PRIVACY POLICY
For online Users of Harris Connect’s
Graduate Connection® Online Community
The privacy of your personal information is of key importance to Harris Connect, LLC. ("Harris Connect" or "we"). To maintain the highest level of protection in the industry, Harris Connect has taken and will always take significant steps to keep your personal data secure. We ask that you please read and follow the practices described in this Privacy Policy (the "Policy") to ensure the privacy of your data and that of other users.
Your use of this Web site (the "Site") and services related to it will indicate your acceptance of these terms. If you do NOT agree with these terms, please DISCONTINUE your use of the Site.
Introduction
Notice & Disclosure
Please note that this Privacy Policy may change and you should periodically review it to ensure your familiarity with the most recent version. This Policy is incorporated by reference into, and is subject to, the Graduate Connection® Terms and Conditions.The personal information/data ("Personally Identifiable Information", or "PII") covered by this Policy includes:
Name
Maiden name, if applicable
Mailing address
email address
Phone number
Class Year
Spouse/partner/children's names
Photo
Password
Preferred class year
Other academic information - name of institution, degree, etc.
Professional info (e.g., job title, company name, etc.)
This Policy consists of the following Sections:
- Collection and Use of PII
- Sharing of PII
- Modifying Your PII
- Security of Your PII
- Minors, International Users & Safe Harbor Registration
I. Collection and Use of PII
This Policy addresses only Harris Connect's use and disclosure of the PII we collect from you, your representative and other sources, including but not limited to: directory information permitted to be released under the Family Education Rights Privacy Act of 1974 ("FERPA"), as provided by the school or alumni association/foundation affiliated with your school, third party research providers that provide contact information using publicly available sources, and reunion organizers authorized to conduct class reunions for your school. Different rules may apply to the use and disclosure of information by your school, association or organization. Therefore you should review any privacy policy available on the Web site of your school, association or organization to determine how any information collected by it from you may be used. When you are updating PII for inclusion in a Harris Connect directory, except as noted below, any information provided by you to us will only be released to the school, association or organization for which it has been prepared, people who have proven their identities as members or alumni of that school, association or organization, or reunion organizers authorized to conduct class reunions for your school. If you would not like your information shared, you will always have the opportunity to hide your profile or portions of your profile - via the Update Profile feature online.
Only authenticated users have online access to any PII and any of the services available on the Site.
Credit Card and Related Information. If you elect to purchase a product/service offered on the Site, you may be required to provide us with certain contact information, such as your name, email address and billing address. Additional information may be needed to process a related payment, such as a credit card number and expiration date. Information you provide to us may be used to bill you for products/services you request, or to notify you of other products/services that are available.
By purchasing a product/service on the Site, you consent to our delivery of this information to our service providers, including but not limited to banks and credit card companies that we use for processing the transaction. We may contract with a third party to provide certain services for us, including sending emails to users, conducting user surveys, processing transactions or performing statistical analysis. In so doing, we may provide certain PII, such as your name, email address and other financial information required in order to deliver the service.
Other than as described above, we will share your PII only with a very limited group of persons or entities - except in specific instances where your informed consent has been obtained - including our research partners and third party vendors who help us provide you with services and products we offer e.g., for distribution of print and CD-ROM directories, all of whom have signed agreements with Harris Connect containing provisions protecting the confidentiality of PII that are at least as protective as this Policy, and prohibiting retention, sharing, storage or use of PII for any other purpose.Harris Connect may use PII to send email on behalf of partners and vendors under contract with Harris Connect, for which each member will have the right to opt out. (See also Section IV. Security of Your PII below.)
Also, only with your written consent, Harris Connect will provide pre-employment verification of your academic credentials in the form of a "verify/unable to verify" response.
Keep in mind that this Site may contain links to other Web sites that may or may not be owned or operated by Harris Connect. Unless otherwise explicitly stated, we are not responsible for the privacy practices or content of such sites, including such sites' use of any information collected when visitors to the Site click through links to those sites. To the extent you disclose your PII on unaffiliated Web sites, different rules may apply to the use or disclosure of your PII to third parties. Any dealings you may have with an advertiser or other third party found on or through this Site, including participating in promotions, purchasing goods or services, and any terms and conditions, warranties or representations related to such activities, are solely between you and such party.
