Introduction

The New England Innovation Academy (the “School,” “NEIA,” “We,” “Us,” or “Our”) is a coeducational day and boarding school for students in grade six through grade twelve. The School’s future-focused curriculum is shaped to connect students’ passion to purpose and to mold the next generation of young innovators to learn and grow. To fulfill our mission and foster our institutional growth, we collect, use and share information from and about potential students and their families, students and their families, alumni and their families, potential employees, friends and visitors, including individuals who visit or use our websites, portals, applications and other resources.

The School is committed to protecting the confidentiality, integrity, and security of your personal information. We take this responsibility seriously. This Privacy Policy is intended to help you understand how we collect and safeguard your information. This Privacy Policy may change from time to time (see “Changes to Our Privacy Policy,” below). Your continued use of this website after we make changes is deemed acceptance of any changes, so please check the policy periodically for updates.

I. What Does This Privacy Policy Cover?

This Privacy Policy covers our treatment of personal identifiable information, as defined by numerous statutes in the United States; personal information, as defined by the Massachusetts Standards for the Safeguard of Personal Information, the federal Children’s Online Privacy Protection Act (“COPPA”); and, personal data, as defined by the European Union General Data Protection Regulation (the “GDPR”), (collectively “Personal Information”) which we gather in a variety of ways, as explained more thoroughly below. This policy does not apply to the practices of companies and organizations that we do not own or control, or to individuals whom we do not employ or manage.

II. What Information Does NEIA Collect?

NEIA does not collect Personal Information indiscriminately. We limit the types and amounts of Personal Information we collect to what is necessary to fulfill our mission of educating our students and providing for the long-term well-being of the School. With that in mind, we collect the following types of information:

A. Information You Provide to Us

We may collect Personal Information from you when you:

Communicate with us: You can communicate with NEIA through our websites or by email, mail, phone, text, chat, or any other paper or electronic form. When you communicate with us, we may collect your name, your contact information (including phone number, email address, work and/or home address), the content of any communication, and the metadata associated with any communication.

Apply for a child to be enrolled as a student: When you submit an application for a child to enroll at NEIA, the application information may include or you may choose to provide (about you and/or your child) name, contact information (including phone number, email address, work and/or home address), date of birth, demographic information (like gender, age, household income, nationality, and race and/or ethnicity), Social Security number, immigration status and documentation, religious affiliation, schooling and education information, testing results, biographical information, family information, personal interests, sexual orientation, health and/or medical information, disability information, teacher evaluations, recommendations, parental interview notes, child screening, financial information, financial aid information, employment information and/or history, information from interviews, a user name or email address in combination with a password or security question that would permit access to a NEIA account you may establish, and any other information you provide to us.

Register for or attend a NEIA event: When you register for a NEIA event, we may collect your name, your contact information (including phone number, email address, work and/or home address), work information, a user name or email address in combination with a password or security question that would permit access to a NEIA account you may establish, and any other information you provide to us.

Apply for employment: When you submit an application for employment, you may choose to provide or we may collect your name, contact information (including phone number, email address, work and/or home address), date of birth, demographic information (like gender, age, household income, nationality, and race and/or ethnicity), immigration status and documentation, schooling and education information, disability information, recommendations, employment information and/or history, information from interviews, a user name or email address in combination with a password or security question that would permit access to a NEIA account you may establish, and any other information you provide to us.

Donate money to NEIA: When you donate money to NEIA, we may collect your name, contact information (including phone number, email address, work and/or home address), information about a person in whose name you donate, and any other information you provide to us, which may include a credit card number or financial institution information, depending on how you make your donation.

Appear in NEIA recordings: Through your attendance at NEIA events, your image, voice, and/or likeness may be recorded for later use by the School or as part of School livestreaming broadcasts.

You can choose not to provide us with certain information listed above, although that may affect NEIA’s ability to accept a child as a student, to employ you, to communicate with you, to accept your donation, or to invite you to NEIA events.

