INTRODUCTION
St. Luke Academy is entrusted to provide high-quality education and care, operate with integrity, and empower students to thrive. Respecting the privacy rights of our consumers is an integral part of building and maintaining that trust. This Notice explains how St. Luke Academy collects and uses its consumers’ personal information.
WHO DOES THIS NOTICE APPLY TO?
This Notice applies to any person who purchases or uses St. Luke Academy’s services (Consumer), including prospective, current, or former Consumers. It also covers all services provided by St. Luke Academy in its primary location.
For simplicity throughout this Notice, ‘we’, ‘us’ and ‘our’ means St. Luke Academy and ‘you’ or ‘your’ means Consumer.
WHO CONTROLS YOUR PERSONAL INFORMATION?
St. Luke Academy is responsible for processing your personal information.
WHY DO WE COLLECT YOUR PERSONAL INFORMATION?
We limit the collection of your personal information to what is necessary. Below we have highlighted the main reasons for collection:
- Fulfill or meet the reason you provided the personal information to us.
- Respond adequately to your requests for Services or information.
- Provide Services to you and/or your dependents.
- Personalize, enhance, and support your website experience and/or the Services.
- Create, maintain, customize, and secure your account with us.
- Facilitate and process purchases, financial transactions, and payments.
- Provide information regarding our Services and areas of interest to you.
- Research and analyze existing Services for training and quality purposes and develop new Services.
- If you receive our Services as an employee benefit, to aid your employer in the administration of the employee benefit.
- Comply with laws, regulations, and sector standards.
- Protect the security of our technology and data.
- Fulfil tax, reporting, and other financial requirements and obligations.
- Prevent or detect unlawful acts.
- As described to you when collecting your personal information.
- Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all assets of St. Luke Academy, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
- In relation to pandemics (for example COVID-19) or other state/national/international emergencies, to comply with our legal and regulatory obligations.
WHEN DO WE COLLECT YOUR PERSONAL INFORMATION?
There are a variety of contexts under which we will collect your personal information. Please click on the section below that is relevant to you.
When you visit our websites or social media accounts
When you call our Main Office
When you receive Services from us
When you visit our websites or social media accounts
When you visit our websites or social media accounts, we collect your personal information from:
- Monitoring your electronic visit and engagement with us.
- The information you provide to us (for instance, by completing one of our webforms).
Our website is not intended for use by children under 16 years of age nor do we knowingly collect personal information from children under 16 through our website. If you are under 16, please do not use or provide any information on our website.
When you call our Main Office
When you call our Main Office, we will collect your personal information from:
- The information you provide to us.
- Recording the calls, including the number you call from, for training and quality assurance purposes.
When you receive Services from us
When you receive Services from us, we will collect your personal information from:
- The information you provide to us.
- Providing the Services to you such as completing forms, assessments, and other documentation as part of the provision of Services.
- Recorded images at locations with CCTV cameras.
- If you receive Services as part of an employee benefit, we may receive your personal information from your employer on your eligibility to use the Services and other reporting identifiers.
- If you receive government funding, we may receive personal information from the government on your eligibility for the funding and other reporting identifiers.
- Government agencies may provide us with personal information to support their regulatory obligations or investigations.
- Third party marketing companies who provide us with contact details for individuals who have consented to receive marketing materials. You have the right to opt-out of these communications at any time.
WHAT PERSONAL INFORMATION DO WE COLLECT AND PROCESS?
If you are a prospective consumer:
- The personal information you provide to us. This personal information may include health related information relevant to determine the suitability of Services.
- Details of your visits to our websites, apps, and social media, as well as information we gather from the use of cookies.
- For locations with CCTV cameras, we may capture images.
- Your contact details as provided to us by third party marketing companies (for individuals who have consented to receive marketing materials). You have the right to withdraw your consent at any time.
If you are a current or former consumer:
- All personal information you provide to us. This personal information may include health related information relevant to the provision of Services or as required under law/regulation or health and safety policies.
- Personalized registration username and passwords, and swipe card/key fob access records for St. Luke Academy premises.
- Details of your visits to our websites, apps, and social media, as well as information we gather from the use of cookies in your web browser.
- For locations with CCTV cameras, we may capture images.
- Access information when using key fobs or swipe cards.
- Care and service records that may include for example: notes from meetings/calls; observations and assessments of you or your dependent’s activities while we provide services to them (e.g., illnesses, sleep, diaper changes, meals, medication, learning, interactions with others, and accidents); review and feedback on your or your dependent’s education/school applications; photographs to share with you for communication purposes, learning records or identification purposes; and utilization reports (including dates of service, user of service and reasons for service).
- If you receive our service as part of an employee benefit, we may receive personal information from your employer on your eligibility to use the Services and other reporting identifiers.
- If you receive government funding, we receive personal information from the government on your eligibility for the funding and other reporting identifiers.
- Government agencies may provide us with personal information to support their regulatory obligations or investigations.
- Other personal information provided to us by third parties to meet our legal obligations.
- Personal information about you and/or your dependent as necessary to respond to and defend legal claims or to pursue legal claims.
