Ngwa High School
Old Boys Association, USA
Privacy Policy
Last updated March 01, 2024
This privacy notice for Ngwa High School Old Boys Association USA ( "we," "us," or "our" ), describes how and why we might collect, store, use, and/or share ( "process" ) your information when you use our services ( "Services" ), such as when you:
- Visit our website
at https://ngwahighschool.org , or any website of ours that links to this privacy notice
- Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading
this privacy notice will help you understand your privacy rights and
choices. If you do not agree with our policies and practices, please do
not use our Services. If you still have any questions or concerns, please contact us at admin@ngwahighschool.org .
SUMMARY OF KEY POINTS
This
summary provides key points from our privacy notice, but you can find
out more details about any of these topics by clicking the link
following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process?
When you visit, use, or navigate our Services, we may process personal
information depending on how you interact with us and the Services, the
choices you make, and the products and features you use. Learn more
about personal information you disclose to us.
Do we process any sensitive personal information? We do not process sensitive personal information.
Do we receive any information from third parties? We do not receive any information from third parties.
How do we process your information?
We process your information to provide, improve, and administer our
Services, communicate with you, for security and fraud prevention, and
to comply with law. We may also process your information for other
purposes with your consent. We process your information only when we
have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.
How do we keep your information safe? We have organizational
and technical processes and procedures in place to protect your
personal information. However, no electronic transmission over the
internet or information storage technology can be guaranteed to be 100%
secure, so we cannot promise or guarantee that hackers, cybercriminals,
or other unauthorized
third parties will not be able to defeat our security and improperly
collect, access, steal, or modify your information. Learn more
about how we keep your information safe.
What are your rights?
Depending on where you are located geographically, the applicable
privacy law may mean you have certain rights regarding your personal
information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is by visiting admin@ngwahighschool.org , or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what we do with any information we collect? Review the privacy notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express
an interest in obtaining information about us or our products and
Services, when you participate in activities on the Services, or
otherwise when you contact us.
Personal Information Provided by You.
The personal information that we collect depends on the context of your
interactions with us and the Services, the choices you make, and the
products and features you use. The personal information we collect may
include the following:
names
phone numbers
email addresses
contact preferences
job titles
contact or authentication data
Sensitive Information. We do not process sensitive information.
All
personal information that you provide to us must be true, complete, and
accurate, and you must notify us of any changes to such personal
information.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We
process your information to provide, improve, and administer our
Services, communicate with you, for security and fraud prevention, and
to comply with law. We may also process your information for other
purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
- To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
- To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
- To protect our Services.
We may process your information as part of our efforts to keep our
Services safe and secure, including fraud monitoring and prevention.
- To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
- To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. ,
legal basis) to do so under applicable law, like with your consent, to
comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The
General Data Protection Regulation (GDPR) and UK GDPR require us to
explain the valid legal bases we rely on in order to process your
personal information. As such, we may rely on the following legal bases
to process your personal information:
- Consent. We may process your information if you have given us permission (i.e.
, consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
Analyze how our Services are used so we can improve them to engage and retain users
- Diagnose problems and/or prevent fraudulent activities
- Understand how our users use our products and services so we can improve user experience
- Legal Obligations.
We may process your information where we believe it is necessary for
compliance with our legal obligations, such as to cooperate with a law
enforcement body or regulatory agency, exercise or defend our legal
rights, or disclose your information as evidence in litigation in which
we are involved.
- Vital Interests.
We may process your information where we believe it is necessary to
protect your vital interests or the vital interests of a third party,
such as situations involving potential threats to the safety of any
person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e. ,
express consent) to use your personal information for a specific
purpose, or in situations where your permission can be inferred (i.e. , implied consent). You can withdraw your consent at any time.
In
some exceptional cases, we may be legally permitted under applicable
law to process your information without your consent, including, for
example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
- If
it is reasonable to expect collection and use with consent would
compromise the availability or the accuracy of the information and the
collection is reasonable for purposes related to investigating a breach
of an agreement or a contravention of the laws of Canada or a province
- If
disclosure is required to comply with a subpoena, warrant, court order,
or rules of the court relating to the production of records
- If
it was produced by an individual in the course of their employment,
business, or profession and the collection is consistent with the
purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations
In Short: We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
In Short: We may use cookies and other tracking technologies to collect and store your information.