B. Information Provided By and About Students

NEIA collects, and you may provide, Personal Information regarding students when they enroll at the School and study here. The students provide some of this Personal Information themselves. Other individuals, including faculty, staff, parents, guardians, and family, produce some of this Personal Information. The information includes: name; contact information; date of birth; demographic information (like gender identity, age, nationality, and race and/or ethnicity); immigration status and documentation; family information; biographical information; personal interests; pictures, videos, and voice recordings of students, including livestreaming; disability information; student records information, including, but not limited to, health, academic, testing, athletic, disciplinary, and residential life records and information; information that comes from student-generated materials, including, but not limited to, emails, tests, homework, projects, and in-class assignments; and user name or email address in combination with a password or security question that would permit access to a NEIA account. As the parent or guardian of a student, you can instruct the School not to collect or use some or all of the information listed above, but that may affect NEIA’s ability to educate the student or the student’s ability to participate in the School’s programs or to learn the skills necessary to advance at the School, which could ultimately result in NEIA’s removing the child from the School. It may also prevent or limit the student from participating in NEIA activities. The School retains the right to take other appropriate action if limitations on the collection and use of a student’s Personal Information impair our ability to educate the student to our standards.

C. Information Collected Automatically

When you interact with any NEIA website or mobile application, certain information may be passively collected (that is, gathered without your actively providing the information) using various technologies and means, such as Internet Protocol (IP) addresses and cookies. These are described in more detail below:

IP Addresses. NEIA’s websites use IP addresses. An IP address is a number assigned to your computer by your internet service provider to access the internet. In most consumer cases, an IP address is dynamic (changing each time you connect to the internet), and not static (unique to a particular user’s computer).

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to make websites work, or work more efficiently, and to provide information to the owners of the site. Most web browsers allow some control of cookies through browser settings. We may collect the following information via cookies: aggregate statistical information, information related to your use of our websites (including your password, the links you click on, your movement around the sites, the pages you visit, the number of times you open a page, and which information is consulted), your IP address, and your browser type. You may be able to change the preferences on your browser or mobile device to send “do not track” signals or to prevent or limit your computer or device’s acceptance of cookies, but this may change the functionality of NEIA’s websites. If you click on a link to a third-party website, such third party may also transmit cookies to you. This Privacy Policy does not cover the use of cookies by any third parties.

Google Analytics is a third-party tool used by the School, to gain visibility into site usage, web traffic, user behavior, and other user interests in order to optimize our website for our users. Google Analytics collects only the IP addresses assigned to you on the date that you visit the website, rather than your name or other identifying information. We do not combine information collected through the use of Google Analytics with Personal Information. Although Google Analytics uses cookies to identify unique users, the next time you visit this website, the cookie cannot be used by anyone but Google. You can prevent Google Analytics from recognizing you on return visits to this website by disabling cookies on your browser.

D. Email Confirmation

When we communicate with you via email, we may receive a confirmation when you open an email from us. This confirmation helps us make emails more interesting and improve our efforts to communicate with you about NEIA. If you do not want to receive emails or other communications from us, please indicate your preference by clicking on the unsubscribe link in any of our emails or by contacting us at:

Attn: Information Security Coordinator
New England Innovation Academy
280 Locke Dr.
Marlborough, Massachusetts 01752

(508) 205-4270

helpdesk@neiacademy.org

Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of NEIA websites, mobile applications, and other resources, and you are responsible for reviewing such legal notices for changes.

E. Special Categories of Personal Information

Consistent with Sections II A and B above, NEIA may collect the following Personal Information, which may fall within a special category of Personal Information under the GDPR: race and/or ethnicity information as part of the demographic information you provide us; religious affiliation; sexual orientation; health and/or medical information; and disability information. Except as stated otherwise in the previous sentence or elsewhere in this Privacy Policy, we do not knowingly collect special categories of Personal Information, including: (1) Personal Information revealing racial or ethnic origin, political opinion, religious or philosophical beliefs, or trade union membership; and (2) genetic data, biometric data, data concerning health, and data concerning a natural person’s sex life or sexual orientation.