There are a variety of categories of your personal information that we collect. Depending upon whether you are a prospective or current Consumer also determines the personal information we process. For more information, please see below.
WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
We consider your personal information confidential and do not share it with anyone else except as described in this Notice. St. Luke Academy does not sell your personal information (or that of your dependents) to third parties.
When you visit our websites, apps, and social media, we use cookies and similar technologies as permitted by law, including for targeting / behavioral advertising. St. Luke Academy recognizes Global Privacy Control and Do Not Track for social media and Targeting cookies and similar technologies.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
Whenever we collect or process your personal information, we’ll only keep it for as long as is necessary for the purpose for which it was collected, as required under law and to defend legal claims. At the end of that retention period, your information will either be deleted completely or anonymized, for example by aggregation with other information so that it can be used in a non-identifiable way for research, statistical analysis, and business planning.
WHERE DO WE PROCESS AND STORE YOUR PERSONAL INFORMATION?
Hardcopy Information:
The hardcopy of personal information we collect remains in the country where you receive the services or provide the information.
Electronic Information
Some personal information may remain on electronic storage data systems in the country where we provide the service. However, our primary electronic storage facilities and contact centers are in the United States. Please note that we (or our Affiliates, service providers or agents) may process personal information in other countries, where your personal information may be subject to the laws of that jurisdiction, including laws regarding the disclosure of personal information to government authorities. We ensure appropriate safeguards are in place before we transfer personal information to any other country.
WHAT RIGHTS DO YOU HAVE OVER YOUR PERSONAL INFORMATION?
The location of where you reside or receive Services determines your rights. We will not discriminate against you for exercising any of your privacy rights.
Boca Raton
Amend Personal Information:
To ask for your personal information to be amended, please follow one of the steps below as applicable to the Services you receive:
- Online Account: If you have an online account, you can update the information directly online.
- Main Office: Call our contact center team to request the amendments.
- Schools: Contact the location providing the Service to request the amendments.
Removal from email lists:
To be removed from email lists, please follow the steps below:
- Unsubscribe: Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that mailing list.
- Account Preferences: If you have an account, log in to your account and change your preferences.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
How do you make a request about your personal information?
Please note:
- Only you, or a person that you authorize to act on your behalf, may make a verifiable request related to your personal information. You may also make a verifiable request on behalf of your child under the age of 16 years old.
- A person who states they are authorized on your behalf to make a request will be required to produce appropriate signed permission / authority from you that they are authorized on your behalf for the purposes of the request.
- You may only make a verifiable request for access or data portability twice within a 12-month period.
- For us to verify your request, you will need to:
- provide sufficient information that allows us to reasonably verify you are the person about whom we processed personal information or a legally authorized representative; and
- describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
- We will not be able to respond to your request if we cannot verify your identity or legal authority to make the request and confirm the personal information relates to you or the subject of the request.
- We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
When and how will St. Luke Academy respond to your request?
We will endeavor to respond to your verified request within 45 days. If we require more time (up to 90 days) or are unable to comply with your request, we will inform you in writing of the reason and extension period.
Will we charge you a fee?
We do not charge a fee to respond to your authenticated request unless in exceptional circumstances we deem it to be excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will advise you in writing why we made that decision and provide you with a cost estimate before completing your request.
What happens if we decline your request?
We will endeavor to inform you of this within 45 days. We will provide our justification for declining to act in connection with your request.
How to Opt-Out of Sale / Sharing of your Personal Information
You have the right to request:
- that we confirm whether we process personal information about you.
- access to your personal information.
- that we provide a copy of your personal information to you in a portable and ready-to-use format. This right applies when we collect personal information from you in an electronic format and it is technically feasible for us to provide it to you in a portable, ready-to-use format.
- that we correct inaccuracies in your personal information.
- deletion of your personal information (subject to certain exemptions).
HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
We utilize appropriate technical, organizational, and physical safeguards to protect your personal information we process in both physical and electronic formats. We provide data protection, privacy and security training and conduct internal periodic quality assurance audits to ensure we maintain these standards.
However, please note that no computer system or information can ever be fully resilient against every possible hazard or risk. We do maintain appropriate levels of security in accordance with data protection, privacy and security laws and regulations in the territories we operate and keep these under review.
You also play a valuable part in protecting the security of your personal information. You should never share with anyone your password to access any accounts that you created or which we created for you. When using a browser to access your account, after you have finished you should log out and exit your browser to prevent unauthorized users from returning to your account.
If you believe that someone has improperly used your account or provided information about you that you didn’t authorize, please contact us immediately at EMAIL ADDRESS
WILL THIS NOTICE CHANGE?
This Notice is subject to change to remain compliant with data protection and privacy laws in the territories in which we operate. Please check back periodically, especially before you provide any personal information. This Notice was last updated in March 2023.
ANY QUESTIONS?
We hope this Notice has been helpful in setting out the way we process your personal information and how we do this in a transparent and accountable manner. If you have any questions that haven’t been covered by this Notice, please contact us at EMAIL ADDRESS