Privacy Policy

This Privacy Policy explains who we are, how we obtain and use personal information about you, why we are allowed to do so by law, who has access to your personal information and what your rights are. Please review it carefully.

We are committed to protecting your personal information. We will always keep your personal information safe and comply with applicable data protection legislation when using your personal information. This Privacy Policy explains how we will do that.

 

You have the right to object to us using your personal information for our organization’s legitimate purposes. For more information about our organization’s legitimate purposes for using your personal information, and your rights and how you can exercise them, please see the sections Legal grounds for using your personal information and Your rights below.

 

Who we are

We are St Mark Community Education, a nonprofit 501c(3) corporation incorporated in Massachusetts and subject to the laws of Massachusetts and the  United States. Our registered address is at:

 

St Marks Community Education Program

25 Beach St

Dorchester, MA 02122

In this Privacy Policy, St Marks Community Education Program  is also referred to as “SMCEP” , "we", "us" or "our". We are the "controller" of the personal information you provide to us. If you have any questions concerning any SMCEP, you can contact us using the details set out at the end of this Privacy Policy.

 

What personal information we collect and why

Personal information is any information which identifies you personally, whether directly (for example, your name) or indirectly (for example, information about your use of our service).

 

We collect information from you when you register on our site, subscribe to our newsletters, respond to one of our surveys, or fill out a form.

When registering your details or making a booking for a service through our website or by completing a form, we may collect the following from you:

 

Your name: This allows us to refer to you when speaking to you and to address any post we may need to send to you specifically.

 

Your telephone number: This is needed to enable us to communicate with you. For example, we may need to call you back regarding a booking, or if we get disconnected from you. We may also call you in response to your expressed interest in SMCEP but will only do so if you tell us that you’re happy to be contacted in such a way.

 

Your mailing address: We need your address to communicate with you and, when required, to send you information and documents related to your booking or information you input into our registration forms.

 

Your email address: The email address you provide may be used to send you information and updates pertaining to your booking, and/or to occasionally send you company news, updates, or related product or service information. We will also send you information about the class registered, such as Zoom links, handouts and other class-related information.

 

Your city, state and country if not in the United States of residence for demographic purposes.

Your current level of English language proficiency: This information helps us tailor the services we may offer to you and to help track your learning with us.

 

Your credit card information: We need to know your credit card information to pay for services provided by us and to complete your booking if you are booking directly with us.

 

Your academic results: When you study with us we will record and use your academic results to help us monitor your progress and set appropriate work in class and outside the classroom.

 

Attendance record: We collect and use details of your attendance at our programs to help track your learning progress and so that we can comply with our grant funders and other regulatory agencies.

 

Emergency contact details: We need you to provide contact details for certain persons you have a close relationship to (for instance, your parents, spouse, partner, close friend or family member). We would only use this information in the event of an emergency situation involving you. By providing this information, you agree that you have informed the relevant person(s) of the provision of their contact details to us, and that they are happy for you to do so.

 

Green card: If applying for a citizenship class, we ask how long you have had your green card to determine your eligibility to take the class.

 

Citizenship Test Result: We collect and use details of your citizenship test result at our programs to help track your learning progress and so that we can comply with our grant funders and other regulatory agencies.

Demographic information such as city of residence, income range, country of origin  attendance data, pre and post assessments with funders to confirm we are servicing the target population and other requirements.

 

We will ask whether you have any needs for additional assistance that you would like us to take into account. This will help us tailor our services to you. For example, if you tell us that you are visually impaired or have hearing issues, we can ensure you are given an accommodation that meets your needs. You don’t have to provide this information to us, and, if you choose not to, it won’t prevent us from providing our services to you (we may, however, be unable to provide any additional assistance).

 

How we collect information

When you conduct a transaction such as sending a message through a contact form, registering for class or subscribing the newsletter on our website, as part of the process, we collect personal information you give us such as your name, address, phone number and email address. Your personal information will be used for the specific reasons stated above only.

 

How do we store, use, share and disclose your site visitors' personal information

SMCEP is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to sell our products and services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall.

 

All direct payment gateways offered by Wix.com and used by our company adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.

 

We will disclose your personal information if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to protect the rights, property or safety of our organization, our customers or others; and to successors in title or replacement operators of all or part of our organization, subject to the data being used for the same purposes as originally specified.

 

What information might be shared

  • Information you enter into our booking form or registration form.

  • Information collected on our behalf as part of providing our services to you.

 

Who the information is shared with

  • Teachers and tutors of SMCEP programs

  • Grant funders

  • USCIS if assisting you to resolve an issue

 

How we use your personal information

 

We will also use your personal information to:

  • personalize your experience (your information helps us to better respond to your individual needs)

  • improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you)

  • improve customer service (your information helps us to more effectively respond to your customer service requests and support needs)

  • process transactions

  • administer a contest, promotion, survey or other site feature

  • send periodic emails

 

We only ever use your personal information where we have a legal right to do so. Please see the Legal grounds for using your personal information section below for further information.

 

How we communicate with you

We will contact you to notify you regarding your registration, to troubleshoot problems with same, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveys or questionnaires, to send updates about our company, or as otherwise necessary to contact you to enforce our User Agreement, applicable national laws, and any agreement we may have with you. For these purposes we will contact you via email, telephone, text messages, and postal mail.

 

Marketing

SMCEP would like to send you information about products and services of ours that we think you might like.

If you have agreed to receive marketing, you may always opt out at a later date.

 

You have the right at any time to stop SMCEP from contacting you for marketing purposes or giving your data to other members of SMCEP.

 

If you no longer wish to be contacted for marketing purposes, please click on the opt out link on marketing materials or contact privacy@stmarksesol.org.

