Privacy Policy

This Privacy Policy (the “Policy”) describes the collection, use, maintenance, disclosure, handling and other processing (“Processing”) by Kent School (the “School”) of information that identifies or is reasonably identifiable to (“Personal Information”) a prospective, existing, or former student (a “Student”), family members and other individuals associated with a Student, and other members of the School community (collectively, an “Individual”). However, this Policy does not apply to any person in that person’s capacity as an employee, contractor, supplier, or other vendor of the School, unless that person otherwise is an Individual as listed above.

The School intends this Policy to comply with the various laws, rules, and regulations both domestically in the United States, internationally in the European Union and other local, state, federal, and foreign laws, rules, and regulations that govern the School’s Processing of Personal Information (collectively, “Data Privacy Laws”). However, such Data Privacy Laws apply only if and to the extent the School is subject to them and they govern Personal Information Processed by the School.

This Policy informs Individuals about how the School Processes Personal Information and how an Individual can submit privacy rights requests to the School concerning Personal Information. If you have any questions or concerns about this Policy or about the School’s Processing of Personal Information, please contact our Data Privacy Officer as follows:

Name: Michael Siepmann
Address: P.O. Box 2006
Phone number: (860) 927-5600
Email address: privacy@kent-school.edu

Personal Information

The School Processes Personal Information in the course of providing goods and services to Individuals related to the following (collectively, “Services”): academic, athletic, artistic, musical, and other curricular and extra-curricular activities, education, training, and other development of Students; physical, mental, and emotional health, counseling, special education, and other health and health-education related goods and services; business, management and other operations of the School, including admissions, enrollment, financial aid, curriculum, classroom management, Student performance and education management, Student discipline, health center, physical education and athletics, technology and technical support, collection and payment of tuition and other costs, fees and expenses, finance and accounting, communications with the School community and public, emergency management, transportation, summer camp, facilities, and School campus access and management; communication, outreach, and School activities that involve family members of Students, other Individuals associated with Students, and other members of the School community; solicitation, collection, and management of donations, gifts, and other monetary receipts; and other School activities.

In the course of providing these Services, the School necessarily Processes a wide variety of Personal Information about Individuals, which includes, but is not necessarily limited to, the Personal Information identified above as well as the following: contact information, such as name, physical address, telephone and cellphone number, email address, emergency contact information, and other contact information; family and other social information, such as information about personal and familial relationships, dynamics, and legal matters and other social and community matters; information about personal interests and activities, both related and unrelated to School activities; a wide variety of both academic and non-academic and both curricular and extra-curricular education related information, such as prior and existing performance and performance evaluation, curricular, educational and developmental needs and plans, involvement and participation in classroom, non-classroom, and other School related activities, conduct, discipline, School-related social relationships and interactions, and other education-related information; financial information, including about income, assets, ability to pay, and payment of tuition and other costs, fees and expenses; demographic information, including information on race, ethnicity, gender, sexual orientation, age, marital status, health and disability, and dietary preferences; educational history, such as your prior schools, transcripts, school activities, scholarly work and disciplinary records; testing history, such as standardized testing and corresponding identity verification documentation; donor information, such as donor’s name, donation amount, and other information related to the donation and gifts; employment information, such as your job title, employer’s name, and work location; and your photographs or other images.

Sensitive Personal Information

In addition to Processing the types of Personal Information listed above, the School necessarily Processes a wide variety of Personal Information about Individuals that is of a sensitive nature (“Sensitive Personal Information”), which includes, but is not necessarily limited to, the following: children who are Students as well as family members of Students, other children associated with Students, and other members of the School community who are children; Social Security numbers and other governmental identification numbers; credit card, debit card, and bank and other financial account numbers; dates of birth; health information; biometric information; geolocation information; and race, ethnic origin, national origin, citizenship, immigration status, religious and political belief and affiliation, and sexual orientation and identity. For purposes of this Policy, Sensitive Personal Information is considered a sub-category of Personal Information.

Depending on how Individuals interact with us, we may collect Personal Information when you: request demos, free website reports, or consultations using our web forms; register for an event or participate in a training course; apply for admission; engage with our support team; participate in any of our surveys; send communications to us or contact us with questions or concerns; or otherwise interact with us.

