Blended by Design

This Privacy Policy sets forth Blended by Design, LLC (“BBD”) policy and legal notice with respect to the gathering and dissemination of information we obtain from you on BBD’s website and affiliated websites located at https://blended-by-design.net and with respect to compliance (where applicable) with the European Union’s General Data Protection Regulation (“EU GDPR”).

BBD is the operator of this Site, although software, hosting and other functions may be provided by third parties (“Service Providers”). This Privacy Policy and Legal Notice (“Policy”) describes the type of information BBD and its Service Providers collect from visitors to this Site, what we do with that information, and how visitors can update and control the use of information provided on this Site.

This Policy does not necessarily describe information collection policies on other sites, such as separate sites operated by our Service Providers that we do not control. Many of the resources linked from this Site are not maintained by BBD. BBD cannot monitor all linked resources, only those pages that fall directly within BBD world-wide web structure. BBD is in no way responsible for the privacy practices or the content of these linked resources, and the statements, views, and opinions expressed therein are neither endorsed by nor do they necessarily reflect the opinion of the BBD.  Any links to non-BBD information or resources are provided as a courtesy. They are not intended to nor do they constitute an endorsement by BBD of the linked materials.

This Policy may be changed from time to time and without further notice. Your continued use of the Site after any such changes constitutes your acceptance of the new terms. If you do not agree to abide by these new terms or any future terms, please do not use the Site. This site is not directed to children under 13 years of age, and children under 13 years of age shall not use this Site to submit any personal information about themselves.

Information We Gather

When you visit the Site, we may collect certain routing information, including, but not limited to, the Internet Protocol (“IP”) address of your originating Internet Service Provider (“ISP”), and information provided by “cookies” stored on your hard drive. We may also collect aggregate information about the use of the Site, including, but not limited to, which pages are most frequently visited, how many visitors we receive daily, and how long visitors stay on each page. We may disclose and publish aggregate information on an aggregate basis to any party through any means, but such aggregate information will not disclose any personal information. Any information collected through this Site may also be used in aggregate by system administrators in the administration of the Site. This information helps us understand aggregate uses of our site, track usage trends, and improve our services. You may also be required to provide certain personal information in order to access various features and information on the Site. Such information may include, among other things, your name, address, and phone number. If you do not want to provide such information, you may choose not to access those features of the Site. Any personal information that you choose to provide through the Site will be protected in accordance with the provisions of this Policy.

Cookies

Cookies are small pieces of data that may be stored by a Web browser. Cookies are often used to remember information about preferences and pages you have visited. This information is stored for your convenience and also may be used in the aggregate to monitor and enhance the Site. For example, when you visit some

sites on the Web you might see a “Welcome Back” message. The first time you visited the site a cookie may have been set on your computer; when you return, the cookie is read again. You can refuse to accept cookies, can disable cookies, and remove cookies from your hard drive. However, if you do not accept cookies from the Site, you may lose access to the Site or experience decreased performance of the Site.

Security and Accuracy of Confidential Information

BBD does its best to ensure that the personal information obtained from you is accurate. You may review the information saved or submitted via the Site at any time up to the point when it is purged from the flat file or database. In the event that there is an error in your personal information, we will correct the information on your request.

We have put in place reasonable physical, technical, and administrative safeguards designed to prevent unauthorized access to our use of the information collected online. While we strive to protect your personal information by encryption and other means, we cannot guarantee or warrant the security of the information you transmit to us, and if you choose to use the Site, you do so at your own risk.

Please keep in mind that the information disclosed by you on our Site in certain forums – for example, information, including personal information, that you may provide to others on bulletin boards, through blogs or in chat rooms that may be available on the Site – can be collected and used by visitors to the Site.

Sharing of Information

BBD is committed to maintaining the privacy of your personal information. We do not actively share personal information gathered from the Site. However, there may be some instances in which we will need to do so as required by law (including but not limited to the New York State FOIL), as necessary to protect BBD interests, and/or with Service Providers acting on our behalf. BBD also complies with the Family Educational Rights and Privacy Act (“FERPA”), which generally prohibits (with some exceptions) the release of education records without student permission. For more details on FERPA, currently enrolled students should see their institution’s specific policies.

Questions

If you have questions about this Policy or you believe that your personal information has been released without your consent or if you wish to correct information held by BBD, please contact us at https://www.BBD.edu/contact.