 

Cookies and other tracking tools

 

SMCEP uses Wix to host their website and Wix uses cookies for important reasons, such as:

  • To provide a great experience for site visitors and customers.

  • To identify registered members (those who create a user name and password to the SMCEP website).

  • To monitor and analyze the performance, operation and effectiveness of Wix's platform.

  • To ensure Wix platform is secure and safe to use. 

 

The following links explain how to access cookie settings in various browsers

 

Please click here to learn more about cookies:

All About Cookies

 

Legal grounds for using your personal information

We only collect and use your personal information if have legal grounds to do so. We rely on a number of different grounds for handling your personal information. These are as follows:

 

For our organization’s legitimate purposes

 

In certain circumstances, it is necessary to collect and use your personal information for the purposes of our legitimate interests as organizations, which are to:

  • Understand your current level of English proficiency.

  • Monitor your academic progress, provide you with feedback on this and customize your class work and work outside the classroom.

  • Obtain feedback on student satisfaction in respect of the services we provide to you.

 

Where we rely on this legal ground for handling your personal information, we consider whether our interests as an organization are overridden by your interests or fundamental rights and freedoms. We have considered these matters and on balance, we consider that our interests described above are not outweighed by your fundamental rights and freedoms. You may request further information from us concerning the process we have followed here.

 

You have the right to object to the decision we have arrived at. Please see Your rights below.

 

Where we think there is a risk that one of your interests or fundamental rights and freedoms may be affected, we will not use your personal information unless we have obtained your consent to using it in that way.

 

For compliance with our legal obligations

If asked, and if obligated and authorized to do so by law, we share your personal information with law enforcement agencies, regulators, courts or other public authorities.

 

For performance of our contract with you

 

Aside from the information noted above that we use on the basis of our legitimate purposes and to comply with our legal obligations, we use the information we collect as part of our booking process to assist in entering into a contract with you to provide our services. This may include us providing you with a quote for provision of our services.

 

Consent

We first obtain your consent before we collect and use your information for the purpose of informing you of information about our business which may include new products, new locations and promotional offers.

 

How long we keep your personal information

We retain your personal information for no longer than is necessary for the purposes for which it was provided and in accordance with our data retention policy. What this means in practice will vary between different types of information.

In summary, we keep:

  • Information about your booking or registration for up to ten years.

  • Information about details required to inform you of our activities and offers for up to five years (or the point at which you ask us to unsubscribe you from our mailing list).

  • Following these periods, we will stop using the relevant information and it will either be anonymized or deleted to the extent it is technically feasible to do so.

  • In certain limited circumstances we may be required to retain your personal information for longer. When determining whether this is necessary for the purpose(s) for which it was provided, we take into account factors including:

  • The sensitivity of the personal data we are holding and business risks we face if we delete or anonymize the data.

  • Specific regulatory or other legal requirements to hold the information.

 

How to withdraw your consent for our sharing your information

You may withdraw your consent at any by contacting us by mail, email or by phone.

 

Your rights

You have the following rights regarding your personal information:

 

Right to be informed

 You have the right to be provided with clear, transparent and easily understandable information about how we use your personal information and your rights. This is why we are providing you with the details of what information we keep in this Privacy Policy.

 

Right of access

You have the right to obtain access to your personal information (if we are using it) and certain other information (similar to that provided in this Privacy Policy). This is so you are aware and can check that we are using your personal information in accordance with data protection law.

 

Right to rectification

You are entitled to have your personal information corrected if it is inaccurate or incomplete.

 

Right to erasure

This is also known as ‘the right to be forgotten’, and, in simple terms, enables you to request the deletion or removal of your personal information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions (for example, we have the right to continue using your personal information if such usage is necessary for compliance with our legal obligations).

 

Right to restrict processing

You have the right to ‘block’ or suppress further use of your personal information in certain circumstances (for example, where you think the personal information, we are using about you is inaccurate, whilst we verify its accuracy). When usage is restricted, we can still store your personal information, but may not use it further. We keep lists of people who have asked for further use of their personal information to be ‘blocked’ to make sure the restriction is respected in future.

 

Right to data portability

You have the right to obtain and reuse your personal information in a structured, commonly used and machine-readable format in certain circumstances when we use your personal information on certain legal grounds, such as consent. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party. The right to data portability does not apply to personal information which it is necessary for us to process for our organization’s legitimate purposes. Please see the section, Legal grounds, for using your personal information to read about the circumstances in which we use your personal information on the basis of consent or for our organization’s legitimate purposes.

 

Right to object to processing on the grounds of legitimate interests

You have the right to object to us using your personal information for our organization’s legitimate purposes. Please see the section, Legal grounds, for using your personal information to read about the circumstances in which we use your personal information for our organization’s legitimate purposes.

 

Right to withdraw consent to processing

If you have given your consent to us to use your personal information for a specific purpose, you have the right to withdraw your consent at any time (although if you do so, it does not mean that any use of your personal information up to that point is unlawful).

 

Right to make a complaint to the data protection authorities

You have the right to make a complaint to Director, Mike Oliver if you are unhappy with how we have handled your personal information or believe our use of your personal information does not comply with data protection law.

 

If you would like to exercise your data protection rights or if you are unhappy with how we have handled your personal information, you may contact us by mail at:

 

St Marks Community Education Program

25 Beach St

Dorchester, MA 02122

617-288-8515

or by email at: privacy@stmarksesol.org

 

If you're not satisfied with our response to any enquiry or complaint or believe our use of your personal information does not comply with data protection law, you can make a complaint by emailing privacy@stmarksesol.org.

 

Privacy policy updates

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

 

Last Update: May 24, 2021