The School has collected Personal Information in the last twelve months and Processed it for the purposes described in this Policy.

Information We Collect From Third Parties

From time to time, and if and to the extent permitted by law, we may obtain and receive certain Personal Information about you from third-party sources. We obtain and receive your Personal Information from such sources so that we can better understand which of our Services may be of interest to you and to provide you with information necessary to improve our Services.

Legal Bases for Processing of Personal Information

The School Processes Personal Information for several different purposes and legal bases, including in order to fulfill our statutory, contractual, common law, and other commercial and legal relationships and duties, including to provide Services; in connection with your or another person’s vital interests; and in connection with public interests. The School also obtains consent from Individuals for the Processing of Personal Information, including obtaining consent from Individuals to Process Sensitive Personal Information, and obtaining consent from parents or legal guardians of Students for the Processing of Personal Information.

If and to the extent necessary and not prohibited by Data Privacy Laws, the School also may Process Personal Information for one or more of the following reasons: to comply with local, state, federal, or foreign laws, rules, or regulations; to comply with a civil, criminal, judicial, executive, legislative, agency, or other regulatory inquiry, investigation, subpoena, summons, or other legal process; to cooperate with a law enforcement agency or authority concerning conduct or activities that the School in good faith believes may violate a local, state, federal, or foreign law, rule, or regulation; to investigate, establish, exercise, prepare for, or defend any allegation or claim concerning conduct that the School in good faith believes may violate a School rule or policy or a local, state, federal, or foreign law, rule, or regulation; to protect an interest that is essential for the life or physical safety of the Individual or another person; to detect, respond to, prevent or protect against illegal or unlawful activity, fraud, harassment, malicious or deceptive activities, identity theft, or any other security incident; to create, evaluate, develop, improve, enhance, and otherwise manage the Services; and to engage in other educational, academic, non-academic, curricular, extra-curricular, business, operational, financial, technological, and other activities that are or should be reasonably aligned with the expectations of Individuals, reasonably anticipated based on your relationship with the School, or otherwise compatible with the Processing of Personal Information in furtherance of providing the Services.

Disclosure of Personal Information

Except as necessary or appropriate to provide Services, the School does not disclose your Personal Information to any third party. However, we may disclose Personal Information for the following purposes and in the following circumstances.

If directed to do so by the Individual about whom the Personal Information pertains, the parents or legal guardians of the Student about whom the Personal Information pertains, and that Individual’s or Student’s legal representatives.
If required to do so by Data Privacy Laws, any other law, rule, or regulation, legal process or warrant, or order of any court or governmental agency or authority.
To child safety and public health agencies, authorities, and officials.
To professional service providers, including attorneys, accountants, tax professionals, financial advisers, public relations and media advisers, and consultants, if doing so is necessary or appropriate to obtain professional services from them.
To organizations that provide marketing and advertising services, and to other suppliers and vendors, if doing so is necessary to obtain good or services from them, provided that the School will secure an appropriate data processing agreement with such organizations, suppliers and vendors prior to disclosing Personal Information to them.
To other schools and institutions for the purposes of administering programs and services, such as the following: cross-registration for courses and programs with other schools and institutions; study abroad at foreign schools; online education offerings through online platforms; research arrangements with other universities and partners; conference, workshop and similar proceedings; and events and activities with clubs and special interest groups.
In connection with a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation of the School.
For the protection of the School and others.

Privacy Rights

Depending on the Personal Information that the School has about an Individual, depending on the Services we provide related to that Individual, and depending on the manner in which we Process an Individual’s Personal Information, you may have the following privacy rights related to our Processing of your Personal Information, and parents and legal guardians of Students may have the following privacy rights related to our processing Personal Information of Students.

Be informed about how your Personal Information is being processed, the categories of Personal Information being processed, and the categories of sources from which your Personal Information has been collected.
Be informed about whether and how your Personal Information is being sold, shared, traded, exchanged or brokered with unaffiliated third parties, and which categories of your Personal Information are being sold, shared, traded, exchanged or brokered with such unaffiliated third parties.
Access or receive a copy of your Personal Information.
Rectify, update, or correct inaccurate or incomplete Personal Information about you.
Erasure or deletion of certain categories of your Personal Information.
Limit processing of your Sensitive Personal Information.
Opt-out of the sale, sharing, trading, exchange, and brokering of your Personal Information with unaffiliated third parties.
Portability of your Personal Information in a commonly used format.
Withdrawal of your consent to processing of your Personal Information to the extent such processing is based on your consent, provided that such withdrawal will not affect the lawfulness of the School’s use of your Personal Information before such withdrawal.
Non-discrimination for exercising your privacy rights.

