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Privacy Policy

Effective Date: February 20, 2023

Scope of this Policy

 

ICCA is a for-profit organization dedicated to promoting cultural awareness and international understanding through a wide range of work and travel, camp, language programs, volunteer opportunities, professional training, and internship and au pair programs within the United States and globally.

This privacy policy applies to:

  • Big Family Group LLC – Series B DBA International Camp Counselor Agency and our affiliates (“ICCA,” “we,” “us,” “our”).

  • ICCA’s online properties, including our websites, and websites or mobile applications that link to it, and our social media pages or handles.

  • ICCA’s programs or services (collectively with the above, “Services”).

This Policy applies when you interact with us through our Services. It also applies anywhere it is linked. It does not apply to third-party websites, mobile applications, or services that may link to the Services or be linked to from the Services. Please review the privacy policies on those websites and applications directly to understand their privacy practices.

We may change this Policy from time to time. If we do, we will notify you by posting the updated version.

Information We Collect

We collect information from you directly, from the devices you use to interact with us, and from third parties. We may combine information from the Services together and with other information we obtain from our business records. We may use and share information that we aggregate (compile to create statistics that cannot identify a particular individual) or de-identify (strip information of all unique identifiers such that it cannot be linked to a particular individual) at our discretion.

Information you give us

You may provide the following information to us directly:

  • Contact information, including name, email address, telephone number, and postal address.

  • Employment information, including professional information, job title, company name and size.

  • Information contained in government-issued identification.

  • Demographic information, such as age and gender.

  • Information required to perform a background check.

  • Audiovisual information and photographs, including recordings of online events.

  • Content you may include in survey responses, including information about your hobbies or interests.

  • Information contained in your communications to us, including call recordings of customer service calls.

  • Information you make available to us via a social media platform.

  • Information you submit to inquire about or apply for a job with us.

  • Sensitive personal information, including:  racial or ethnic origin; political opinions; religious or philosophical beliefs; physical or mental health information; sexual orientation; and any information relating to a criminal offense.

  • Any other information you submit to us.

In addition to the personal information described above, we may also collect the following information from you depending upon the

 

Services we provide:
  • Participant application information, such as childcare reference documents, personal references, medical examination results, Visa status, emergency contacts, Accident and Sickness Insurance documentation, and tax identification information.

  • Host application information, which may include:  providing personal information about members of the household (where applicable); emergency communication channels; and information regarding any payment offered to Participants.

 

Information we collect automatically

We and partners working on our behalf may use log files, cookies, or other digital tracking technologies to collect the following information from the device you use to interact with our Services. We also create records when you make purchases or otherwise interact with the Services.

  • Device information, including IP address, device identifiers, and details about your web browser.

  • Analytical information, including details about your interaction with our website, app, and electronic newsletters.

  • Diagnostic information, including web traffic logs.

  • Advertising information, including special advertising and other unique identifiers that enable us or third parties working on our behalf to target advertisements to you. Please be aware that our advertising partners may collect information about you when you visit third-party websites or use third-party apps. They may use that information to better target advertisements to you on our behalf.

  • Business record information, including records of your purchases of products and services.

 

Information We Collect From Other Sources

We may collect the following information about you from third-party sources:

  • Any personal information you provide to International Cooperators or Hosts in order to use our Services.

  • Sensitive personal information, including physical or mental health information.

  • Contact information, demographic information, and information about your interests and purchases, from consumer data providers.

  • Information about your interests, activities, and employment history from social networks and other places where you choose to share information publicly.

  • Information about your interaction with advertisements on our Services, or ads that we place on third-party websites, from online advertising companies.

  • Background check results.

  • If you decide to invite others to the Services, we will collect your and the other persons’ names, email addresses, and/or phone numbers to send an email or text message and follow up with the other person. You agree that you will obtain the other person’s consent before giving us their contact information. You also agree that you will not send us the contact information of a minor. We will inform any other person you invite that you gave us their information in the invitation email.

