SUPPLEMENTAL POLICY TO THE TGS PRIVACY AND INFORMATION SECURITY POLICY ("POLICY")


    EFFECTIVE DATE: JANUARY 3RD, 2013

    This Think Global School ("TGS") Supplemental Policy ("Supplemental Policy") to the TGS Privacy and Information Security Policy ("Master Policy") supplements the Master Policy. Together, the Supplemental Policy and the Master Policy constitute the TGS Privacy and Information Security Policy ("Policy"). This Supplemental Policy is being made available to you because you have been invited to enroll in TGS, are the parent or guardian of a student who has received such an offer, or you have been made an offer of employment or other retention by TGS.

    ACCEPTING AN OFFER OF EMPLOYMENT OR OTHER RETENTION BY TGS, ENROLLING A STUDENT IN TGS, OR FAILING TO TERMINATE EMPLOYMENT OR ENROLLMENT AFTER HAVING AN OPPORTUNITY TO REVIEW THIS SUPPLEMENTAL POLICY OR ANY AMENDMENT, WILL BE YOUR AGREEMENT TO THE POLICY (INCLUDING THE MASTER POLICY AND THE SUPPLEMENTAL POLICY) OR AMENDMENT, WITHOUT MODIFICATION BY YOU. If you do not agree, do not do any of the foregoing.

    INCORPORATED TERMS

    Master Policy. This Supplemental Policy includes all terms and conditions of the Master Policy which you should review and download or print by clicking on the above link to the Master Policy. The Think Global School Terms of Use ("Master Terms") and the Think Global School Spot Terms of Use ("Spot Terms") are incorporated into and made a part of this Supplemental Policy by this reference. This Supplemental Policy may be amended in the same way as the Master Policy.

    Definitions. Terms used but not defined in this Supplemental Policy have the definitions set forth in the Master Terms and Spot Terms, except that "Site" (as defined in the Master Terms) shall also include Spot (spot.thinkglobalschool.com), and any mobile application in connection with Spot ("Spot App").

    Supplemental Policy

    The following supplements and applies in addition to the Master Policy. If there is a conflict between this Supplemental Policy and the Master Policy, the more specific provision of the Supplemental Policy will control the conflict.

    Information That You Affirmatively Provide. In addition to the personal information we collect that is described in the foregoing section of the Master Policy, we or Third Party Services collect additional information from persons who proceed beyond the application stage. For example:

    • If you are invited to an interview, we might collect identification and information about any disability for which you seek accommodation or anything else for which you seek accommodation (such as religious information). Such information is only required if you choose to seek an accommodation.
    • If you are employed, we and/or governmental authorities may need your Social Security Number or other governmental identification numbers, bank account number and related employment information, passport and visa information, emergency contact information, medical condition information (e.g., in case something happens while we are on the road), dietary information, housing information and so on. We will need most of the same information from students as well as other information from everyone who travels with us, including more information such as gender and date of birth.
    • If you are a parent or guardian, we will need tuition payment information (e.g., bank account number, billing address and so on) as well as information about your legal status relative to the enrolled student (e.g., dissolution decree, adoption orders and so on).
    • If you apply for a scholarship, we will need financial and other information to help us or others determine eligibility, including (but not limited to) this kind of information about parents, guardians and financial supporters: names, ages, salaries, other income details, parental divorce/separation information, assets, and business information.
    • When you use a Third Party Service, it may require information from you and its terms and policies may apply.
    • We will require or allow pictures, videos, blog posts, profile information, and other information for various uses on Spot and the Spot App. For example, students and faculty might share photos and other information about their TGS experiences or their academic work – all of these kinds of things might include personal information.

    The above is not a complete listing of personal information that is collected and you should look at each document seeking personal information from you. Some are part of the Operative Documents attached to (and defined in) your enrollment or employment packet or others will be delivered in the future, such as per-country requirements. TGS will not necessarily be collecting that information but it may be required (such as by a governmental entity with whom you may deal) in order to participate in a TGS program. Third Party Services might also collect information.

    Information That You Do Not Affirmatively Provide. In addition to the personal information we collect that is described in the foregoing section of the Master Policy, we reserve the right to use stronger "cookies" and other tracking mechanisms, and to impose greater security on Spot or the Spot App for Members. We will develop and change that space from time to time and reserve the right to make further Disclosures.

    What We Do With Personal Information (Disclosure). In addition to the personal information we collect that is described in the foregoing section of the Master Policy, we may Disclose any personal information: (a) relevant to your role as a student, employee, parent or guardian (e.g., we will Disclose your grades and transcripts to colleges or other schools to which you apply after graduation); (b) not prohibited by law; (c) as allowed in other contracts, policies or procedures (e.g., student or employee handbooks, consents and enrollment or employment contracts); and (d) to Third Party Services in order to set up and administer accounts for you with Third Party Services, or to otherwise allow you to use those services. As a travelling school, we are likely to need and disclose more personal information than schools in one location and are likely to need to do so in more circumstances, including unexpected circumstances. You accept this risk.