Note that whenever you voluntarily disclose any PII online - e.g., on message boards, through email, or in chat areas - that PII can be collected and used by others. If you post PII online that is accessible to other users of the Site, members or alumni of your school, association or organization, we cannot control others' use of that information.
A. Using email via the Site
The Site's "Send an email" feature enables a member to send an email to another member. "Invite as a friend" enables a member to invite another member to become part of the 1st member's social network. You can send an event invitation via email. When you send email, you reveal your email address to the recipient. Harris Connect respects the privacy of user emails sent via the Site, and will not read or disclose those communications, except when deemed necessary as described below in Section II.D. Legal Disclosure.
B. Using Reunion Boards and Class Notes
Any information you post to Reunion Boards and Class Notes including any associated photos is displayed only to authenticated users of the Site, so please take care in determining the information you decide to disclose.
We have the right, but not the obligation, to monitor any activity and content associated with the Site. Please review our Community Guidelines for more information regarding your appropriate use of the Site.
C. Using 'Invite as a Friend' or 'Send Event Invitation'
If you use a referral service feature in the Site to inform a friend about the Site or a part of it, you will be asked for your friend's name and email address. Harris Connect will automatically send the friend this email (that normally also includes your name and email address) inviting them to visit the Site. The friend's name and email address are requested only to enable us to send this email and to track the success of the referral program.
D. Building a Personal Profile
The Site contains tools so that users can find and view what their old friends have been doing and also find new friends who may share similar interests. When you use the tools to create My Personal Profile (the "Profile") you can decide how much PII you wish to share.
Unless described otherwise when using a particular Profile tool, information that you provide there is viewable by other users and may be found in results of a search feature in the Site. So you should be careful in deciding what information you do and do not want to reveal in your Profile. Please review our Community
Guidelines for more information regarding your appropriate use of the Site.
Also as stated in the Graduate Connection® Terms and Conditions, Harris Connect may use the information provided in the Profile in a variety of Harris Connect products/services/ features, such as affiliation-specific emails, or other services for which your school, association or organization has contracted with Harris Connect to make available to you.
There are Privacy Settings on the Site which enable a user to use a link under email services so that the user can decide which category of emails, news or information a user wants to receive; to hide the entire Profile or elements of the Profile; a user can choose how they will receive email from their friends in their social network. Keep in mind that your school, association or organization has access to any hidden portions of your Profile.
Aggregated data. There may be times when Harris Connect uses PII from your Profile, or your use of the Site/services, without identifying you as an individual to third parties. A portion of your PII may be aggregated, without revealing your identity, with that of other users, in order to know how many users utilize a particular feature, function or other part of the Site or services, for such purposes as Harris Connect, in its sole discretion, deems reasonable or appropriate.
E. Viewing Other Users' Profiles
Harris Connect enables you to locate other users by browsing the affiliation lists or using the search feature in the Site. When you have found another user, you can view his/her Profile to learn more depending on the information they are sharing in the Site.
II. Sharing of PII; Opting Out; Access & Participation; Legal Disclosure
While we believe that all of the products and services that Harris Connect offers are valuable to everyone, we realize you may not wish to participate. Your school, association or organization will provide us with your directory information to carry out whatever project or service for which they have contracted with us, but the inclusion of your PII in any of our products or services is at your option. You have the ability to request omission of all or portions of your PII from this Site.
A. Opting Out
If you wish to opt out of inclusion in this Site, you can log in and decide to: opt out of receiving any emails from Harris, your school, association or organization, or any networked friends; or hide your Profile in its entirety or portions thereof so that none (or applicable portions) of your PII will appear in any online directory searches.
You may also contact us via U.S. mail or email as follows, identifying the specific program (e.g., XYZ High School Online Community).