EU GDPR Privacy Notice

Lawful Bases for Collecting and Processing of Personal Data

BBD is a system of institutions of higher education involved in education, research, and community development. In order for BBD and its institutions to educate its students both in class and online, engage in world-class research, and provide community services, it is essential, necessary, and BBD and its institutions have lawful bases to collect, process, use, and maintain data of students, employees, applicants, research subjects, and others involved in its educational, research, and community programs. The lawful bases include, without limitation, admission, registration, delivery of classroom, online, and study abroad education, grades, communications, employment, applied research, development, program analysis for improvements, and records retention. Examples of data that BBD and its institutions may need to collect in connection with the lawful bases are: name, email address, IP address, physical address or other location identifier, photos, as well as some sensitive personal data obtained with prior consent.

Please note that individual BBD institutions may have their own EU GDPR privacy notices and policies posted on their websites.

Most of BBD’s (including its institutions’) collection and processing of personal data will fall under the following categories:

1. Processing is necessary for the purposes of the legitimate interests pursued by BBD or third parties in providing education, employment, research and development, community programs.
2. Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
3. Processing is necessary for compliance with a legal obligation to which BBD is subject.
4. The data subject has given consent to the processing of his or her personal data for one or more specific purposes.

There will be some instances where the collection and processing of personal data will be pursuant to other lawful bases.

Types of Personal Data Collected and Why

BBD and its institutions collect a variety of personal and sensitive data to meet one of its lawful bases, as referenced above. Most often the data is used for academic admissions, enrollment, educational programs, job hiring, provision of medical services, participation in research, development and community outreach. Data typically includes name, address, transcripts, work history, information for payroll, research subject information, medical and health information (for student health services, or travel), and donations.

If a data subject refuses to provide personal data that is required by BBD or one of its institutions in connection with one of its lawful bases to collect such personal data, such refusal may make it impossible for BBD or its institutions to provide education, employment, research or other requested services.

Where BBD Gets Personal Data and Special Categories of Sensitive Personal Data

BBD and its institutions receive personal data and special categories of sensitive personal data from multiple sources. Most often, this data comes directly from the data subject or under the direction of the data subject who has provided it to a third party (for example, application for admission to a BBD institution through use of a common application).

Individual Rights of the Data Subject Under the EU GDPR

Individual data subjects covered by the EU GDPR (http://www.policylibrary.gatech.edu/legal/eu-general-data- protection-regulation-compliance-policy) will be afforded the following rights:

• information about the controller collecting the data;
• the data protection officer contact information;
• the purposes and legal basis/legitimate interests of the data collection/processing;
• information about who received any personal data;
• if BBD or one of its institutions intends to transfer personal data to another country or international organization;
• the period the personal data will be stored;

• the existence of the right to access, rectify incorrect data or erase personal data, restrict or object to processing, and the right to data portability;

the existence of the right to withdraw consent at any time; the right to lodge a complaint with a supervisory authority (established in the EU); why the personal data are required and possible consequences of the failure to provide the data the existence of automated decision-making, including profiling; and, if the collected data are going to be further processed for a purpose other than that for which it was collected

Note: Exercising of these rights is a guarantee to be afforded a process and not the guarantee of an outcome. Any data subject who wishes to exercise any of the above-mentioned rights may do so by making such request at sdeschel@gmail.com 

Cookies

Please see the description above of “cookies” within the Privacy Policy, which is incorporated and applies equally here in regard to the EU GDPR.

Security of Personal Data Subject to the EU GDPR

All personal data and special categories of sensitive personal data collected or processed by BBD must comply with BBD Cybersecurity Plan, as authorized by the Dr. Susan Ruckdeschel, Founder and CEO. Anyone suspecting that his or her sensitive personal data has been exposed to unauthorized access, report your suspicion to https://blended-by-design.net/contact   

We will not share your information with third parties except as necessary to meet one of its lawful purposes, including but not limited to:

• its legitimate interest;
• contract compliance;
• pursuant to consent provided by you;
• as required by law;
• as necessary to protect BBD and/or its institutions’ interests; and/or,
• with service providers acting on our behalf who have agreed to protect the confidentiality of the data.

New York State Freedom of Information Law

As an entity of the government of the State of New York State, the BBD and its institutions are subject to the provisions of the New York State Freedom of Information Laws (NYS FOIL): https://www.dos.ny.gov/coog/Right_to_know.html

except for those records that are exempt from disclosure under FOIL provides that all citizens are entitled to view the records of state agencies on request and to make copies for a fee.

Data Retention

BBD and any of its affiliates keep the data it collects for the time periods specified in the Blended by Design Retention Schedules available upon request at https://blended-by-design.net/contact