SWAHILI CULTURAL INSTITUTE, INC.

PRIVACY POLICY

 

Effective Date: February 5, 2021

The Swahili Cultural Institute, Inc. (the “Institute”, “we”, “us” or “our”) respects your (“you”, “your”, user” or “users”) privacy and we are committed to protecting your online privacy by protecting you and keeping your information secure.

This privacy policy (the “Privacy Policy”) describes how your personal information is collected, used, and shared when you access and use our website (the “Site”). By visiting this Site, or providing your information to us, you are accepting the terms of this Privacy Policy and of our Terms of Use (the “Terms of Use”). This Privacy Policy is incorporated into the Terms of Use by this reference. Used terms not otherwise defined in this Privacy Policy will have the definitions ascribed to them in the Terms of Use.

INFORMATION WE COLLECT

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device.

The information we collect from you through our Site is voluntarily availed by you to us when you: register for an account; enroll for classes; complete an online survey and make a donation. When you make a payment or donation, or attempt to make a payment or donation through the Site, we also collect certain information from you, including, without limitation, your name, billing address, shipping address, payment information (such as credit or debit card information or information required by other payment methods), email address, and phone number.

Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically collected information as “Device Information.”

We collect Device Information using the following technologies:

“Cookies”, which are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

“Log files” which are track actions occurring on the Site, and which collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

“Web beacons,” “tags,” and “pixels” which are electronic files used to record information about how you browse the Site.

When we talk about “Personal Information” or “Information” in this Privacy Policy, we are talking both about Device Information and other information we collect from you, including payment information.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the Information that we collect generally to facilitate your access to our services on the Site, which include, without limitation, Swahili and other language classes, Swahili and other African language news and resources, and scheduled events. Additionally, we use this Information to:

• Communicate with you;
• To respond to your requests or questions;
• Process your payments and provide you with invoices;
• Share information with third-parties who perform services on our behalf such as vendors who help us manage our online registration process or payment processes; and
• Comply with the law.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our users browse and interact with the Site, and to assess the success of our outreach campaigns).

SHARING YOUR PERSONAL INFORMATION

We share your Personal Information with third parties to help us use your Personal Information, as described above.  We also use Google Analytics to help us understand how our users use the Site-. You can read more about how Google uses your Personal Information here:  https://www.google.com/intl/en/policies/privacy/.  You can also opt-out of Google Analytics here:  https://tools.google.com/dlpage/gaoptout.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

DO NOT TRACK

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

JURISDICTION-SPECIFIC RULES

Users in California

Users who are California residents have certain rights under the California Consumer Privacy Act, (“CCPA”). If you are an eligible California user, included in these rights are:

“Right to Know” — You have the right to request to know more about the categories and specific pieces of personal information that we have collected about you and access a copy of your personal information.

“Right to Deletion” — You have the right to request deletion of personal information that we have collected about you.

“Right to Non-Discrimination” — If you choose to exercise any of your rights under the CCPA, the Institute will treat you like all other users. In other words, there is no penalty for exercising your rights under CCPA.

“Right to Opt-Out” – You have the right to opt out of any sale of your personal information.

CCPA has a specific definition of a “sale” and while we do not, in the traditional sense, sell your personal information or the personal information of any of our users, we do use cookies that make non-personally identifiable information available to select third parties. To opt out of such a “sale,” click on the “Do Not Sell My Personal Information” link at the bottom of this page.

To exercise any of these rights under CCPA, please email [email protected] or write to us at:

Swahili Cultural Institute, Inc.

C/o Thomson Ollunga LLP

104 East 25th Street, 10th Floor

New York, NY 10010, USA.

Users in Nevada

Nevada residents have the right to submit a request that we do not sell your covered personal information, which you can do by emailing [email protected] or writing to us at:

Swahili Cultural Institute, Inc.

C/o Thomson Ollunga LLP

104 East 25th Street,10th Floor

New York, NY 10010, USA

Users Outside of the U.S.

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make a payment or donation through the Site), or otherwise to pursue our legitimate organizational interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

DATA RETENTION

When you make a payment or donation through the Site, we will maintain your Information for our records unless and until you ask us to delete this information.

MINORS

The Site is not intended for individuals under the age of 18. Children under the age of 18 may not set up an account but may have a parent or guardian open an account and help them enroll in appropriate courses. Individuals younger than the required age for consent to use online services may not use the Services. If we learn that we have collected personal data from a child under those ages, we will take reasonable steps to delete it.

Parents who believe that we may have collected personal data from a child under 13  can submit a request for removal at [email protected].

THIRD-PARTY SITES

Our website uses external links of or to other third-party websites, applications, and services (“Linked Sites”) that are not owned, operated or controlled by the Institute. These may include third party payment processor sites or applications. All such links are provided solely as a convenience to you and neither we nor any of our respective affiliates are responsible for any content, materials or other information located on or accessible from any other website or app. Links to Linked Sites do not constitute approval, sponsorship or an endorsement by association with us of such websites or the content, products, advertising or other materials presented on such Linked Sites thereof.

We make no warranties or representations about the accuracy, completeness, or timeliness of any content posted on the Site or by anyone other than us. We disclaim all responsibility for any viruses or malicious code that may appear on any Linked Sites, any damage or loss caused or alleged to be cause by or in connection with the use of or reliance on any content, goods or services available on any Linked Site.

If you are directed to any Linked Site or otherwise rely on any Linked Site, you do so at your own risk and assume all resulting responsibilities and consequences and are subject to the Terms and Conditions, Privacy Policy and all other policies applicable to such Linked Site.

CHANGES

We may update this Privacy Policy at any time, and from time to time, in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

CONTACT US

For more information about our Privacy Policy and practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at or by mail using the details provided below:

Swahili Cultural Institute, Inc.

C/o Thomson Ollunga LLP,

104 East 25th Street,10th Floor,

New York, NY 10010, USA

Email: [email protected]