    Third Party Systems and Services that We Use. In addition to the Third Party Services described in the Master Policy, we also use additional Third Party Services for employees, students, and certain members of the TGS Community – these additional services, as changed from time to time, are part of the Third Party Services. Third Party Services allow us to offer a richer educational experience than we would otherwise be able to provide by using our own software applications and services. You may be able to tell that a Third Party Service is used if you exit Spot, or if the feature that you seek to use contains the branding of another entity; such indications put you on notice that Third Party Services are being used, and accordingly, that other policies and practices may apply to your personal information. TGS does not control these Third Party Services, and does not purport to inform you of all of their policies and practices, which may change from time to time without notice to us, or to you.

    The Third Party Services provide many of the services that TGS, Spot, and the Spot App use, including e-mail, videos, images, blogging and micro-blogging, and voice over IP ("VOIP"). The Third Party Services will change from time to time. For questions about which Third Party Services we use at a particular time, please contact our Head of Technology. An illustrative list of Third Party Services that we use includes service such as:

    • Google Apps for Education, which includes e-mail hosted by Gmail (www.google.com/a/edu/);
    • Google Books (http://books.google.com);
    • MindMeister (http://www.mindmeister.com/);
    • Skype (http://www.skype.com/); and
    • Rosetta Stone (http://www.rosettastone.com/);
    • Managebac (managebac.com); and
    • Kaltura (http://corp.kaltura.com/).

    Third Party Services may make many or more Disclosures that TGS makes with your personal information, and Third Party Services may have different privacy practices and policies that you should review before using any Third Party Service. There will be conflicts between our policies and practices and those of Third Party Services. Third Party Service policies and practices typically involve (but are not limited to) the following:

    • Using personal information that you supply or that is otherwise collected in your use of the Third Party Service, to customize advertising content that you see, request your participation in surveys, or engage in marketing or promotional operations, offers, contests, and games. Some of our contracts for Third Party Services preclude advertisements to students, however;
    • Requiring you to generally provide complete and accurate personal information to Third Party Services, and updating the information that you provide when it becomes inaccurate or incomplete;
    • Collecting more categories of personal information than TGS possesses about you, including information that you provide to Third Party Services, such as information about your profile, contacts, log-ons, account activity, and data displayed or clicked on. For example, Skype or other VOIP Third Party Services may collect video and sound recordings, and Google may collect location data bout you when you use location based services such as Google Maps for your iPhone or mobile device;
    • Retaining your personal information for longer periods of time, in the sole discretion of Third Party Services;
    • Sharing your personal information with other third parties, for their purposes, and to provide you with the services that they offer;
    • Disclosing your information to judicial, law enforcement, or government authorities upon request;
    • Placing cookies and/or third party cookies on your computer, and sharing the information collected with third parties; and
    • Utilizing clear gifs, web beacons, and other hidden tracking mechanisms to track website page visits and your e-mail usage practices.

    We may be able to access, monitor, use, or otherwise Disclose personal information that you provide to Third Party Services that you access through Spot or the Spot App, or otherwise utilize in connection with your employment, enrollment, or affiliation with TGS. For example, if you use Skype, we may obtain your personal and traffic data. You consent to this.

    Information Security and Protecting Yourself. We will take what we believe to be commercially reasonable steps to protect Spot and the Spot App but you need to do your part as well. As noted in the Master Policy, perfect security is not possible and the nature of the Internet makes it more impossible. For example, you may post a picture of yourself and your classmates intended only for your parents to see, but if a parent or a classmate were to share that picture then more people will see it. Accordingly, be careful about what you post.

    Medical Records. You will complete a Medical Information Form which will provide us with general medical information about you, and you will update this form as necessary to ensure that the information it contains is always current. This information is being provided to us to be used,among other reasons, to provide needed medical care. We may also use the information for internal purposes, such as determining the extent of a disability to determine what reasonable accommodations are, but we will not disclose the information to third parties unless disclosure is required to provide needed medical care, accommodations, or in the event of a medical emergency or disclosure is required by law. If copies of your medical records are provided to us pursuant to a Medical Records Release Form, you acknowledge and agree that we are holding those records for you only as your agent and that the records are your property and not the property of TGS. We reserve the right to use the medical records to update our files to ensure that the medical information we have on file for you is complete. Please note that TGS is not a "Covered Entity" under the Health Information Portability and Accountability Act ("HIPAA") and therefore TGS is not subject to HIPAA’s rules regarding disclosure of protected health information.

    No Waiver of Employer Rights. Nothing in our Policy waives any of our rights to Disclose information under our other contracts with you, under our other policies and procedures, or under any law that applies to TGS, notwithstanding any conflict or contrary provision in this Policy. For example, if employment law does not give you a right to access your information, then you may not access it by trying to rely on this Policy – we retain all of our rights as an employer.