III. What Does NEIA Do With Personal Information?

NEIA collects and uses Personal Information:

• To communicate with you and respond to your inquiries;
• To operate, maintain, develop, and grow the School;
• To operate, develop, maintain, and improve NEIA’s websites, tours, facilities, student recruitment, application review, development department, communications, and other departments, systems, and functions;
• To evaluate potential students for admission, including by contacting relevant parties who are identified as knowing or having a relationship with a student;
• To educate students and help them grow;
• To develop NEIA’s alumni network;
• To administer your NEIA account and improve your experience interacting with NEIA;
• To evaluate potential employees, including by contacting relevant parties who are identified as knowing or having a relationship with a potential employee;
• To prepare and manage events, register you for events as relevant, and notify you of other events that may be of interest to you;
• To solicit and process donations;
• To research trends and developments that are relevant to the operation and growth of the School;
• To investigate and resolve disputes and security issues; and
• For any other lawful, legitimate business purpose.

We may also share certain Personal Information with third parties (as described in this Section and in Section IV below).

IV. Will NEIA Share Any of the Personal Information it Collects?

For the purposes referred to in this Privacy Policy and relying on the bases for processing as set out below, we may share your Personal Information with certain third parties. In some cases, you will be asked to opt in to these data sharing arrangements. In those cases, you should carefully consider the possible impact that not opting in will have on the provision of our core teaching, learning, and residential school services to you. The School has not sold and will not sell your Personal Information for monetary or other considerations.

Please note that this Privacy Policy does not apply to the practices of any third parties that we do not own or control, or to individuals whom we do not employ or manage.

A. Third Parties

The School may share Personal Information with third parties that perform services on our behalf. Third-party recipients may include:

• Our affiliates and contractors where there is a legitimate reason for their receiving the information, including:
  • Third parties that work with us to provide student support services (i.e. counseling, health services, etc.);
  • Third parties that are contracted to provide services such as dining, IT, and staffing;
  • Organizations operating software on our behalf; and
  • Internal and external auditors.
• Any educational programs in which you may participate;
• Governmental departments and agencies where we have a legal obligation to provide information;
• Crime prevention or detection agencies;
• Parents, guardians, and next-of-kin (where there is a legitimate reason for disclosure);
• Third parties conducting surveys;
• Third-party communication providers; and
• Third-party data services providers.

B. Legal Obligations, Our Protection, and the Protection of Others

We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with the law or a court order; to enforce or apply our conditions of use and other agreements; or to protect the rights, property, or safety of NEIA, our employees, our students, or others. This includes exchanging information with other individuals, organizations, and companies for fraud protection and credit risk reduction.

C. With Your Consent

Except as set forth above, we will obtain your consent before disclosing your Personal Information with third parties, and you will be able to prevent the sharing of this information.

V. NEIA’s Legal Basis for Collecting and Using Personal Information

NEIA collects and uses your Personal Information and the Personal Information of your child pursuant to your informed consent, which you have granted by (a) confirming the prompts produced by NEIA’s websites and/or any portals, applications or other resources; and (b) continuing to use NEIA’s websites, portals, applications, and other resources consistent with this Privacy Policy. Please note that without your consent to collect and use your Personal Information or the Personal Information of your child, you may not be able to participate in NEIA events, donate money to the School, enroll your child at the School, or communicate with us. Similarly, without your consent to collect and use the Personal Information of a student, that student may not be able to participate in NEIA events, participate in learning activities at the School, or remain as a student at NEIA. If you have any questions concerning the terms of this Privacy Policy and the conditions of your consent, please contact us at:

Attn: Information Security Coordinator
New England Innovation Academy
280 Locke Dr.
Marlborough, Massachusetts 01772

(508) 205-4270

helpdesk@neiacademy.org

To the extent that you provide NEIA with the Personal Information of other people, you warrant and represent that each such person who is required under the Privacy Laws to give consent, or the person who is required to give consent, if the Privacy Laws require the consent of another person, has granted his or her consent to your sharing his or her Personal Information with NEIA for the use described in this Privacy Policy.

