy Policy.
What are our policies regarding children?
The Website is intended for general use by persons who have reached the age of consent in their state of residence and it is not targeted to anyone under thirteen (13) years of age. HxA does not knowingly collect PI from anyone under thirteen (13) years of age. If we learn that we have unintentionally collected PI from anyone under thirteen (13) years of age, we will promptly delete such information.
What are Your California Privacy Rights?
If you are a California resident, you may ask us to refrain from sharing your PI with certain third parties for marketing purposes. Please express your preference to us by contacting us at: admin@heterodoxacademy.org or at the following address: Heterodox Academy, 82 Nassau Street #646, New York, NY 10038.
Do we respond to Do Not Track Signals?
The Website does not have the capability to respond to “Do Not Track” signals received from various web browsers.
Do we have a mechanism to address the removal of PI and complaints about the handling of information that we collect?
If you wish to remove PI that you have submitted to HxA, please send us an email requesting such removal (with the word “Removal” in the email subject line) to admin@heterodoxacademy.org. If you have questions or concerns about any of our information collection or handling practices, please contact us at admin@heterodoxacademy.org or write to us at Heterodox Academy, 82 Nassau Street #646, New York, NY 10038.
Data Subjects in the EEA, the UK and Switzerland
This section clarifies your rights as data subjects residing in Switzerland, the UK or the EEA. All terms not otherwise defined shall have the meanings as defined under applicable data protection laws. In the event of any conflict between this Section and another other Section(s) of the Privacy Policy, the terms of this Section shall prevail.
Consent
We will make it clear if we rely on your consent to process your personal data and you are free to withdraw your consent at any time. If you wish to do so, please contact us at admin@heterodoxacademy.org.
Legitimate Interest
Another reason we might use your personal data is because we have—or a third party has—a legitimate interest in doing so. We do so when responding to your inquires about our events and services, to provide technical support to you, to comply with laws that apply to us and to enable internal administrative processes.
Retention Period
When we no longer need to process your personal data for the purposes described in this Privacy Policy, we will delete your personal data from our systems. We therefore generally retain information when we have an ongoing legitimate business need for the information and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Providing Your Data
One reason we might use your personal data is because you’ve inquired into entering into a contract with us or you’ve entered into a contract with us and we need to provide services under that contract. We may not be able to fulfill that contract if you choose not to provide us with your personal data.
Purpose of Processing
When we process your personal data, we determine the purpose of the processing and act as a controller. We will primarily process personal data from the EEA and the United Kingdom to offer our Website, process payments, and to provide information about our services, in addition to other purposes set out in this Privacy Policy.
Automated Profiling & Decision Making
We do not engage in any automated decision making or profiling as a part providing the Website.
Your Right to Rectification
We want our records to be as accurate as possible, so please advise us of any errors and we will make corrections accordingly. Although a difference of opinion or view does not necessarily mean that personal data is inaccurate, if you have a difference of opinion, we will do our best to add that opinion to our records.
Erasure and your “Right to be Forgotten”
Please contact us if you want us to delete your personal data. We will do our best to honor your request, but we may have an obligation to keep records for audit and legal purposes. We may also be able to “Restrict Processing” or delete specific information or a document, which we will do without undue delay, for example, where it has been sent to us in error.
Your Right to Object to Processing
In certain circumstances, you have the right to object to our use of your personal data, such as if we are using your personal data for direct marketing; for our or a third party’s legitimate interests or the public’s interest; or for scientific or historical research and statistics. Please contact us at admin@heterodoxacademy.org if you would like us to do so.
Right to Restrict Processing
Under some circumstances, you may request that we limit how we use your data or “Restrict Processing.” Simply a difference of opinion or view does not necessarily justify a restriction, but we will always consider your opinion. We will always inform you before we lift any restrictions.
Your Right to Access Data
You have a right to receive a copy of your personal data from us. If you would like to do so, please contact us at admin@heterodoxacademy.org and we will advise you of the next steps as soon as possible, and in no more than one month.
Right to Data Portability
At your request, we are happy to provide your personal data in a machine-readable or “portable” format so you can move it or store it wherever you want, subject to certain limitations. We can also send it to another controller where technically feasible. If you would like to do so, please contact us at admin@heterodoxacademy.org and we will advise you of the next steps.
Right to Complain
If you have a complaint about how HxA uses your personal data, we hope that in the first instance you will contact us and we will promptly address your concern. However, you can always file a complaint with the supervisory authority in your Member State. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Union are available at http://ec.europa.eu/justice/ar....
Charges/Fees
We do not charge you a fee for exercising any of your rights described above. The only exception to this will be if the request is excessive or repetitive, but we will always let you know that we plan to charge you before doing so.
Contact Information
Please direct any rights requests (as described above) or additional questions that you may have regarding this Privacy Policy to admin@heterodoxacademy.org or write to us at Heterodox Academy, 82 Nassau Street #646, New York, NY 10038.