We
may use cookies and similar tracking technologies (like web beacons and
pixels) to access or store information. Specific information about how
we use such technologies and how you can refuse certain cookies is set
out in our Cookie Notice : https://ngwahighschool.org/generic/terms_conditions .
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We
will only keep your personal information for as long as it is necessary
for the purposes set out in this privacy notice, unless a longer
retention period is required or permitted by law (such as tax,
accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us .
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize
such information, or, if this is not possible (for example, because
your personal information has been stored in backup archives), then we
will securely store your personal information and isolate it from any
further processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational
security measures designed to protect the security of any personal
information we process. However, despite our safeguards and efforts to
secure your information, no electronic transmission over the Internet or
information storage technology can be guaranteed to be 100% secure, so
we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized
third parties will not be able to defeat our security and improperly
collect, access, steal, or modify your information. Although we will do
our best to protect your personal information, transmission of personal
information to and from our Services is at your own risk. You should
only access the Services within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age .
We
do not knowingly solicit data from or market to children under 18 years
of age. By using the Services, you represent that you are at least 18
or that you are the parent or guardian of such a minor and consent to
such minor dependent’s use of the Services. If we learn that personal
information from users less than 18 years of age has been collected, we
will deactivate the account and take reasonable measures to promptly
delete such data from our records. If you become aware of any data we
may have collected from children under age 18, please contact us at admin@ngwahighschool.org .
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada , you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, Switzerland, and Canada ),
you have certain rights under applicable data protection laws. These
may include the right (i) to request access and obtain a copy of your
personal information, (ii) to request rectification or erasure; (iii) to
restrict the processing of your personal information; (iv) if
applicable, to data portability; and (v) not to be subject to automated
decision-making. In certain circumstances, you may also have the right
to object to the processing of your personal information. You can make
such a request by contacting us by using the contact details provided in
the section " HOW CAN YOU CONTACT US ABOUT THIS NOTICE? " below.
We will consider and act upon any request in accordance with applicable data protection laws.
If
you are located in the EEA or UK and you believe we are unlawfully
processing your personal information, you also have the right to
complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law,
you have the right to withdraw your consent at any time. You can
withdraw your consent at any time by contacting us by using the contact
details provided in the section " HOW CAN YOU CONTACT US ABOUT THIS NOTICE? " below or updating your preferences .
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows,
will it affect the processing of your personal information conducted in
reliance on lawful processing grounds other than consent.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
Log in to your account settings and update your user account.
Contact us using the contact information provided.
Upon
your request to terminate your account, we will deactivate or delete
your account and information from our active databases. However, we may
retain some information in our files to prevent fraud, troubleshoot
problems, assist with any investigations, enforce our legal terms and/or
comply with applicable legal requirements.
Cookies and similar technologies:
Most Web browsers are set to accept cookies by default. If you prefer,
you can usually choose to set your browser to remove cookies and to
reject cookies. If you choose to remove cookies or reject cookies, this
could affect certain features or services of our Services. For further information, please see our Cookie Notice: https://ngwahighschool.org/generic/terms_conditions .
If you have questions or comments about your privacy rights, you may email us at admin@ngwahighschool.org .
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ( "DNT" )
feature or setting you can activate to signal your privacy preference
not to have data about your online browsing activities monitored and
collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized .
As such, we do not currently respond to DNT browser signals or any
other mechanism that automatically communicates your choice not to be
tracked online. If a standard for online tracking is adopted that we
must follow in the future, we will inform you about that practice in a
revised version of this privacy notice.