By U.S. mail: Harris Connect Graduate Connection, 1511 Route 22, Suite C-25, Brewster, NY 10509
By email: gradfeedback@graduateconnections.com
B. Internet Advertising Policy
For advertisements on Harris Connect sites:
This Advertising Policy (the "Ad Policy") is applicable to all Advertisers, Ads and Sites.
1. Ad Content and Site Content. To provide quality information, news and tools in a timely manner to the alumni, staff and friends of public high schools, Harris Connect ("HC") permits certain advertising on the site HC hosts for each school (the "Site"). However, HC does NOT allow advertisers to affect the quality or accuracy of information on the Site. Further, HC does NOT endorse any products, and the fact that an advertisement appears on the Site is not, and should not be deemed, a recommendation, approval or guarantee by HC of any product or service advertised or claim made. All advertisers are totally independent of HC and HC assumes no responsibility for the content of their advertisements. HC does not permit any advertiser or other third party sponsor to change any content of the Site or introduce biased content into the design of any section of the Site.
2. Requirements for Ads. Advertisements appear on the Sites ("Ads") only following execution of, and pursuant to, an online advertising insertion order ("Insertion Order" or "IO") between HC and the advertiser ("Advertiser"). The requirements for each Ad are stated in the Standard Terms & Conditions of the IO (such as the prohibition of false, misleading or inaccurate advertising). Advertisers are also bound by the Corporate Privacy Policy of HC which is incorporated herein by reference.
3. Identification. HC clearly identifies all Ads, sponsorships and sponsor-related materials on the Site. Advertisers must place in at least one frame of the Ad either the pertinent company's registered URL or name. No advertisement will be accepted that does not identify the company.
4. Spyware and related Software. HC strictly prohibits the delivery, on or through any Site, of spyware or any software that contains any virus or other computer program or code intended to damage, interfere with, intercept or expropriate any data, personal information, program or system. "Spyware" includes but is not limited to: a software-based trigger or program that monitors usage of a computer, sends information about such usage or identifying information to a remote computer or server, and/or displays or causes to be displayed an advertisement in response to such usage without the knowledge or consent of the user (e.g., a Trojan horse).
5. Site Aggregators. HC reserves the right to review all potential advertisers' websites at any time, before or after placement of an Ad on a Site, to determine whether they are deemed "site aggregators", which act as a portal or destination site containing content and advertising from multiple entities. Ad server tags (including third party tags) will be implemented by HC so that they are functional.
6. Space Brokering. Advertising agencies desiring to purchase space in a Site must comply with the following:
- Space must be filled by a single specific advertiser.
- IOs for space must be signed by each advertiser, and a signed agreement between agency and HC must accompany each IO.
7. Changes to this Ad Policy. HC reserves the right to change or eliminate this Policy. Thereafter submission of an Ad for distribution or publication by HC represents the Advertiser's agreement to this Policy as changed.
C. Access & Participation
Access to and active participation in all of our products and services is convenient and easy if you are a bona fide alumnus/a or member of one of Harris Connect's client organizations. Your name and other PII must be provided to us on the database we receive from your pertinent organization in order for you to be permitted to gain access to the Site. If we cannot validate your affiliation, we will contact the organization to determine your status. We want you to be actively involved in order to get the most out of our services, so we provide easy online access for you to contact us. Updating your directory listings on the Site or purchasing a subscription can be done at your convenience. For the online community, you have access to your information so long as the client organization has an active contract with Harris Connect to host the online community. In order to gain access to this Site, users will be provided with a unique ID and asked to create a user name and password.
Although Harris Connect simultaneously hosts information for multiple client organizations, each organization and its constituents can only view the information pertinent to that specific organization.
D. Legal Disclosure; Protection of Rights, Property and Safety
At all times, Harris Connect reserves the right to disclose any information, including PII: to comply with any applicable law, regulation, legal process or government request; to investigate, prevent or take action to protect any party's safety or property, including Harris Connect's rights or property (including without limitation in the event of a merger or transfer of control of Harris Connect or substantially all of its assets); during emergencies when safety is at risk; in suspected illegal activities, credit fraud, or for risk reduction purposes; or suspected violations of Graduate Connection® Terms and Conditins.
