The JACK KENT COOKE FOUNDATION Privacy Policy

LAST UPDATED: November 1, 2018

The Jack Kent Cooke Foundation (“Cooke Foundation,” “we,” “us,” “our”) wants the visitors to www.jkcf.org (our “Website”), the applicants to our scholarship and other Cooke Foundation programs, and their families (collectively, “you” or “your”) to understand how we collect, use and disclose your information. We learn about you from information collected when you visit our Website, submit an application, ask the College Board to provide your information to us, or communicate with us in other ways. We also receive information from schools, teachers, recommenders, and other resources. This Privacy Policy explains:

  • What personal information we receive about you;
  • How we use and protect your personal information;
  • With whom we may share your personal information; and
  • How you can contact us about your personal information.

 

WHAT THIS PRIVACY POLICY DOES AND DOES NOT COVER

Personal Information. This Privacy Policy covers the personal information received and stored by the Cooke Foundation. For purposes of this Privacy Policy, the term “personal information” refers to information that can be used to identify you as an individual, directly or indirectly, alone or together with other information. This includes, for example, your name, e-mail address, and phone number; and may also include indirect identifiers such as your geolocation, IP address, device ID, and other internet usage information.

Third Party Controlled Sites. This Privacy Policy does not apply to information that you provide to third parties through their applications or websites, including your social media accounts and locations you can access from links posted on our Website. You should not transmit your personal information to us from one of these sources, because it will be not be covered by this Privacy Policy. For more information, see the section titled, “SOCIAL MEDIA PLATFORMS AND THIRD-PARTY LINKS.”

De-identified Information. We may create de-identified data from personal information by excluding data components (such as your name, email address, or linkable tracking ID) that makes the information personally identifiable to you, through obfuscation, or through other means. Our use of de-identified data is not subject to this Privacy Policy.

 

YOUR CONSENT TO THIS PRIVACY POLICY

Please read our Privacy Policy carefully. When you use our Website, you signify to us that you have read, understand, and agree to this Privacy Policy and that you also consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy. You should not submit personal information to us if you do not agree to the terms of our Privacy Policy and the Terms and Conditions posted on our Website.

Note to International Users. Around the world, the legal protections for personal information differ significantly as to what categories of personal information are protected and how they are protected. The Cooke Foundation is located in the United States and operates under United States law, which may not have the same level of legal protection for your personal information as your home country. If you are not in the United States, your personal information will be transferred from your location to the United States for processing by the Cooke Foundation. When you submit personal information in an application, by e-mail, on our Website or in any of the ways covered in this Privacy Policy we will ask for, or reasonably infer from the communication, that you consent to the transfer of your personal information to the United States. For additional information applicable to international users, see the Section titled, “INTERNATIONAL STUDENTS, EDUCATORS, AND OTHERS.

 

WHAT PERSONAL INFORMATION DO WE COLLECT?

Personal Information Provided by Applicants and their Families

When you apply for a Cooke Foundation scholarship, grant or award, it will be necessary to submit extensive personal information to show that you meet the Cooke Foundation’s academic and financial criteria for eligibility and then to demonstrate the personal characteristics that support your selection for the program. The categories of information include, among others: name, mailing and e-mail address; gender and date of birth; school transcripts; test scores; and other information about academic achievement; financial and tax information about you and your family; and information about the experiences, activities, and challenges that are important to you. The personal information you submit online and through other means in the application process will be handled by the Cooke Foundation in accordance with this Privacy Policy.

 

Personal Information Provided by Website Visitors

Visitors do not need to register with us to view most of the content on our Website. If you sign up to receive notifications or for our newsletter, we will request the following information as applicable: name; e-mail address; phone number if you wish to receive text messages; program you’re interested in; name of your school or organization; and job title. If you wish to start an application, you will be automatically transferred to an online portal with the Common Application (for College Scholars and Undergraduate Transfer Students) and with other platforms we use for other grant and award programs. If you register for a conference or other event through the Website, we’ll capture information about the specific event, and any selections, preferences, or requests you submit.

 

Personal Information Provided Online by Cooke Scholars

Recipients of Cooke Foundation scholarships, grants, and awards continue to provide detailed information to the Cooke Foundation on an ongoing basis and use the Cooke Access Portal, Cooke Connect, and Thrive Together link to update their scholar profiles and contact information, submit current transcripts and other education information required by the Cooke Foundation, and let us know about their campus activities.

