Privacy Policy Statement

Effective Date: May 25th, 2018

Colonial Williamsburg Foundation (CWF)
Privacy Policy for Residents of the European Economic Area

NOTE: This policy is directed to residents of the European Economic Area (“EEA”), if you are located outside of the EEA please refer to CWC’s Privacy Policy.

Protection and proper use of your personal information is very important to us and we are committed to having proper processes for the collection, use and protection of it. The purpose of this section is to explain what information we collect from you; how the personal information that you are asked to submit or have submitted will be used by the Colonial Williamsburg Foundation and its subsidiary, the Colonial Williamsburg Company (hereafter referred to as CWF); how your personal information is protected and transferred and to provide the information that you need to provide your consent to this use. CWF is located at 301 First Street, Williamsburg, Virginia 23185, United States and is incorporated in the Commonwealth of Virginia.  CWF is the primary data controller for your personal information covered under this policy.

If You are Under 16 Years Old

The CWF websites will not deliberately collect, use, provide or process in any other form any personal information of children under the age of 16.

We therefore also ask you, if you are under 16 years old, please do not send us or submit your personal information (for example, your name and email address). If you are under 16 years old and you nevertheless wish to use the websites in anyway which requires you to submit your personal information, please get your parent or guardian to do so on your behalf.

Purpose of Collecting Personal Information

Your personal information is collected by CWF to communicate with you. We use it to:

• manage our business and our relationship with you;
• deal with your inquiries;
• process your requests for products and/or services
• understand how our website is used so that we can improve it and to comply with our legal and regulatory responsibilities and to prevent and detect crime and fraud.

We may combine and analyze your personal information to help us develop and improve our products and services as well as to understand our customers better and to manage and improve our relationship with you. This could include, for example, evaluating the effectiveness of our marketing and customer service and conducting market analysis.

CWF does not resell your personal information.

We will not otherwise use or disclose your personal information without your consent except (i) as described in this privacy policy, (ii) as required by court order or other government or law enforcement authorities in order to comply with legal process or law, (iii) in the event of a legitimate interest of CWF (iv) in order to protect and defend our rights and property, or (v) in order to protect the personal safety or property of our users or the public.

Types of Personal Information Collected

Personal information collected when you contact CWF through our website or any of our locations:

Name, email, your company name (if applicable), address, contact telephone number and country of origin.

Work experience, qualifications, personal information provided in a resumé and nationality/right to work details including work permit information (if applicable).

CWF may automatically collect non-personal information about you such as the type of internet browsers and cookies (see section 9 below for details on our Cookie Policy) you use or the website from which you linked to our website. We may also aggregate details which you have submitted to the site (for example, the country where you live). You cannot be identified from this information and it is only used to assist us in providing an effective service on this web site. We may from time to time supply third parties with this non-personal or aggregated data for uses in connection with this website.

We may also create de-identified information from such information that you provide to us and used per the paragraph below described as ‘creation of de-identified data’.

If it is reasonably necessary, we may disclose all or part of this information to a third-party service provider and/or relevant CWF personnel, for CWF to meet any of its legal and regulatory obligations to you including but not limited to the assessment of your inquiry and the implementation of a response arising out of the assessment.

Creation of De-Identified Data

We may create De-Identified Data records from personal data by excluding information (such as your name) that makes the data personally identifiable to you. Once we create De-Identified Data, this De-Identified Data is our property. We use this De-Identified Data in many ways including analyzing request and usage patterns, creating reports and performing analytics so that we may enhance the content of our services, our compliance with equal opportunities regulations, improve Site navigation and provide meaningful analysis of habits, usage, trends, and effectiveness of marketing campaigns etc. as part of our analytics and other services. CWF reserves the right to use and disclose De-Identified Data to Third Party Companies in its absolute discretion.

Career Information

If you apply for a career with us we will collect the information you provide to us in any forms you fill in plus your resumé (or for example your LinkedIn profile) if you provide that to us. We may also carry out background and other checks but will only do so with your permission which will be separately requested. If you become an employee, then your data will no-longer be subject to this privacy policy but will be subject to certain other policies applicable to our employees. Personal information that you provide to us when applying for a career will be used for the purpose of proceeding with such application and it may be provided to third parties who may carry out recruitment, testing and other recruitment related services for us. These third parties may be based overseas. We may also create anonymous information from such information that you provide to us and used per the paragraph below described as ‘creation of anonymous data’.

