Privacy Statement

VšĮ “American Councils for International Education: ACTR/ACCELS“ (hereinafter “American Councils Lithuania” or “we”) takes your privacy seriously. We respect and value the privacy of everyone who visits this website (www.belarus.americancouncils.org) (“Our Site”). We will only collect and use your personal data in ways that are described herein, and in a way that is consistent with our obligations and your rights under applicable privacy and data protection regulations.

The Privacy Statement is to inform you about the processing of your personal data and your rights regarding the processing in accordance with the General Data Protection Regulation (“GDPR”).

This Privacy Statement only applies to the processing activities American Councils Lithuania carries out as a data controller. If you have any comments or questions about this Privacy Statement or the collection and use of your personal data, please contact our Data Protection Officer at privacy@americancouncils.org.

How Do We Collect Personal Data?

We collect personal data from you in one or more of the following ways:

• When you visit our site or any other American Councils site

• When you deliver to us program application or other documents in paper form or by email or other electronic means

• When you register to use AIS Forms or any other application platform

• When you use other forms on the AIS Forms websites

• When you complete the “contact us” form on Our Site

• When you agree to receiving our email subscriptions

• When you apply for a job with us

What Personal Data Do We Collect?

Depending upon your use of Our Sites and/or services, we may collect some or all the following personal data from you:

• Full name (first/given, middle/patronymic, and last/family name)

• Gender

• Home and mailing addresses

• Email addresses

• Telephone numbers

• Social media IDs

• Date of Birth

• Birthplace

• Countries of citizenship and legal residency

• Marital Status

• Race or Ethnicity

• Religious or philosophical beliefs

• Smoking status

• Educational history

• Work and volunteer history

• Military history

• Resume/CV

• Medical history and insurance information

• Disability or accommodations information

• Dietary restrictions

• Financial records

• Credit card and bank account information

• Criminal background history

• Confirmation of identity

• National identification documents and numbers

• Passport information

• Personal statement

• Photos and videos

• Language skills and testing results

• International exchange programs history

• History of participation in American Councils and U.S. Government programs

• Personal travel history

• IP address

• Computer operating system

• Web browser type

• A list of URLs starting with a referring site, your activity on Our Sites and the site you exit to

• Other personally identifiable information that you choose to provide to us.

We may also request the following personal data about your parents/legal guardians, emergency contacts, recommenders, and colleagues:

• Full name (first/given, middle/patronymic, and last/family name)

• Gender

• Home and mailing addresses

• Email addresses

• Telephone numbers

• Social Media IDs

• Educational history

• Work history

• Resume/CV

• Marital status

• Guardianship rights

• Financial records

• Other personally identifiable information that you or they choose to provide to us

How Do We Use Your Personal Data?

It is our practice not to ask you for personal data unless we need it or intend to use it for a pre-defined and legitimate purpose. Under the GDPR, we must always have a lawful basis for using personal data. This may be because:

• The data is necessary for our performance of a contract with you; or

• You have consented to our use of your personal data; or

• It is in our legitimate business interests to process your personal data; or

• We have a legal obligation to process your personal data Your personal data may be used for one or more of the following purposes:

• Performing analytics and understanding your preferences when you visit our site

• Responding to your requests when you complete the “contact us” form

• Processing your application

• Administering your program

• Contacting you about post-program activities

• Generating aggregated and anonymised statistical reports that may be shared with program funders

• Handling of job applications

What Personal Data Do We Share and with Whom?

We may share your personal data with various American Councils’ offices, affiliated organizations, and third-party business partners. Our third-party business partners may include program funders, service providers, and others located in the United States of America and throughout the world that work with us to process your application or request and to deliver our program and other services to you. All third-party business partners that we share your personal data with are expected to comply with applicable regulations and privacy requirements. We strive to ensure that such third parties will only share this information with other organizations or individuals that are working with them to deliver American Councils’-related program and other services.

How Long Do We Keep Personal Data?