 

Personal Information from Educational and Other Sources

We may receive information about eligible candidates from their schools, teachers, and others who know about their educational goals. To help us identify students who may be interested in our programs we use resources provided by the College Board, ACT, National Student Clearinghouse, and organizations around the country that also seek to advance the education of exceptionally promising students who have financial need. We receive information from surveys we conduct with applicants, alumni and others. The personal information you give us and information about you we receive in other ways may be combined with other personal information available from our records and other sources.

 

INFORMATION COLLECTED USING TECHNOLOGY

Cookies and Other Online Tracking Mechanisms

We want you to be aware that when you use our Website, information is automatically collected about you and your online activities using Google analytic tools and other internet resources. Cookies, web beacons, and tags placed on your computer when your web browser accesses our Website enable us to recognize you, record how you and other visitors use our Website, and track statistics about Website usage. Data generated about your online activities are stored and logged. The data collected using cookies and similar technologies may include:

  • Identification – date and time of each visit to our Website, history of visits, user name and password if you establish a Website account, and other personalized services including event registrations;
  • Device – your IP address, internet domain name, internet service provider, browser type, operating system, mobile network, device telephone number;
  • Usage – referring site of application, text and video content viewed on our Website and time spent in viewing each file, number and duration of visits and history of the Website pages viewed, and other internet activities; and
  • Location – your general geographic location can be determined by your IP address and a more specific location is available if you access our Website using a mobile device unless blocked.

For information about how we use information collected using these technologies, see “SHARING INFORMATION WITH THIRD PARTIES.”

 

Restricting the Use of Information Collected Using Technology

You can control how cookies and other technologies are used to track and log your online activities in several ways:

  • Manage the preference settings on your browser and device;
  • Communicate directly with Google as explained at: https://policies.google.com/privacy ;
  • Purchase a utility from an independent software provider that you install on your computer browsers to make website visits anonymous.

If you restrict the use of cookies and other technologies, there may be some features of our Website that you will not be able to use. Note that our Website does not respond to “do not track” requests.

 

HOW DO WE USE PERSONAL INFORMATION?

We use the personal information we receive directly from you, from others who you authorize to provide information to us, from our Website, and from other sources for the purpose of achieving the Cooke Foundation’s goal of advancing the education of exceptionally promising students who have financial need. Specific purposes for which we use personal information include the following:

  • Processing and reviewing applications for our scholarship, grant, and other award programs, and selecting recipients;
  • Communicating and answering questions about our application process and individual applications;
  • Administering our programs and awarding Cooke scholarships and grants;
  • Providing ongoing services to our College Scholars, Undergraduate Transfer Scholars, Young Scholars, and other award recipients;
  • Maintaining ongoing communications with our scholars and other award recipients and tracking fulfillment of their program requirements;
  • Conducting research and statistical analysis of the long-term effectiveness of our programs using either de-identified information or with the consent of the applicants and scholars whose personal information is used for these purposes;
  • Responding to Website requests for notifications and to receive our newsletter;
  • Sending e-mails and e-newsletters unless directed to stop sending these messages; see the section titled “Opt In / Opt Out Procedures;” and
  • Administering our Website and using data collected with technology to analyze trends in usage, number of visits (including via IP address logging) from different locations, track users’ movements around the Website, and gather demographic information about our user base.

 

SHARING INFORMATION WITH THIRD PARTIES

The Cooke Foundation permits selected third party service providers to have access to your personal information where we believe the service provider is better able to perform a specific function. Some of these service providers need personal information in order to perform the service. For other services, the provider may have technical access to your information, but does not need or use the information in order to perform the contract service. We endeavor to select service providers who demonstrate their commitment to protecting the personal information we entrust to them and who maintain appropriate confidentiality and security safeguards that are consistent with our Privacy Policy. These third parties are prohibited from using or disclosing your personal information except to perform their services on behalf of the Cooke Foundation.

 

Support Services

Processing Applications. We use the Common Application, Slate for Admission or other third party platforms for you to complete and submit an application for a Cooke Foundation scholarship, grant or other award program. Once you submit your application, it will be processed and stored using a hosted database service. This service provider and Cooke Foundation staff may perform some preliminary automated review and sorting of the applications we receive. However, no final selection decisions are made by an automated process.