For Individuals and Personal Information Subject to the GDPR: In addition to relying on informed consent, NEIA reserves the right to process your Personal Information and the Personal Information of other people that you properly and legally provide to us: (1) in order to pursue our legitimate business interests in operating the School, educating our students, and developing the School’s resources; and/or (2) in order to perform a contract to which you are a party, such as the enrollment contract between you and NEIA. Where the processing is based on a contractual requirement, your failure to provide the relevant Personal Information may result in NEIA’s terminating the contract, NEIA’s requesting that the student leave the School, or another action by the School. Any one or more of these bases is the legal basis for NEIA’s collection and use of Personal Information, depending on the relationship between you, NEIA, and (as relevant) any people whose Personal Information you properly and legally provide to us.

VI. How Long Will NEIA Retain Personal Information?

We will retain your Personal Information for as long as needed to meet the uses described in this Privacy Policy and in compliance with legal document retention obligations. Even where you have exercised one of the rights listed below with respect to your Personal Information, we will have the right to retain your Personal Information for compliance with a legal obligation, for the performance of a task carried out in the public interest, for archiving purposes in the public interest, for scientific or historical research purposes, for statistical purposes, or for the establishment, exercise, or defense of legal claims.

VII. What Are Your Rights to Control Your Personal Information?

Except where permitted or required by law (including, but not limited to, compliance with a legal obligation, to further a public interest, and establishing and/or exercising a legal claim or defense), you have the rights described below regarding NEIA’s collection and use of your Personal Information and the Personal Information of your child. Please note that in the event that a student requests to enforce any of the rights below and the School determines that such enforcement would interfere with the enrollment contract governing that student’s status at NEIA (including interfering with the efficacy of NEIA’s program for that student), we will contact the parents or guardians of that student before acting on the student’s request and reserve the right not to act in order to preserve that contract.

A. Requests to NEIA

You may request: (1) the correction, updating, deletion, or restriction of collection and use of your Personal Information or the Personal Information of your child; (2) the categories of Personal Information NEIA has collected; (3) the categories of sources from which NEIA has collected your Personal Information or the Personal Information of your child; (4) the business purpose(s) for collecting and disclosing your Personal Information or the Personal Information of your child; (5) an account of how NEIA has used or is using your Personal Information or the Personal Information of your child; (6) a copy of your Personal Information or the Personal Information of your child retained by NEIA, to be delivered in a structured, commonly used and machine readable format to review or to transfer or transmit to another entity without hindrance, to the extent that that is technically feasible; (7) the categories of third parties with which NEIA shares your Personal Information or the Personal Information of your child; (8) the categories of Personal Information which we have shared with third parties, and the contact information for such affiliates and/or third parties; (9) a list of all third parties that have received your Personal Information or the Personal Information of your child from NEIA; and (10) the specific pieces of Personal Information NEIA has collected about you or your child. We will respond to all such requests in up to 30 days, subject to lawful extension of that period, and there may be a delay in processing a request while we verify that the request is valid and originates from you as opposed to an unauthorized third party. If you request that your Personal Information or the Personal Information of your child be deleted or that NEIA otherwise limit its use of that Personal Information, we reserve the right to review how such a request will affect our ability to educate your child consistent with NEIA’s high standards. Such a review may result in a decision that the child should not remain a student at NEIA. If we do not have your Personal Information or the Personal Information of your child, have not collected that Personal Information, or have not disclosed or transferred that Personal Information to another party, we will inform you in response to a request regarding your Personal Information or the Personal Information of your child. Any of the above requests may be made by contacting us at:

Attn: Information Security Coordinator
New England Innovation Academy
280 Locke Dr.
Marlborough, Massachusetts 01752

(508) 205-4270

helpdesk@neiacademy.org

When you update information, we may maintain a copy of the unrevised information in our records. Please note that some information may remain in our private records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.

B. Withdrawal of Consent

You may withdraw your consent at any time by contacting us at:

Attn: Information Security Coordinator
New England Innovation Academy
280 Locke Dr.
Marlborough, Massachusetts 01752

(508) 205-4270

helpdesk@neiacademy.org

Please be aware that such withdrawal does not affect the lawfulness of NEIA’s use of your Personal Information before such withdrawal. Withdrawal of consent may affect: (1) your ability to participate in NEIA events, donate money to the School, enroll your child at the School, or communicate with us; and (2) your child’s ability to participate in NEIA events, participate in learning activities at the School, or remain as a student at NEIA.

