November 22, 2011
Access to this Site and the Services (as defined below) is void and unauthorized where prohibited by applicable law or regulation.
1) Description of the Site. RPI and the Site provide information on organized travel programs for high school and college students, families and groups. The Site enables Users to review available travel programs, request personal home visits from RPI representatives, request a newsletter or catalog, submit an application for participation in a travel program as well as enter available Promotions (the “Services”).
The term “Users” shall collectively refer to all visitors, users, applicants and participants on the Site and its Services.
The term “Applicants” shall refer to users of the Site that submit Applications for participation in RPI’s travel programs as provided on the Site.
The term “Visitors” shall refer to users of the Site other than Applicants.
The term “Service(s)” shall include all features, capabilities and permitted actions available through and on the Site, including but not limited to participation in any specific Promotion.
The term “Promotions” shall include various contests, sweepstakes and other promotions offered through the Site.
The term “Information Package” shall include the various documents, information packets, disclaimers, health-related reports, financial assistance applications and rules of conduct and behavior provided to Users by RPI both during the initial online Application process and afterward and deemed critical by RPI to the success of any travel program.
2) What information does the Site collect?
Visitor Activity. Visitors, or non-Applicants, to the Site may choose to browse, search and examine any information made available to non-Applicants on the Site without providing any PII. When you visit our Site as a Visitor, we collect only information you provide or submit to the Site directly, information you send to us by email, information you provide when ordering a catalog, information you provide when requesting a home visit by one of our representatives, information and messages you send or post through our accounts on third party social networks (such as Facebook, YouTube or Twitter), and any comments you post or information or message you send through Services. The foregoing statement notwithstanding, our servers may recognize and collect information on Visitors’ IP addresses and any usage information on pages visited.
Application Process. In order to apply for participation in one of the travel programs offered on the Site, Users are required to submit an online application (“Application”). When submitting an Application with the Site, you will be asked to provide some PII about yourself (“Application Data”). An Application may require such PII as name, email address, birth date, gender, address, schools, parent or legal guardian contact information, passport information and, if applicable, credit card information. Both during the Application process and afterward, we may request additional demographic and personal information.
Information Package (health & financial information): As part of the Application process, you and your parents (or legal guardians) may be asked to review and approve documents and rules governing your participation in a travel program. These forms may require your and your parents (or legal guardians’) signature, name, address, and other PII. In addition, you might be asked to submit various health-related information necessary for safe participation in our travel programs. These forms may also require the submissions of information by a qualified doctor. Such information may include emergency contact information, known allergies, medication taken, food allergies and other medical concerns. Also, in the event you wish to apply for financial scholarship or assistance, you might be asked to provide financial information such as parent income.
Submissions to the Site. Submissions include the upload, submission, sending, posting or communication, where and if available, by Users of any comment, opinion, answer, response, question, photograph, video, image, text or other content to the Site. Any PII or Submission that you voluntarily disclose on the Site is collected by us. This may include any information you submit as part of your Application.
Catalog Requests: Users may request the mailing of a catalog. When submitting a request we collect contact information including name, address, school and phone number.
Surveys & Newsletters. We may now or in the future send or run surveys or provide newsletters to our Users. At such time we may request certain PII such as name, email address and demographic information (such as zip code, age and school affiliation).
Home Visits: We may now or in the future enable Users to request a home visit by one of our representative. At such time we may request certain PII such as name, address, email address and certain demographic information (such as zip code, age and school affiliation).
Usage Information. We may collect information about your usage, such as when you use the Site, the information you review, the frequency and size of data transfers, as well as information you display or click on in the Site.
Click-Through URLs. In some of our email messages we may use a “click-through URL” linked to content on the Site. When Users click one of these URLs, they pass through our web server before arriving at the destination web page. We may, now or in the future, track this click-through data to help us determine interest in particular topics and measure the effectiveness of our communications.
3) How do we use the information you provide us? We use PII such as your name, address, your parents (or legal guardians) contact information, school, phone number and e-mail address in order to provide you with the Services.
Any PII collected as a result of interactions initiated through our Sites, are used to enable Services and features.
We may share your PII with our agents, representatives, contractors and service providers so they can provide us with support services such as authorization of credit card transactions, e-mail origination, support services, customer relationship management services or order fulfillment.
We may also use such PII to determine if you comply with the T&Cs or any of the other policies or rules provided on this Site.
We use PII collected as health information to assure the safety of Users applying for any specific travel program. The health information is also provided to our local guide to assure access in the event of an emergency.
Unless you opt-out, we may use your e-mail or other PII to send commercial or marketing messages without your further consent.
Be advised that we use your e-mail address and other contact information provided by you to contact you regarding certain Submissions, including communications and inquiries you make of the Site or RPI.
We may also use your e-mail address without further consent for non-marketing or administrative purposes (such as notifying you of major Site changes or customer service purposes).
We use both your PII and certain non-PII (such as anonymous user data, cookies, IP addresses, browser type, clickstream data, etc.) to improve the quality and design of the Site and to create new features, promotions, functionality and services by storing, tracking, analyzing and processing User preferences and trends, as well as User activity and communications.
Note: Your PII may be passed on to a third party in the event of a transfer of ownership or assets of RPI or a bankruptcy. We may also disclose PII when we determine that such disclosure is necessary to comply with applicable law, to cooperate with law enforcement or to protect the interests or safety of RPI or other Users of the Site. Whenever PII is disclosed under this paragraph, we may also disclose your demographic information on a non-anonymous basis.
How Does RPI Protect Users Personal Information? We implement a variety of security measures to ensure the security of your PII on our systems. When you enter sensitive information (such as credit card number) on our Application forms, we encrypt that information using secure socket layer technology (SSL).
We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, therefore, while we strive to use commercially acceptable means to protect your PII, we cannot guarantee its absolute security.
Third parties may unlawfully attempt to intercept or access transmissions or private communications and other Users may abuse or misuse your personal information that they collect from the Site. Although we work very hard to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private.
5) Is Any Information Collected Directly by Third Parties: When submitting an entry into any of our Promotions, your PII may be collected by a third party vendor assisting us or managing our Promotion. Except to any extent that PII may be backed up or cached on their servers, all information collected by the third party vendor shall be remitted directly to us. The third party vendor shall be under contract not to use or keep any of the PII collected on our behalf. Except as provided in this Agreement, none of the information you submit to the Site is collected directly by third parties.
7) How do you change PII provided or OPT-OUT? RPI gives Users an option for modifying or removing some information from our database. To update, modify or delete such information, follow the instructions provided on the Site or contact us at email@example.com. We will comply with your requests as reasonably as we can. Please note that we require some PII for billing and administrative purposes. While you may remove your PII from our database at any time, you acknowledge that we may retain archived or cached copies of your PII. Please submit any questions and requests regarding your PII submitted as part of an Application to firstname.lastname@example.org.
Rustic Pathways Australia (USA) Inc.
34900 Chardon Road
Building 1, Suite #205
Willoughby Hills, OH 44094