Website Privacy Notice
The Milton Hershey School (“MHS,” “we” or “us”) respects your privacy and is committed to protecting your privacy when you visit websites owned or operated by MHS (collectively, the “Websites”). This privacy notice (“Privacy Notice”) describes:
- The types of information we may collect from you or that you may provide us.
- Our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies only to information we collect through the Websites and in email or other electronic communications sent through or in connection with the Websites. This Privacy Notice DOES NOT apply to information that:
- We collect offline or through any other means.
- You provide to or is collected by any third party, including through any application or content that may link to or be accessible from or on the Websites. These third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.
Please read this Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not access or use the Websites. By accessing or using the Websites, you accept and agree to be bound and abide by our Privacy Notice.
Changes to Privacy Notice
This Privacy Notice may change from time to time, and you are responsible for checking this Privacy Notice periodically for updates when accessing or using the Websites. The date the Privacy Notice was last revised is identified at the top of the page. If we make material changes to how we treat your personal information, we will notify you through a notice on the Websites home page. Your continued use of the Websites after we make changes to this Privacy Notice is deemed to be your acceptance of those changes.
Information We Collect and How We Collect It
We collect several types of information from and about users of our Websites, including information:
- By which you may be personally identified, such as your name, address, email address, telephone number(s), social security number, or any other identifier that can be used on its own or with other information to identify, contact or locate you (“personal information”).
- That is about you but individually does not identify you, such as marital status, employment information or geographic location.
- About your internet connection, the equipment you use to access our Websites and other usage details.
We collect this information:
- Directly from you when you provide it to us.
- Automatically when you access or use the Websites.
- From third parties, including other vendors or business partners.
Information You Provide To Us
The information we collect on or through our Website may include:
- Information that you provide by filling in forms on our Websites. This includes, but is not limited to, information you provide at the time you apply for admission or employment, at the time you register for an event, at the time you update your student or alumni information, at the time you sign up for newsletters, at the time you post or submit any materials, and/or at the time you contact us.
- Records and copies of your correspondence with us.
- Your responses to surveys or questionnaires that we might ask you to complete.
- Limited details of transactions you carry out through our third party payments system (currently Paypal), in order to process the transaction (e.g., a donation). Our third party payment processor does not share full credit card numbers or CVV information with us.
You also may provide information to be posted on public areas of the Websites, or transmitted to other users of the Websites or third parties (collectively, “User Contributions”). Your User Contributions are posted on the Websites and transmitted to others at your own risk. Although we may monitor certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Websites with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Automatic Information Collection and Tracking
- Usage Details. When you access and use the Websites, we may automatically collect certain details of your access to and use of the Websites, including location data, length of time you visit the Websites or specific pages, page views, click-stream information, referring URL, logs, location information, and other communication data and the resources that you access and use on or through the Websites.
- Device Information. We may collect information about your device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, and network information.
- Stored Information and Files. The Websites also may access metadata and other information associated with other files stored on your device.
- Behavioral Tracking/Targeting. We also may collect information about your activities over time or across third-party websites, apps, or other online services, commonly known as behavioral tracking. The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. We may use this information to provide you with interest-based (behavioral) advertising or other targeted content, such as asking you to complete an application or form you previously started.
Information Collection and Tracking Technologies
The technologies we use for automatic information collection may include:
- Cookies (or browser/mobile cookies). A cookie is a small file placed on your device. Cookies are a way to carry information from one session on a website to another, or between sessions on related websites, without having to burden a server machine with large quantities of data storage.
- Flash Cookies. Certain features of the Websites may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Websites.
- Web Beacons and Other Technologies. Pages of our Websites and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit MHS, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). The information we may obtain in this manner would, for example, enable us to customize the Websites and to measure the overall effectiveness of the Websites.
- [Facebook Pixels. We use Facebook pixel, which is an analytics tool that allows us to measure the effectiveness of our advertising by understanding the actions people take on the Websites. We use the pixel data to make sure our ads are being shown to the right people and to build advertising audiences. We have a pixel code on the header of the Websites. When someone visits the Website and takes an action (like completing a form), the Facebook pixel is triggered and reports this action. By accepting this Notice, you consent to the processing of your data by Facebook.]