11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California , Colorado, Connecticut , Utah or Virginia , you are granted specific rights regarding access to your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
Category | Examples | Collected |
A. Identifiers | Contact
details, such as real name, alias, postal address, telephone or mobile
contact number, unique personal identifier, online identifier, Internet
Protocol address, email address, and account name |
B. Personal information as defined in the California Customer Records statute | Name, contact information, education, employment, employment history, and financial information |
Gender and date of birth | ||
Transaction information, purchase history, financial details, and payment information | ||
Fingerprints and voiceprints | ||
Browsing history, search history, online | ||
Device location | ||
Images and audio, video or call recordings created in connection with our business activities | ||
Business
contact details in order to provide you our Services at a business
level or job title, work history, and professional qualifications if you
apply for a job with us | ||
Student records and directory information | ||
Inferences
drawn from any of the collected personal information listed above to
create a profile or summary about, for example, an individual’s
preferences and characteristics | ||
We
may also collect other personal information outside of these categories
through instances where you interact with us in person, online, or by
phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
Learn about how we use your personal information in the section, " HOW DO WE PROCESS YOUR INFORMATION? "
Will your information be shared with anyone else?
We
may disclose your personal information with our service providers
pursuant to a written contract between us and each service provider.
Learn more about how we disclose personal information to in the section,
" WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? "
We
may use your personal information for our own business purposes, such
as for undertaking internal research for technological development and
demonstration. This is not considered to be "selling" of your personal information.
We
have not disclosed, sold, or shared any personal information to third
parties for a business or commercial purpose in the preceding twelve
(12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.
California Residents
California Civil Code Section 1798.83, also known as the "Shine The Light"
law permits our users who are California residents to request and
obtain from us, once a year and free of charge, information about
categories of personal information (if any) we disclosed to third
parties for direct marketing purposes and the names and addresses of all
third parties with which we shared personal information in the
immediately preceding calendar year. If you are a California resident
and would like to make such a request, please submit your request in
writing to us using the contact information provided below.
If
you are under 18 years of age, reside in California, and have a
registered account with the Services, you have the right to request
removal of unwanted data that you publicly post on the Services. To
request removal of such data, please contact us using the contact
information provided below and include the email address associated with
your account and a statement that you reside in California. We will
make sure the data is not publicly displayed on the Services, but please
be aware that the data may not be completely or comprehensively removed
from all our systems (e.g. , backups, etc.).
CCPA Privacy Notice
This
section applies only to California residents. Under the California
Consumer Privacy Act (CCPA), you have the rights listed below.
The California Code of Regulations defines a "residents" as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2)
every individual who is domiciled in the State of California who is
outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You
can ask for the deletion of your personal information. If you ask us to
delete your personal information, we will respect your request and
delete your personal information, subject to certain exceptions provided
by law, such as (but not limited to) the exercise by another consumer
of his or her right to free speech, our compliance requirements
resulting from a legal obligation, or any processing that may be
required to protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
- whether we collect and use your personal information;
- the categories of personal information that we collect;
- the purposes for which the collected personal information is used;
- whether we sell or share personal information to third parties;
- the categories of personal information that we sold, shared, or disclosed for a business purpose;
- the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
- the business or commercial purpose for collecting, selling, or sharing personal information; and
- the specific pieces of personal information we collected about you.
In
accordance with applicable law, we are not obligated to provide or
delete consumer information that is de-identified in response to a
consumer request or to re-identify individual data to verify a consumer
request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer's sensitive personal information.
Verification process
Upon
receiving your request, we will need to verify your identity to
determine you are the same person about whom we have the information in
our system. These verification efforts require us to ask you to provide
information so that we can match it with information you have previously
provided us. For instance, depending on the type of request you submit,
we may ask you to provide certain information so that we can match the
information you provide with the information we already have on file, or
we may contact you through a communication method (e.g. ,
phone or email) that you have previously provided to us. We may also
use other verification methods as the circumstances dictate.
We
will only use personal information provided in your request to verify
your identity or authority to make the request. To the extent possible,
we will avoid requesting additional information from you for the
purposes of verification. However, if we cannot verify your identity
from the information already maintained by us, we may request that you
provide additional information for the purposes of verifying your
identity and for security or fraud-prevention purposes. We will delete
such additionally provided information as soon as we finish verifying
you.