C. Object or Challenge

You may object, on grounds relating to your particular situation, at any time to the collection and use of your Personal Information or the Personal Information of your child based on NEIA’s legitimate interests or based on public interest, or otherwise challenge our compliance with the Privacy Laws, by contacting us at:

Attn: Information Security Coordinator
New England Innovation Academy
280 Locke Dr.
Marlborough, Massachusetts 01752

(508) 205-4270

helpdesk@neiacademy.org

NEIA shall respond in up to 30 days, subject to lawful extension of that period. Where such objection is received from an individual whose Personal Information NEIA collects and uses as the processor for a controller (as those terms are defined in the GDPR), NEIA shall inform the controller of the objection within at least 30 days, subject to lawful extension of that period.

D. Non-Discrimination

NEIA will not discriminate against you because you have exercised any of the rights above or any other rights you retain pursuant to Privacy Laws.

VIII. Is Personal Information About Me Secure?

We use appropriate technical, administrative, and physical safeguards to protect against loss, unauthorized access, destruction, misuse, modification, and improper disclosure of the Personal Information we collect, in both physical and electronic format. We endeavor to protect the privacy of the Personal Information that we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of information at any time.

At times, your access to NEIA resources is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser.

Our websites, portals, applications, and other resources may contain links to other sites. We are not responsible for the privacy policies and/or practices on other sites. When following a link to another site you should read that site’s privacy policy.

IX. Children’s Privacy

Protecting children’s privacy is important to us. For that reason, no part of our website is targeted to attract anyone under the age of 13. We do not request, or knowingly collect, any personally identifiable information from children under the age of 13. Minors from ages 13 to 15 may use the website(s) only under the supervision of a parent or guardian who agrees to be bound by the website’s Terms of Use. While we may collect information of children under the age of 13 when they are prospective students, we do not solicit this information from the child directly – we will seek parental consent for any Personal Information provided for children under the age of 16. We also will not disclose or share the information of a user under the age of 16 with any third parties. The School also complies with the Children’s Online Privacy Protection Act (COPPA). If you are the parent or guardian of a child under 13 who has provided his or her information to us that you have not authorized, please contact us at:

Attn: Information Security Coordinator
New England Innovation Academy
280 Locke Dr.

Marlborough, Massachusetts 01752

(508) 205-4270
helpdesk@neiacademy.org

For GDPR purposes, the Privacy Notice is not directed to “children,” as defined per Member State implementation legislation. Where a prospective or current student is classified as a child, we will make reasonable efforts to verify that consent is given or authorized by the holder of parental responsibility over the child, where Personal Information of the child is to be processed.

X. Failure to Provide Personal Information

You can always opt not to disclose information to us, but certain information is needed to enroll a child at NEIA, for a child to study with us, for NEIA to consider an employment application, for NEIA to accept a donation, for you to attend a NEIA event, and for other activities and benefits described in this Privacy Policy.

XI. Changes to Our Privacy Policy

The School reserves the right, at our sole discretion to change, modify, add, remove, or otherwise revise portions of our policies and this Privacy Policy at any time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we use Personal Information, we will notify you by posting an announcement on our website or sending you an email. You are bound by any changes to the Privacy Policy when you use NEIA’s websites, portals, applications, or any other NEIA resources after such changes have been first posted.

XII. Use of Text and Images

All NEIA trademarks, service marks, and trade names are proprietary. All copyrighted materials, including audio, text, photographs, videos, and graphics, are protected by law and cannot be used unless expressly authorized by this Privacy Policy and with prior written permission from the School.

If you would like to publish information that you find on our website, please email us your request. Where text or images are posted on our site with the permission of the original copyright holder, a copyright statement appears.

XIII. Translations

This Privacy Policy was originally published in English; however, it may be translated upon request. The content of the English original shall prevail in case of differences in the content or context of other language versions.

Effective May 12, 2022