You should never provide us with any ‘sensitive personal data’ through the CWF websites, products or services.

Recipients of Personal Information

CWF will take all reasonable steps to ensure that your personal information is only received by third parties that are either subject to this Privacy Policy or follow practices at least as protective as those described in this Privacy Policy and a limited number of authorized individuals within CWF whose role is essential to the CWF’s compliance with its business and legal obligations in the assessment of your enquiry with the company. Your personal information may be used by CWF authorized managers and representatives from the legal, marketing, sales, funds development, support, human resources, product functions, and IT department.

Retention and Storage of Personal Information

Collected personal information shall be stored for as long as the CWF has your consent to do so or is required to do so in accordance with all applicable data privacy laws and regulations. We will not retain your personal information for longer than is necessary for our business purposes or for legal requirements.

Security of Personal Information

CWF is required to meet all applicable regulatory compliance standards for data protection and to take appropriate organizational and technical measures to protect your personal information from:

• misuse;
• theft;
• unauthorized disclosure or access; and
• loss.

We maintain physical, electronic and procedural safeguards for the collection, storage and disclosure of personally identifiable information and CWF’s security procedures mean that we may request proof of identity before we disclose personal information to you. Wherever online portals and/or third-party service providers are used, CWF ensures that these requirements meet the same security and data protection standards.

However, due to the design of the Internet, ever-changing technology and other factors outside of our control, CWF cannot guarantee that communications between you and our servers will be free from unauthorized access by third parties or that we will not be subject to security breaches.

Transfer of Data

While CWF data is managed primarily at data centers within the U.S., some of your personal information may be stored in other locations depending on selected service providers.  Whenever CWF transfers personal information, we will ensure that the information is transferred in accordance with this Privacy Policy and as permitted by the applicable laws on data protection.

If we send your personal information overseas, the recipients are required to store and use it only in accordance with CWF’s data policies. CWF may make your personal information available to government authorities when required by law.

CWF is subject to the investigatory and enforcement powers of the United States Government.  We may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Rights

In respect of your personal information collected and held by CW, you have the right to:

• access the personal information we process on you;
• request restriction of our use;
• rectify inaccuracies in the personal information;
• deny or withdraw your consent to all or some of our use of your personal information collected by us;
• lodge a complaint with a supervisory authority;
• deletion of your personal information from our system of records. However, in such event we may not be able respond to or engage further with your inquiry with the company

CWF aims to keep its records about you as accurate as possible. If you would like to review, change or delete details you have supplied us with or wish to exercise any of your other rights, please contact us as set out below.

Cookies and Similar Technologies

When you visit CWF websites, we and our advertising partners may store and access information from your device, including “cookies”, clear GIFs (which are also sometimes called web bugs or web beacons) and browser details. We may collect information such as your browser type, the type of operating system you use, the domain name of your Internet service provider, IP address, pages visited on the site, services used and how you have used them. We and our advertising partners do this for a variety of purposes. In the case of our advertising associates, this may include the personalization of advertisements based on your visits to sites in that party’s network.

Please note there is currently no accepted standard on how to respond to Do Not Track signals and that at least some of the CWF websites do not currently respond to a web browser’s Do Not Track instructions (i.e., “signal”). The industry is currently still working toward defining exactly what Do Not Track means, what it means to comply with Do Not Track, and a common approach to responding to Do Not Track. To learn more about Do Not Track, you can do so here. Additionally, we may use Google analytics. Google analytics manages ‘Do Not Track’ instructions from your browser in accordance with its own privacy policies http://www.google.com/intl/en/policies/privacy/.

Another example of how we use cookies might be to track the effectiveness of our marketing and advertising campaigns and to show you CWF ads on other websites after you have visited our website. Please note: if you continue to use this website, or any other CWF website, we will imply from this that you consent to our use of cookies.

We may also work with third-party advertising companies that collect and use information to deliver more relevant advertising across the Internet and when you are using our products and services.

Requests for Access/Removal

The Colonial Williamsburg Foundation is the data controller for your personal information. Any questions that you have concerning this EU Privacy Policy or CWF’s collection and use of personal information should be addressed to [email protected].

CWF’s business changes constantly and our EU Privacy Policy will change also. We may e-mail periodic reminders of our notices and conditions, unless you have instructed us not to, but you should check our website frequently to see recent changes. Unless stated otherwise, our current policy applies to all information that we have about you. Please check our EU Privacy Policy on a regular basis.