To make a privacy rights request, please complete and submit the Privacy Rights Request Form on the School’s website, or contact our Data Privacy Officer. The School will confirm receipt of a privacy rights request within 10 days of our receipt of it. The School will substantively respond to all such privacy rights requests within 30 days, subject to any lawful extension of that period. Additionally, there may be a delay in processing a privacy rights request while we verify that the request is valid and originates from you as opposed to an unauthorized person.

Please be aware there may be valid reasons for the School to decline to comply with a privacy rights request, either in whole or in part. For example, the School may be required to retain and Process certain Personal Information under local, state, federal and foreign laws, rules, and regulations. Similarly, to provide Services to you or your Student, the School may be unable to comply with a privacy rights request in whole or in part, or compliance with a privacy rights request may limit or prevent the School from providing Services to you or your Student. In those situations, the School will notify you in writing within 30 days. You may also contact our Data Privacy Officer for help with those situations. Finally, the School’s ability or duty to comply with privacy rights requests may be limited by Data Privacy Laws.

If you disagree with any response, position, or other decision that the School has taken or made with respect to your privacy rights request, you may appeal by completing and submitting the appeal field in the Privacy Rights Request Form on the School’s website, or by contacting our Data Privacy Officer and requesting such an appeal. The School will confirm receipt of such an appeal within 10 days of our receipt of it. The School will substantively respond to all such appeals in writing within 60 days, subject to any lawful extension of that period.

The School will not discriminate against you if you exercise any of the foregoing rights or any other rights under Data Privacy Laws, including, by not denying Services to you or your Student, not providing a different level or quality of goods or Services to you or your Student, and not suggesting that you or your Student will receive a different level or quality of Services.

Selling, Sharing, Trading, Exchanging, and Brokering Personal Information

Except as otherwise disclosed in this Policy, the School does not sell, share, trade, or exchange Personal Information (including as those terms are defined and used in Data Privacy Laws) in any way, including for itself, or any unaffiliated third party. If and to the extent you want to opt-out of the sale, sharing, trading, or exchanging of your Personal Information, please complete and submit the Privacy Rights Request Form, and we will address such requests as described in the foregoing section of this Policy.

International Transfers of Personal Information

If and to the extent the School transfers Personal Information from another country into the United States, the School does so in compliance with the privacy laws of the originating country and for purposes outlined in this Policy. If and to the extent we transfer Personal Information of iindividuals in the European Union, the United Kingdom, or Switzerland to the United States, we do so under the Standard Contractual Clauses approved by the European Commission, the Swiss Addendum approved by the Swiss Authorities, and the United Kingdom Addendum to the Standard Contractual Clauses approved by the United Kingdom authorities, where appropriate. In addition, we may also rely on the EU-U.S. Data Protection Framework, the United Kingdom Extension to the EU-U.S. Data Protection Framework, and the Swiss-U.S. Data Protection Framework for the transfer of Personal Information to the United States. If you have any inquiry regarding our adherence to the Data Privacy Framework, Contact our Data Privacy Officer.

Automated Decision Making

The School does not use automated decision making or profiling in the Processing of Personal Information, and does not make decisions that affect you based on automated decision making or profiling using Personal Information.

Cookies

When you visit the School’s website, we may place a cookie (a text file containing a randomly assigned number) on your device so that we have the ability to customize the look and feel of the website for you. Cookies remember information about you, your preferences, and your device for a better user experience when visiting the website. Using cookies, the School may also collect a variety of other information regarding your usage of the website, including your Internet protocol address, username, session identification, browser, web pages viewed, referring web pages, when you access the website, and general online behavior for performance and marketing purposes.

Changes to Policy

The School reserves the right to change or amend this Policy at any time and for any reasons, including to remain in compliance with Data Privacy Laws.

Questions or Concerns

If you have any questions or concerns about this Policy or about the School’s Processing of Personal Information, please contact our Data Privacy Officer as follows: