we use, store, transfer, and protect this personal data; and your rights in relation to this personal data. This notice applies to The New School, with global headquarters at 66 West 12th Street, New York, NY 10011 USA, as well as to its affiliated legal entities and branches (collectively “we,” “us,” or “our”):
TNS Parsons (“Parsons Paris”) of 45 rue Saint-Roch, 75001 Paris, France is the European branch of Parsons School of Design. Parsons Paris works closely with our US-based operations and certain information is shared between entities, so for purposes of this privacy notice, both The New School and Parsons Paris are data controllers. For more information on how your information is shared with third parties, please refer to Section 3 of this notice.
This privacy notice applies to all personal data we collect or process about you, including from you directly (e.g., when you contact us by email or request information through our website), data we generate about you in the course of our relationship with you (e.g., data collected from cookies and other similar technologies as described below) and data we collect about you from other sources, including commercially available sources, such as public databases (where permitted by law).
Some New School websites and mobile applications may include forms used to collect information from prospective students, students, and alumni. To the extent that you choose to submit information through these forms, there may be other privacy notices that apply to you. These notices may be found at: https://ispo.newschool.edu/policies/privacy-notices/.
This notice will inform you of:
Personal data we collect and use;
How we use your personal data and the basis on which we use it;
Who has access to your personal data;
How your personal data is protected and stored;
International transfer of your data;
How to exercise your rights;
How to contact us; and
Changes to the privacy notice.
1. Personal data we collect and use
We collect and use certain personal data about you. Personal data is information about you through which you can be identified (including where you can be identified by combining the information with other information).
Note that we may be required by law to collect certain personal data about you, or as a consequence of any contractual relationship we have with you. Failure to provide this information may prevent or delay the fulfillment of our obligations to you. We will inform you at the time your personal data is collected whether certain data is compulsory and the consequences of the failure to provide such personal data.
1.1 Personal data we collect directly from you
We collect some personal data directly from you. Personal data that is collected directly from you includes the following:
a) Personal details, such as your name(s), date of birth, and place of birth;
b) Contact details, such as your phone number, personal email address, mailing address, and social media handles;
c) Authenticating information, such as user names, passwords, and security questions and answers;
d) Transaction details, such as when you make purchases or respond to offers;
e) Communications, such as when you participate in message boards or forums, participate in polls or surveys, write a review, or contact us with a question, comment, or request;
f) Information about your family/guests, such as names of relatives who may be attending an event; and
g) Information about your current interests and preferences.
b) Contact details, such as your phone number, personal email address, mailing address, and social media handles;
c) Authenticating information, such as user names, passwords, and security questions and answers;
d) Transaction details, such as when you make purchases or respond to offers;
e) Communications, such as when you participate in message boards or forums, participate in polls or surveys, write a review, or contact us with a question, comment, or request;
f) Information about your family/guests, such as names of relatives who may be attending an event; and
g) Information about your current interests and preferences.
1.2 Personal data generated by us
In addition, the following categories of personal data about you may be generated by The New School in the context of your use of the Services:
a) Records of our interactions with you; and
b)Internal notes, including notes about your inquiry into our programs and services.
1.3 Personal data we automatically collect about your use of the Services
We may also automatically collect the following categories of personal data from you over time and across different websites when you use the Services, including through the use of “cookies,” which are small text files that the Services save on your computer using your web browser and access when you return:
a) Information about your computer and other devices, including your IP address, MAC address, and information about your browser and operating system;
b) Information about your usage of our Services, such as the pages you visit when using the Services, the search terms you enter on the Services, how often you use the Services, and the pages you access before and after accessing the Services; and
c)Data that we generate about you as a result of your use of the Services, such as our understanding of your interests as a result of your use of the Services and whether you are a regular or occasional user of the Services.
For more information about cookies and how we use them on our websites, please refer to our Cookie Statement here: https://ispo.newschool.edu/notices/cookies/.
1.4 Personal data we obtain from other sources
The New School may also obtain the following categories of personal data about you from third parties:
a) Personal details, such as name, date of birth;
b) Contact details, phone number, personal email address, mailing address, and social media handles;
c) Information about your current interests and preferences; and
d) Details about advertising preferences, such as products purchased or interaction with advertisements online.
2. How we use your personal data and the basis on which we use it
We use your personal data for the following purposes:
- Identification and authentication. We use your identification information to verify your identity when you access and use our Services and to ensure the security of your personal data. This is so we can comply with our contractual obligations to you.
- Operating the Services. We process your personal data to provide the Services you have requested. This is so we can comply with our contractual obligations to you.
- Improving our Services. We analyze information about how you use our Services to provide an improved experience for users of all our Services, including product testing and site analytics. It is in our legitimate business interests to use the data provided to us for this purpose, so we can understand any issues with our Services and improve them.
