Effective: May 2018
Revised: November 2019
- What information do you gather about me and/or my child?
- How do you collect and use my and/or my child’s information?
- How can I access, update or delete my or my child’s information?
- How do you collect and use information?
- What security is in place to protect my and my child’s information?
- Where will my and/or my child’s information be processed and will it be shared?
- What is your email policy?
- Who can I contact with questions or concerns about this policy?
Data you provide to HPA is:
- processed fairly and in a transparent manner;
- collected for specific and legitimate purposes;
- limited to what is necessary for the specified purposes;
- kept accurate and up-to-date;
- only retained for as long as is necessary;
- and appropriately secured.
1. What information do you gather about me and/or my child?
Portions of this website may ask for personally identifiable information (e.g., your name, email address, other contact information) for the purposes of conducting internal marketing and development, for responding to your inquiries, and for other business of the Academy. The information gathered is governed by Family Educational Rights and Privacy Act (FERPA), Children’s Online Privacy Protection Act of 1998 (COPPA), Health Portability Act, and California Assembly Bill AB 370 (AB 370).
We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Site or on or through any of its features/register on the Site, use any of the interactive or public comment features of this Site or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at email@example.com
2. How do you collect and use my and/or my child’s information?
We will Collect Your or Your Child’s information
- if you authorize it;
- if the information is provided to help complete a transaction for you;
- if the disclosure is done as part of a purchase, transfer or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, customer information may be one of the transferred assets);
How We Use Your and Your Child’s Information
- To provide, update, maintain and protect our Services, Websites and business.
- To verify and grant you access to the HPA services.
- To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your personal Information to respond and provide technical and implementation support.
- To better understand how your child is progressing at HPA. We may analyze trends, monitor patterns, to help us better understand our performance so we can optimize and improve our Services.
- To send emails and other communications related to changes to the service or important announcements. We may send you service, technical and other administrative emails, messages, informative and other types of communications.
- We may also contact you to inform you about changes in our Services, our Services offerings and important Services-related notices, such as security and fraud notices.
- To carry out training and marketing related to the service. We sometimes send emails about new product features, promotional communications or other news about HPA. These are marketing messages so you can control whether you receive them or not from the Notifications tab in your Profile or you may unsubscribe at any time.
- To deliver tailored advertising. We may use your personal information to serve and manage ads on our services or on third party sites and to tailor ads based on your interests and browsing history. Please see “Your Rights” for additional information on how to manage the ads you see.
- Profiling. We may analyse your Personal Information to create a profile of your interests and preferences so that we only send information that is relevant to you. We may make use of additional information about you when it is available from external sources to help us to do this effectively. We may also use your personal information to detect and reduce fraud or credit risk.
- To comply with applicable laws, legal processes or regulations.
- To process payments.
When you submit your personally identifiable information it is used only for the purpose stated above.
3. How can I access, update or delete my or my child’s information?
HPA will accept data requests via the HPA GDPR Information Request Form. This form can be emailed, mailed or faxed.
You have the following rights to your or your child’s information in accordance with FERPA and GDPR:
Right to access
You may ask to receive confirmation as to whether your personal data is being processed by us, as well as various other information relating to our use of your personal data.
Right to request a copy
You may request a copy of the personal information held by HPA.
Right to obtain confirmation of information use.
Right to obtain information relating to whether or not your personal data is being processed, where and for what purpose.
Right to rectify information.
You may update or correct your information at anytime. This can be done with the settings and tools provided in your myHPA account or by making a request via email.
Right to be deleted.
You may request erasure of your Personal Data which we are processing at anytime. Your data will be deleted except any information we are required to maintain by law (i.e. transcripts) or to continue to function as a school. You may also have the right to lodge a complaint.
Right to consent.
You have the right to give your consent for HPA to control your data if you are a European citizen or California resident. Additionally, EU citizens have the right to rescind their consent.
Right to data portability.
You may request a copy of your data held by HPA in a machine readable format, free of charge.
Right to object.
HPA may control your Personal Data for direct marketing purposes and you have the right to object or withdraw consent to HPA’s use of your Personal Data for this purpose at any time.
Right to be notified of a breach.
In the case of a breach that is likely to result in a risk to your rights and freedoms, HPA will notify you of the breach within 72 hours.
Right to complain. You have the right to raise a complaint with us (firstname.lastname@example.org) or a right to lodge a complaint to a supervisory authority relating to the use of your personal information.
4. How do you collect and use information?
This website uses Google Analytics to help understand how visitors engage with the site. Your web browser automatically sends certain information to Google. This includes, for example, the web address of the page that you’re visiting and your IP address. Google may also set cookies on your browser, or read cookies that are already there. If you would like further information on how Google uses data when you use our website you may visit, www.google.com/policies/privacy/partners/.