How We Use Your Information

We may use any of the information we collect for the following purposes.

  • Service functionality: To provide you with our products and services, including to take steps to enter a contract for our services, process payments, send communications (including renewal reminders), and conduct general business operations, such as accounting, recordkeeping, and audits. The lawful basis of processing is performance of a contract. In addition, we may collect citizenship information and passport information where the lawful basis of processing for this information is explicit consent.

  • Service improvement: To improve and grow our Services, including to develop new products and services and understand how our Services are being used, our customer base and purchasing trends, and the effectiveness of our marketing. The lawful basis of processing is our legitimate interest.

  • Personalization: To offer you recommendations and tailor the Services to your preferences. The lawful basis of processing is our legitimate interest.

  • Advertising and marketing: To send you marketing communications, personalize the advertisements you see on our Services and third-party online properties, and measure the effectiveness of our advertising. We may share your information with business partners, online advertising partners, and social media platforms for this purpose. The lawful basis of processing is consent and our legitimate interest.

  • Security: To protect and secure our Services, assets, network, and business operations, and to detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal. The lawful basis of processing is compliance with legal obligations and our legitimate interest.

  • Legal compliance: To comply with legal process, such as warrants, subpoenas, court orders, and lawful regulatory or law enforcement requests and to comply with applicable legal requirements. The lawful basis of processing is compliance with legal obligations.

  • Sensitive Personal Information: We may use this information for legal compliance; and to provide our Services (such as to facilitate matching with Hosts). The lawful basis of processing is consent, for compliance with a legal obligation, and/or as necessary to protect the vital interests of a data subject.

 

How We Share Your Information

We may share any of the information we collect with the following recipients.

  • Affiliates: We share information with other members of our group of companies.

  • Service providers: We engage vendors to perform specific business functions on our behalf, and they may receive information about you from us or collect it directly. These vendors are obligated by contract to use information that we share only for the purpose of providing these business functions, which include:

    • Supporting Service functionality, such as, customer service and customer relationship management, list cleansing, postal mailings, and communications (email, fax).

    • Auditing and accounting firms, such as firms that assist us in the creation of our financial records.

    • Professional services consultants, such as firms that perform analytics, assist with improving our business, provide legal services, or supply project-based resources and assistance.

    • Analytics and marketing services, including entities that analyze traffic on our online properties and assist with identifying and communicating with potential customers.

    • Security vendors, such as entities that assist with security incident verification and response, service notifications, and fraud prevention.

    • Information technology vendors, such as entities that assist with website design, hosting and maintenance, data and software storage, and network operation.

    • Marketing vendors, such as entities that support distribution of marketing emails.

  • Business partners: Based upon your interactions with our Services, we may share your personal information with unaffiliated third parties, such as business partners who provide products and services that we think you may be interested in.

  • Online advertising partners: We partner with companies that assist us in advertising our Services, including partners that use cookies and online tracking technologies to collect information to personalize, retarget, and measure the effectiveness of advertising.

  • Social media platforms: If you interact with us on social media platforms, the platform may be able to collect information about you and your interaction with us. If you interact with social media objects on our Services (for example, by clicking on a Facebook “like” button), both the platform and your connections on the platform may be able to view that activity. To control this sharing of information, please review the privacy policy of the relevant social media platform.

  • Government entities/Law enforcement: We may share information when we believe in good faith that we are lawfully authorized or required to do so to respond to lawful subpoenas, warrants, court orders, or other regulatory or law enforcement requests, or where necessary to protect our property or rights or the safety of our employees, our customers, or other individuals.

  • Other businesses in the context of a commercial transaction: We may change our ownership or corporate organization while providing the Services. We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information as described in this policy.

 
Security

We use a combination of physical, technical, and administrative safeguards to protect the information we collect through the Services. While we use these precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.

Your Options and Rights Regarding Your Information

Your Account: Please visit your account at http://app.icca.camp to update your account information.