Call Center. Because of the high volume of calls we receive, particularly when the application process is open, we use a call center to handle calls about the application process and individual applications. The call center and its staff are not permitted to retain, disclose, store, or use any personal information except as necessary to provide the services on behalf of the Cooke Foundation.

Operations Support. We use service providers to perform administrative and technology functions to support the operations of the Cooke Foundation, such as website and applications hosting, database management, contact management, event management, network infrastructure support, and e-mail marketing services. These providers may have access to personal information, but are prohibited from accessing or using the personal information they process for us for any purpose except on behalf of the Cooke Foundation.

 

Research

The Cooke Foundation and our research partners undertake research projects to evaluate the effectiveness of our programs. We track the academic and other achievements of our scholars and other award recipients. With your consent, which we request at the time you submit your application, we may also follow the educational progress of applicants who did not receive a Cooke Scholarship or award using personal information provided by the National Student Clearinghouse. Some research is conducted using de-identified information, which is not covered by this Privacy Policy.

 

Website Analytics, Marketing, and Advertising

Data Analytics. We use Google web analytics tools and similar tools to evaluate the performance of our Website and gather information about Website usage and visitors. Google represents that it processes data for Website usage and other data for legitimate purposes without revealing any personal information that identifies you individually. To learn more about how Google collects and processes data from websites for advertising and data analytics purposes, please visit https://policies.google.com/technologies/partner-sites. For information about ways to manage the collection and use of your personal information, see the section titled “Restricting the Use of Information Collected Using Technology.”

Direct Marketing. When you sign up on our Website for notifications or to receive our Newsletter we will ask for your consent to communicate with you by e-mail or text message. We will use your contact information to continue those communications unless you instruct us to stop. See the section titled “HOW TO OPT-OUT OF E-MAIL MESSAGES.” With your consent, which we request at the time you submit your application, we may provide your contact information to colleges and other educational institutions that offer financial assistance to high achieving students. In return, they may provide similar information to us from their applicant pool and other sources. We do not sell, rent, or disclose your personal information to third parties for commercial purposes.

Online Advertising. We may partner with a third party to manage our advertising on other websites. A third party will use technologies such as cookies to gather information about your activities on our Websites and other websites in order to provide you advertising based upon your browsing activities and interests. You may use your browsers or device settings and other measures to block receiving interest-based ads, but you may still continue to receive general ads. See the section titled “How You Can Restrict the Information Collected Using Technology.

 

Legal Process and Site Protection.

In certain situations, we may be required to disclose personal information (1) in response to lawful requests by courts, law enforcement, or other government authorities, (2) to comply with a subpoena or other legal process, or (3) as otherwise required by law. We also may disclose your personal information when we believe in good faith that disclosure is necessary to protect our rights, enforce our Website policies and terms, protect your rights or safety or the rights or safety of others, or prevent and investigate fraud.

 

HOW TO OPT-OUT OF E-MAIL AND TEXT MESSAGES

At any time you may tell us to stop sending you e-mail or text messages by:

  • Clicking “unsubscribe” in an e-mail you receive from us;
  • Reply to a text with the word “STOP” to unsubscribe from text messages

 

HOW DO WE PROTECT PERSONAL INFORMATION?

Protecting your personal information is important to us. We have implemented organizational and technical security measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We limit access to your personal information to staff members and third parties who need such access in order to carry out their responsibilities on behalf of the Cooke Foundation. Those processing your information may do so only in an authorized manner and are subject to a duty of confidentiality. When you enter sensitive information (such as your password), we encrypt that information in transit using industry-standard Transport Layer Security (TLS) encryption technology. Still, we cannot guarantee the security of your personal information from unauthorized access, disclosure, use, or alteration. There is always a risk inherent in the electronic transmission and storage of information (including without limitation the risks of unauthorized entry or use, telecommunication issues, hardware or software failure, and other factors).

 

HOW LONG DO WE KEEP PERSONAL INFORMATION?

We retain personal information for as long as we reasonably require it for legal or legitimate Cooke Foundation purposes. For research purposes, we retain certain application information indefinitely and may selectively de-identify portions of the personal information in an application on a selective basis. When we no longer have a legitimate interest in keeping your personal information, we securely delete or destroy it. In determining data retention periods, Cooke Foundation takes into consideration applicable laws, contractual obligations, and what we reasonably believe are your expectations.