We share information that does not personally identify you to:
- National Association of Independent Schools (NAIS) and Data and Analysis for School Leadership (DASL)
- The Association of Boarding Schools (TABS)
- Hawai‘i Association of Independent Schools (HAIS)
- Google analytics
A cookie is a small text file stored by your browser that allows the website to “remember” your preferences such as calendar settings and site bookmarks on the site from visit to visit, or to maintain your “logged in” status when visiting protected areas. Portions of this site may utilize cookies to temporarily maintain information related to your use of this site and for anonymously gathering statistical data about the site’s visitors. Web browsers have settings allowing you to reject cookies, or selectively accept cookies, or delete cookies previously accepted. Please be aware that rejecting or deleting cookies from our website may make certain functions unavailable to you.
5. What security is in place to protect my and my child’s information?
Most standard website servers use website statistic packages such as Google Analytics to analyze trends in how our website is accessed and utilized. Information monitored includes internet protocol (IP) addresses, geographic location of visitors (country, city), browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, time spent on pages, and keywords used to find our site via search engines. We may use it to identify high-use or low-use areas of the site, pinpoint problem areas of the site, analyze broad demographic trends in our visitors, and make decisions about how to make it easier for you to find and navigate our website.
LINKS TO OTHER SITES
This website may contain links to other sites. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by this website.
This website takes every precaution to protect our users’ personal information. Whenever users submit personal information (such as contact info or credit card info) via online forms, registration, or online purchase, upon submission that information is encrypted via the highest level of SSL (Secure Sockets Layer) available. Servers that store personally identifiable information are in a secure environment and securely maintained. Under no circumstances are credit card numbers permanently stored on our servers. A lock will be present in your browser in areas when SSL is available.
6. Where will my and/or my child’s information be processed and will it be shared?
Secured employee devices and networking infrastructure for processing and administrative tasks.
We use the following affiliated approved third parties to process and store information about you:
- Blackbaud https://www.blackbaud.com/company/privacy-policy/north-america
- Hubspot https://legal.hubspot.com/privacy-policy
- Google https://gsuite.google.com/terms/education_privacy.html
- Magnus https://magnushealth.com/privacy-policy/
- Naviance https://ui-production.papaya.naviance.com/naviance-static-assets/html/policies/privacy.html
- Boardingware https://www.boardingware.com/legal/privacy
Each classroom, department and/or event may use software or web applications to enhance learning or improve processes. This list is posted in our password-protected community portal and updated with what information is shared with each vendor.
7. What is your email policy?
HPA complies fully with the federal CAN-SPAM Act of 2003 and Canada’s Anti-Spam Legislation (CASL). HPA will not share, sell, rent, swap or authorize any third party to use your email address for commercial purposes without your permission. If you feel you have received an email from us in error, contact email@example.com.
You may receive one or more of the following emails from HPA:
Account and/or Service Related Email
HPA offers several email newsletters. You will only receive these if you previously chose to complete a form to gain more information about our services. If you no longer wish to receive a specific newsletter, follow the “unsubscribe” instructions located near the bottom of each newsletter.
HPA may periodically email you messages about services that HPA thinks may be of interest to you. You can choose not to receive messages in the future by following the “unsubscribe” instructions located near the bottom of each email.
HPA may send you emails inviting you to participate in user surveys, asking for feedback on our services and existing or prospective products and services, as well as information to better understand our users. User surveys greatly help us to improve our services, and any information HPA obtains in such surveys will be used internally. The information may be shared with affiliated third parties in aggregate form only.
If you sign up to receive email from us you will receive emails in HTML (with images) format.
HPA tracks whether recipients open messages by adding an invisible graphic to our emails. When the graphic downloads from the sending server, or the recipient clicks a link, the message registers as open.This process does not leave any information on your computer, nor does it collect information from your computer. HPA may share this data with other third parties in aggregate form only to improve the quality of the emails and offers HPA distributes.
Emails From You
If you send us emails, be aware that information disclosed in emails may not be secure or encrypted and thus may be available to others. It is recommended that you exercise caution when deciding to disclose any personal or confidential information in emails. HPA will use your email address to respond directly to your questions or comments.
8. Who can I contact with questions or concerns about this policy?
If you have questions, comments, concerns, or complaints about this privacy or HPA’s handling of your or your child’s personal information, you can get in touch with us in any of the following ways.
Please direct all privacy-related inquiries to firstname.lastname@example.org.
Data Protection Officer, Wishard Administration Building, 65-1692 Kohala Mountain Road, Kamuela, HI 96743.