We will not keep your personal data for any longer than is necessary in accordance with the reasons for which it was first collected.

When the personal data is no longer needed for its original processing goal, and there are no further legal requirements, we will delete your personal data.

For the student records, we have the following retention terms:

• If you apply with us for a student program, we keep your applicant data for six months. We delete your applicant data one year after application deadline.

• If you become a successful applicant and participate in a student program, we keep your participant records for six months after the completion of the program. We delete your participant records one year after the completion of the program.

What Are Your Rights and How Can You Access Your Personal Data

Under the GDPR you have the following rights:

1. The right to be informed about our collection and use of your personal data. This Privacy Statement should tell you everything you need to know, but you can always contact us to find out more or ask any questions using the contact details found at the end of this Privacy Statement.

2. The right to access the personal data we hold about you. You will be informed how to do this in this Privacy Statement.

3. The right to have your personal data corrected if any of your personal data held by us is inaccurate or incomplete. Please contact us using the contact details found at the end of this Privacy Statement.

4. The right to be forgotten, which is, the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the contact details found at the end of this Privacy Statement.

5. The right to restrict, or prevent, the processing of your personal data.

6. The right to object to us using your personal data for a particular purpose or purposes.

7. The right to data portability. This means that you can ask us for a copy of that personal data to re-use with another service or business in applicable cases.

8. The right to not be subjected to automated decision-making and profiling. This means that if we use automated decision-making or profiling, and this has legal consequences for you, you have the right to have your data reviewed by a natural person.

9. The right to lodge a complaint with the relevant Data Protection Authority. You have the right to submit a complaint to the Hungarian National Authority for Data Protection and Freedom of Information when you are not satisfied with our response to your request or you feel that we have not treated you in accordance with relevant rights under the GDPR.

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (“where such personal data is held”). This is known as a “data subject access request”.

All subject access requests should be made in writing and sent to the email address shown below. Please note that we may ask you to verify your identity before responding to such requests. We will respond to your request within 30 days of receiving such request.

There is normally no charge for a subject access request. If your request is “manifestly unfounded or excessive” (for example, if you make repetitive requests) a fee many be charged to cover our administrative costs in responding.

Exercising Your Rights or Submitting a Complaint to American Councils Lithuania

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the contact details provided at the end of this Privacy Statement.

Further information about your rights can also be obtained from the Lithuanian State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija). If you have any cause for complaint about our use of your personal data, please contact us directly.

How and Where Is Your Personal Data Stored

We may store and transfer some or all your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU Member States, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the EEA. This means that we will take additional steps to ensure that your personal data is treated just as safely and securely as it would be within the EEA under the GDPR.

We share your data within the American Councils group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. When we transfer personal data outside the EEA, we make use of Standard Contractual Clauses.

Unsubscribing from Our Email Lists and Database

When you consent, we may also use your personal data for marketing purposes, which may include contacting you by email. We may also use your personal data for marketing purposes when you complete and submit a form found on our site. You will not be sent any unlawful marketing or spam communications. You can always unsubscribe from these communications.

We may use Third-Party Service providers, such as social and/or analytical platforms, to perform certain services on behalf of us or Our Site or services. We may also use your personal data that has been collected by those Third-Party Service providers. Those vendors may have additional or different privacy policies and/or Terms of Service. You should be sure that you read and agree to those policies and Terms.

Cookies

Our website makes use of Cookies.

Cookies are small text files that are stored on your terminal device. To find out more about how we use cookies please see our Cookie Declaration. [TBU]

Amendments to this Privacy Statement

American Councils Lithuania reserves the right to modify this Privacy Statement at any time by posting changes on our website. We encourage you to review it periodically.

How to Contact Us

If you have any questions about our Privacy Statement, if you wish to exercise your rights or if you wish to lodge a complaint, please contact us:

American Councils Lithuania
Pilies g. 16-9 Vilnius,
LT- 01119 Lithuania
privacy@americancouncils.org

Last updated: September 2023