Email Unsubscribe: If you do not wish to receive marketing information from us or wish to opt out of future email promotions from us, please contact us at: hello@icca.camp . All promotional email messages you receive from us will include an option to opt out of future email communications. Please note that your unsubscribe request only applies to promotional messages, and not to administrative messages that we are required to send as part of our business relationship. Examples of administrative messages include, but are not limited to, email messages regarding program compliance, urgent updates about weather or health alerts, reminders about confirming departure from a host country, and/or completing a SEVIS check-in.

 

Ad Choices: You have options to limit the information that we and our partners collect for online advertising purposes.

 

If you exercise these options, you may still see advertising, but it will not be personalized, nor will exercising these options prevent other companies from displaying personalized ads to you. If you delete your cookies, you may also delete your opt-out preferences.

 

Do Not Track: Your browser or device may include “Do Not Track” functionality. The information collection and disclosure practices and the choices that we provide to you will continue to operate as described in this privacy policy, whether a Do Not Track signal is received.

 

Jurisdiction-specific rights: You may have certain rights with respect to your personal information depending on your location or residency. Please see “privacy disclosures for specific jurisdictions” below. Please contact us to exercise your rights.

 

Special Information for ICCA Job Applicants

When you apply for a job with us, we may collect information from you, including:

  • Information you provide in connection with your application.

  • Information that you make available in your social media accounts.

  • Information about you that is available publicly.

  • Information that you authorize us to collect via third parties, including former employers or references.

 

In certain circumstances, you may submit your application for employment through a third-party service that displays our job posting. We do not control the privacy practices of these third-party services. Please review their privacy policies carefully prior to submitting your application materials.

 

Other Important Information

Data retention

We may store information about you for as long as we have a legitimate business need for it.

 

Cross-border data transfer

We may collect, process, and store your information in the United States and other countries. The laws in the United States regarding information may be different from the laws of your country. Any such transfers will comply with safeguards as required by relevant law.

 

Information about children

The Services are intended for users age thirteen and older. We do not knowingly collect information from children. If we discover that we have inadvertently collected information from anyone younger than the age of 13, we will delete that information. Please contact us at hello@icca.camp with any concerns.

 

Sharing of Medical or Health Information

To the extent that we receive protected health information about you, that information is subject to electronic disclosure to the extent permitted by applicable law.

 

Privacy Disclosures for Specific Jurisdictions

European Economic Area, United Kingdom, and Switzerland

We process “personal data,” as that term is defined in the European Union’s General Data Protection Regulation (“GDPR”).

Your rights under the GDPR: Users who are located in the European Economic Area (“EEA”), U.K., or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. Please contact us at privacy@interexchange.org to exercise these rights.

 

If you are located in the EEA, U.K., or Switzerland, you have the following rights.

  • Access and Portability: Request access to personal data we hold about you or request transmission of your data to a third party.

  • Correction: Request that we rectify inaccurate or incomplete personal data we store about you.

  • Erasure: Request that we erase personal data when such data is no longer necessary for the purpose for which it was collected, when you withdraw consent and no other legal basis for processing exists, or when you believe that your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.

  • Restriction of processing: Request that we restrict our processing of personal data if there is a dispute about the accuracy of the data; if the processing is unlawful; if the processing is no longer necessary for the purposes for which it was collected but is needed by you for the establishment, exercise, or defense of legal claims; or if your request to object to processing is pending evaluation.

  • Objection to processing: Object to processing of your personal data based on our legitimate interests or for direct marketing (including profiling). We will no longer process the data unless there are compelling legitimate grounds for our processing that override your interests, rights, and freedoms, or for the purpose of asserting, exercising, or defending legal claims.

  • Transfers: Obtain information about and a copy of the safeguards we use to transfer personal data across borders.

 

Contact information, submitting requests, and our response procedures

Please contact us if you have questions or wish to take any action with respect to information to which this privacy policy applies.

 

Email: hello@icca.camp

Telephone: +1 832-409-2731

Mail: 1707 Half Post Oak Blvd #281, Houston, Texas 77056 USA

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