Other privacy rights
- You may object to the processing of your personal information.
- You
may request correction of your personal data if it is incorrect or no
longer relevant, or ask to restrict the processing of the information.
- You can designate an
authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
- You
may request to opt out from future selling or sharing of your personal
information to third parties. Upon receiving an opt-out request, we will
act upon the request as soon as feasibly possible, but no later than
fifteen (15) days from the date of the request submission.
- We will
honor your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.
To exercise these rights, you can contact us by visiting admin@ngwahighschool.org , by email at admin@ngwahighschool.org , or
by referring to the contact details at the bottom of this document. If
you have a complaint about how we handle your data, we would like to
hear from you.
Colorado Residents
This
section applies only to Colorado residents. Under the Colorado Privacy
Act (CPA), you have the rights listed below. However, these rights are
not absolute, and in certain cases, we may decline your request as
permitted by law.
- Right to be informed whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right
to opt out of the processing of your personal data if it is used for
targeted advertising, the sale of personal data, or profiling in
furtherance of decisions that produce legal or similarly significant
effects (
"profiling" )
If we decline to take action regarding your request and you wish to appeal our decision, please email us at admin@ngwahighschool.org .
Within forty-five (45) days of receipt of an appeal, we will inform you
in writing of any action taken or not taken in response to the appeal,
including a written explanation of the reasons for the decisions.
Connecticut Residents
This
section applies only to Connecticut residents. Under the Connecticut
Data Privacy Act (CTDPA), you have the rights listed below. However,
these rights are not absolute, and in certain cases, we may decline your
request as permitted by law.
- Right to be informed whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right
to opt out of the processing of your personal data if it is used for
targeted advertising, the sale of personal data, or profiling in
furtherance of decisions that produce legal or similarly significant
effects (
"profiling" )
If we decline to take action regarding your request and you wish to appeal our decision, please email us at admin@ngwahighschool.org .
Within sixty (60) days of receipt of an appeal, we will inform you in
writing of any action taken or not taken in response to the appeal,
including a written explanation of the reasons for the decisions.
Utah Residents
This
section applies only to Utah residents. Under the Utah Consumer Privacy
Act (UCPA), you have the rights listed below. However, these rights are
not absolute, and in certain cases, we may decline your request as
permitted by law.
- Right to be informed whether or not we are processing your personal data
- Right to access your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to opt out of the processing of your personal data if it is used for targeted advertising or the sale of personal data
Virginia Residents
Under the Virginia Consumer Data Protection Act (VCDPA):
If this definition of "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.
Your rights with respect to your personal data
- Right to be informed whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right
to opt out of the processing of your personal data if it is used for
targeted advertising, the sale of personal data, or profiling in
furtherance of decisions that produce legal or similarly significant
effects (
"profiling" )
Exercise your rights provided under the Virginia VCDPA
If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Verification process
We
may request that you provide additional information reasonably
necessary to verify you and your consumer's request. If you submit the
request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.
Upon
receiving your request, we will respond without undue delay, but in all
cases, within forty-five (45) days of receipt. The response period may
be extended once by forty-five (45) additional days when reasonably
necessary. We will inform you of any such extension within the initial
45-day response period, together with the reason for the extension.
Right to appeal
If
we decline to take action regarding your request, we will inform you of
our decision and reasoning behind it. If you wish to appeal our
decision, please email us at admin@ngwahighschool.org .
Within sixty (60) days of receipt of an appeal, we will inform you in
writing of any action taken or not taken in response to the appeal,
including a written explanation of the reasons for the decisions. If
your appeal is denied, you may contact the Attorney General to submit a complaint.
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised"
date and the updated version will be effective as soon as it is
accessible. If we make material changes to this privacy notice, we may
notify you either by prominently posting a notice of such changes or by
directly sending you a notification. We encourage you to review this
privacy notice frequently to be informed of how we are protecting your
information.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) , Jonathan , by email at admin@ngwahighschool.org , or contact us by post at:
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?