III. Modifying Your PII
Quality and accuracy hold a place of high importance at Harris Connect since so many individuals look to the products and services we provide for career networking, getting back in touch with old friends, and reaching out to make new ones. Therefore it is very important that you be able to contact Harris Connect if your PII is inaccurate in any way or out of date. You will always have the opportunity to update your profile or portions of your profile through the Update Profile feature. If you want to contact us, please email us at gradfeedback@graduateconnections.com. We want you to get the most value out of our products and services, and working with you to ensure that your information is up-to-date is the best way to accomplish that.
IV. Security of Your PII; International Users; Safe Harbor Registration
Except as provided in this Policy, Harris Connect will neither give nor sell your PII to anyone who does not have a hand in directly providing you with our valuable products and services. Your PII will appear in this online directory unless you hide your Profile or ask us to exclude it, and we always maintain significant safeguards to protect your PII provided to us for inclusion in this directory. All Harris Connect employees sign confidentiality agreements obligating them not to disclose PII to which they have access as part of their job. Harris Connect restricts access to certain databases to employees on an "as needed" basis. Although no online data transmission can be 100% guaranteed secure, Harris Connect's online security is consistent with online industry security requirements and access to your own PII is password protected to further ensure your privacy. However, Harris Connect cannot and will not be responsible for any activity of a school, association or organization that results in a deviation from our standard security measures. You should take your own precautions to keep your ID and password confidential and secure, and notify us immediately if you believe unauthorized access to your account has occurred, or your ID or password has been compromised. Given the rapid rate of development of technological threats to privacy, information security and Internet activities, we cannot and will not be liable for security breaches beyond our control. No one can guarantee the security of PII under all circumstances. But working with you to take care to protect PII using the most accepted business practices, together you and we can keep PII as safe as possible.
To secure your PII, access to your PII on the Site is protected by unique password, and sensitive data (e.g., credit card information) is protected by SSL encryption when it is transmitted between your browser and the Site. To protect any PII you place on the Site, we take the additional precautions of continually conducting audits of our systems against potential vulnerabilities.
For additional security, we have in place physical, electronic and procedural safeguards to store and maintain your PII. To assist in this effort, you may be required to use a password to access certain pages on the Site where portions of your PII or Profile can be changed or deleted. Therefore please be sure to protect against unauthorized access to your password, to emails from us, and to your computer.
International Users & Safe Harbor Registration
Users who use the Site from outside the U.S. should be aware that providing PII to us represents consent to the transfer of PII to the U.S. for handling and keeping PII pursuant to this Policy, regardless of privacy laws and regulations in any other country.
At Harris Connect, we value our business relationships with European Union clients as well as those in the U.S. and Canada. To ensure ongoing harmony in those relationships, particularly with respect to the privacy protection of PII shared, Harris Connect pledges to conduct its business according to the Safe Harbor Privacy Principles agreed upon by the U.S. Department of Commerce and the European Union ("Safe Harbor"), which regulations are defined more thoroughly on the U.S. Department of Commerce Web site http://www.export.gov/safeharbor.
Individuals who wish to file a complaint relating to Safe Harbor or who take issue with Harris Connect's Safe Harbor policies should direct such communication to the contact information provided in Section II.A above. Harris Connect has registered under the Direct Marketing Association's Safe Harbor complaint resolution process. Should an individual be unable to resolve a complaint related to Safe Harbor after having contacted Harris Connect's customer service department above, he/she may file a complaint with the Direct Marketing Association as indicated below:
V. Minors
Children below the age of 18 (minors) are not eligible to become users and are not permitted to use the Site or our services. They should not attempt to do so, nor submit any PII. If we become aware that a minor is a user, access will be terminated and the ID and password disabled. It is Harris Connect's policy to comply with the Children's Online Privacy Act and fair information practices.
Recent Changes/Updates to this Policy
The effective date of the most recent update is: September 22, 2008.
Graduate Connection is a registered trademark of Harris Connect, LLC.
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