- Communicating with you. We use your personal data when we communicate with you, for example, if we are providing information about changes to the terms and conditions; if you contact us with questions about the Services; or for sending you New School newsletters and publications. It is in our legitimate interests that we are able to provide you with appropriate responses and provide you with notices about our Services. Where required by law we will obtain your consent before sending you marketing communications.
- Marketing. We use your personal data to build a profile about you and place you into particular marketing segments in order to understand your preferences better and to appropriately personalize the marketing messages we send to you. It is in our legitimate interest to provide more relevant and interesting advertising messages. Where required by law we will obtain your consent before sending such marketing messages.
- Complying with legal obligations. We process your personal data to comply with legal obligations to which we are subject, including to defend your and our rights in legal proceedings and to cooperate with regulators, law enforcement, and governmental or other competent bodies. This processing is necessary to comply with legal obligations and to serve our legitimate interests in complying with the laws to which we are subject.
- Customizing your experience. When you use the Services, we use your personal data to improve your experience of the Services, such as by providing interactive or personalized elements on the Services and providing you with content based on your interests. It is in our legitimate interests to provide you with a customized experience.
- For purposes of program planning and development. This processing is necessary to serve our legitimate interests in the efficient management and administration of our academic programs and extracurricular activities.
- Keeping our records accurate and up-to-date. This processing is necessary to comply with legal obligations and to serve our legitimate interests in efficient management and administration.
We may also anonymize your personal data in such a way that you may not reasonably be re-identified by us or any other party, and we may use this anonymized information for any purpose.
3. Who has access to your personal data
We treat your personal data with care and confidentiality. Your personal data will be available for the purposes mentioned above and only to employees on a need to know basis and to the extent reasonably necessary to perform their functions. We may share your personal data with third parties under the following circumstances:
- Service providers and business partners. We may share your personal data with our service providers and academic or business partners that perform services for us. For example, we may partner with other companies or entities to process secure payments, fulfill orders, optimize services, serve online behavioral advertising, send newsletters and marketing messages, support email and messaging services, and analyze information. These service providers and business partners include advertising agencies and fraud prevention agencies which will use your personal data only in the ways described in this policy.]
- The New School’s global headquarters and branch campuses. The New School’s branch campuses are part of The New School, whose global headquarters is located in the United States. The branch campuses work closely with our US-based operations and, from time to time, with each other. As a result, we may share certain personal data about you collected or used in the context of our academic programs with other New School personnel located at our main campus in the United States or other branch campuses.
- Law enforcement agencies, courts, regulators, government authorities, or other third parties. We may share your personal data with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
Because we operate internationally, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide the services). See the section on “International transfer of your data” below for more information.
4. How your personal data is protected and stored
We implement physical, technical, and organizational measures designed to safeguard the personal data we process. These measures are aimed at ensuring the ongoing integrity and confidentiality of personal data.
We will retain your personal data for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal data for a period of time that enables us to:
- Maintain academic records;
- Comply with record retention requirements under applicable law;
- Defend or bring any existing or potential legal claims; and
- Resolve or otherwise address any complaints or queries relating to our programs.
5. International transfer of your data
Your personal data may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for personal data under the data protection laws of your locale.
We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your personal data is adequately protected. For more information on the safeguards in place, please contact us at the details below.
6. How to exercise your rights
You have certain rights regarding your personal data. You have the right to access personal data The New School holds, and in some situations you have the right to have that personal data corrected or updated, erased, restricted, or delivered to you or a third party in a usable electronic format (the right to data portability). You may also object to how The New School uses your personal data if the legal basis for processing that information is our legitimate interest.
Where we are using your personal data on the basis of your consent, you have the right to withdraw that consent at any time. You also have the right to register a complaint to the applicable supervisory data protection authority.
If you wish to exercise these rights, or notify us of a change in your details, please visit our Data Subject Access Rights webpage at https://ispo.newschool.edu/dsar/.
7. How to contact us
If you have questions or concerns regarding the way in which your personal data has been used, please contact us at privacyoffice@newschool.edu or:
The New School
Office of Information Security and Privacy
71 Fifth Avenue, 9th Floor
New York, NY 10003 USA
Our representative in the European Union is TNS Parsons, of 45 rue Saint-Roch, 75001 Paris, France.
We are committed to working with you to obtain a fair resolution of any complaint or concern about your privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the applicable supervisory data protection authority:
- For Parsons Paris, the supervisory data protection authority is the Commission Nationale de l’Informatique et des Libertés – CNIL, 3 Place de Fontenoy, TSA 80715 – 75334 Paris, Cedex 07, https://www.cnil.fr/.
8. Changes to the privacy notice
You may request a copy of this privacy notice from us using the contact details set out above. We may modify or update this privacy notice from time to time.
Where changes to this privacy notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will notify you of the changes and give you sufficient advance notice so that you have the opportunity to exercise your rights (for example, to object to the processing).
REVISED NOVEMBER 11, 2020
ADOPTED JULY 8, 2020