- Other Retargeting/Behavioral Advertising Providers. We use these tracking technologies to collect information about you when you use the Websites. The information we collect may be associated with your personal information or we may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services. We may use this information to provide you with interest-based (behavioral) advertising or other targeted content, such as sending you an email to compete an application.
How We Use Your Information
- To present our Websites and their contents to you.
- To estimate usage patterns and customize the Websites.
- To provide you with emails and newsletters.
- To fulfill any other purpose for which you provide the information or express an interest. For example, information submitted on an employment application will be used to process your employment application and evaluate your candidacy.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
- To allow you to participate in interactive features of our Websites.
- To provide advertisements to you.
- In any other way we may describe when you provide the information, and for any other purpose with your consent.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction. In addition, we may disclose personal information that we collect or you provide:
- To our affiliates, contractors, service providers, and other third parties we use to support our operations.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of MHS’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by MHS about our users is among the assets transferred.
- To fulfill the purpose for which you provide it. For example, if you provide us an email address to receive newsletters, we will transmit emails to that email address.
- For any other purpose disclosed by us when you provide the information.
- For any other purpose, with your consent.
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply this Privacy Notice.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of MHS, our employees, students or others.
Except as provided herein, personal information collected through the Websites will not be sold or otherwise disclosed to third parties for direct marketing purposes.
Your Choices About Our Collection, Use, and Disclosure of Your Information
We strive to provide you with choices regarding the personal information you provide to us. If you do not want us to collect your information, as described in this notice, do not use the Websites. This section describes mechanisms we provide for you to control certain uses and disclosures of your information.
- Email and Solicitions. When you contact us through certain forms on the Websites, you will thereafter may be added to our email list(s) to receive email messages. For example, if you contact us about employment, we may email you to provide you with information about MHS or current employment opportunities. At any time, you can choose to no longer receive such emails by using the “unsubscribe” method found at the bottom of each email or by sending us a return email stating your request.
You may also send us an email, give us a call, or write us a letter via the contact information of this Privacy Notice to specifically request to correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you delete your User Contributions from the Websites, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Websites users.
No Collection of Information From Children
Our Websites are not intended for use by children under 13 years of age. We do not solicit or knowingly collect any information from visitors under 13 years of age, and please do not use the Websites if you are not yet 13. If we learn we have collected or received personal information from a child under 13, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us immediately through the contact information found in this Privacy Notice.
“Do Not Track” Signals
For residents of California and Delaware, California Bus. & Prof. Code § 22575 and 6 Del.C. § 1205C seek disclosure of how the Websites respond to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information about their online activities over time and across third-party websites or online services. Although it is not clear that the statute applies, we believe that an example might be a browser option allowing you to ask websites not to track you across third-party websites so that they can serve targeted or behavioral advertising to you. The Websites may collect personal information using behavioral tracking or associate personal information with other information collected using behavioral tracking. If your browser or similar mechanism gives the Websites a “do not track” signal, the Websites will not honor it because of the tracking described in “Information We Collect and How We Collect It”. You should not use the Websites if you desire a “do not track” signal, because the Websites will not honor it.
Your California Privacy Rights
Pursuant to California Civil Code § 1798.83, California residents may request the identity of any third parties to whom MHS has disclosed personal information for the third parties’ direct marketing purposes within the previous calendar year, along with the type of personal information disclosed. If you are a California resident and would like to make such a request, please submit your request in writing to MHS at the address set forth below. Please note that under California law, MHS is only required to respond to a request once during any calendar year.
Using the Websites from Outside the United States
This policy is intended to cover collection of information on or via the Websites from residents of the United States. If you are visiting the Websites from outside the United States, please be aware that the data protection laws of other countries might not be as comprehensive as those in your country. By using the Websites, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Notice.
We have implemented reasonable measures designed to secure your information from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. We urge you to be careful about giving out information in public areas of the Websites. The information you share in public areas may be viewed by any user of the Websites.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your information, we cannot guarantee the security of your information transmitted through our Websites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites.
To ask questions or to comment about this Privacy Notice or our privacy practices, please contact us. You may contact us in writing at the following address: MHS Office of General Counsel, P.O. Box 830, Hershey, PA 17033-0830. You may also contact us via email at: firstname.lastname@example.org or via phone at (717) 520-2200.
Effective: March 15, 2018