 

SOCIAL MEDIA PLATFORMS AND THIRD-PARTY LINKS

Our Website contains links to social media platforms, other websites, and mobile applications that do not process personal information on our behalf (collectively, “Third Party Controlled Sites”). Although you may choose to communicate with us using a Third Party Controlled Site, you should not submit any sensitive personal information to the Cooke Foundation from a Third Party Controlled Site. The Cooke Foundation does not endorse, approve, or certify any Third Party Controlled Site, and we have no control, responsibility or liability for their privacy, security, content, reliability, or activities. Any personal information you submit to us through a Third Party Controlled Site is not covered by our Privacy Policy. If you activate a link from our Website to a Third Party Controlled Site, cookies and other tracking devices may be set by the Third Party Controlled Site to collect your personal information, including your IP address and the page you are visiting on our Website. You should consult the privacy policy of each Third Party Controlled Sites for information about how it processes personal information.

 

INTERNATIONAL STUDENTS, EDUCATORS, AND OTHERS

Processing Takes Place in the United States. The Cooke Foundation operates in the United States and follows the information and consumer protection laws of the United States and its individual states. If you reside or are located in a different country, the data protection laws of that country may differ as to what, and how, your personal information is protected. We want you to understand that when you provide your personal information to us, or we obtain it through our application process, our website, or other communications with us, you consent to our processing your information in the United States, subject to United States laws, and as explained in this Privacy Policy. We will respond to requests you may have about your personal information as described below.

Information for Our Applicants and Others in EAA Countries. If you reside in an EU Member State or other EAA country, we want you to know that the lawful basis under the General Data Protection Regulation (“GDPR”) for the collection and processing of personal data by the Cooke Foundation are:

  • Processing and collection of personal data that is necessary for the Cooke Foundation to pursue its legitimate interests in outreach, recruitment, selection, and research for and conducting our scholarships and other educational programs in accordance with our mission to advance the education of exceptionally promising students who have financial need.
  • The applicant or other data the subject has given consent to processing his or her personal data, including special categories of personal data, for specific purposes, such as consideration of an application, participation in our programs, research, and other specific purposes.

We base the e-mail and text messaging communications we send to you on our legitimate interest in furthering the Cooke Foundation’s objectives and what we understand is your interest in the Cooke Foundation’s services as a student, educator, parent or guardian, or other person interested in our mission. At any time you may instruct us to stop sending these materials by “unsubscribing” to our email or as explained in the section titled “HOW TO OPT-OUT OF E-MAIL AND TEXT MESSAGES.”

The Cooke Foundation is the controller of the personal data subject to this Privacy Policy. We have endeavored in this Privacy Policy to provide an accurate description of the personal data we process, the purposes of the processing, the third parties to whom we may disclose your personal data, and the reasons for third party disclosure. The following is a brief and partial summary of some of the rights and protections of the GDPR for general guidance only. Detailed information is available at: https://www.eugdpr.org/.

You may have certain rights, among others and subject to legal limitations, to the following:

To find out what personal information we have about you or request a readable copy;

  • To ask us to limit how we use your personal information;
  • To ask us to correct personal information we have about you;
  • To request data in a portable format suitable for reuse.
  • To object to our further processing of your personal information;
  • To register a complaint regarding how we handle your personal information;
  • To ask us to erase personal information we have about you if we do not, or no longer, have a lawful basis for processing it.
  • To file a complaint with a supervisory authority.

If you contact us in writing as explained in the section titled “HOW TO CONTACT US,” we will respond to appropriate requests as soon as practicable and within the time limits prescribed by law. The Cooke Foundation will provide a process for considering and responding to your request, but the final response will depend on the nature of the request and applicable law. Note that research data, opinions and impressions, third party recommendations, internal selection and review materials, and derived data will not be made available, copied, or erased unless required by applicable law. To protect your privacy and security, we may take steps to verify your identity before taking action on your request. We encourage you to contact us directly and allow us to work with you to address any concern you may have about how we process your personal data or to file a complaint.

 

HOW TO CONTACT US

If you have any questions or requests or wish to file a complaint, you can contact us:

By e-mail us to: privacy@jkcf.org

By letter to: 44325 Woodridge Parkway, Lansdowne, VA 20176

We may need to confirm your identity in order to respond to some requests.

 

NOTIFICATION OF CHANGES TO THIS PRIVACY POLICY

We will notify you of changes to this Privacy Policy by updating the Privacy Policy posted on our Website. These changes will apply only to information collected after the date of the change.