FACES Privacy Policy
FACES complies with the Trans-Atlantic Data Privacy Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.
How we use information we collect
FACES collects personal data related to the J-1 Visa Exchange Visitor Program it administers, sponsoring teachers for placements in public, private, and charter schools in South Carolina. We use the information we collect to provide, maintain, protect, and improve our website and the program we administer; to help applicants apply for and succeed in the J-1 Visa Exchange Visitor Program; and to protect FACES program applicants and participants. To help teachers obtain J-1 visas and enter the exchange visitor program, FACES collects personal information from applicants and program teachers including, but not limited to Driver’s Licenses, Passports, Visas, Criminal Background information, email addresses, school transcripts, teaching licensures, and other relevant information relating to the program. FACES only collects these types of personal information and shares it with data processors assisting in the BridgeUSA (exchange Visitor Program) it administers.
FACES does not sell your personal information to companies, organizations, and other outside individuals. FACES is obligated to share personal information with the U.S. State Department and schools as it relates to placing teachers and the administration of its program.
We collect information by
Information you give: FACES requires those seeking participation in its program to sign up for an account. When you do, we will ask for personal information like your name, email address, and telephone number to store with your account. In most instances, exchange visitor program applicants and current/past program participants (“Users”) are asked to upload the majority of their personal information directly, and they retain access to any uploaded information as they transition from applicant to participant. Users uploading information to FACES’s secure website have access to the information they uploaded for as long as the information is retained by FACES.
Information we get from your use of the FACES website: FACES may track information such as your phone number and U.S. physical home address. Examples of information we may gather from your use of FACES’s website include:
Log information: When you use FACES’s services, we may collect and store certain information in server logs with details of how you used our services, telephone log information, your IP address, device event information, and cookies.
Local Storage: We may collect and store information, including personal information, locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.
Information associated with your FACES account is treated as personal information. For more information about how you can access, manage, or delete information that is associated with your FACES Account contact a FACES staff member.
Transparency and Choice
At FACES, Users are in control of their personal information. Our goal is to clearly state what information we collect and how we use it so that you can make an informed decision prior to becoming a User. To become a participant in the BridgeUSA program that FACES administers, the U.S. State Department requires FACES to gather, review, and retain certain types of personal information. This does not mean that those wishing to participate in the program FACES administers are without choice in the collection of their personal information outside the initial decision to become a User. FACES Users have additional choice in determining the personal information they share with EPI and access to that personal information, such as:
What you upload to FACES: You often have a choice in the information which you upload to FACES. Certain documents and types of personal information are required to be considered for the exchange visitor program that FACES administers. However, in many instances, you have a choice of the information you upload to FACES from a range of documents and personal information, and Users are directly in control of the uploading of information to our secure server.
Blocking Cookies: You may also set your browser to block all cookies, including cookies associated with our services, or to indicate when a cookie is being set by us. However, it’s important to remember that many of our services may not function properly if your cookies are disabled.
Access: Users have the right to access the entirety of personal information at any time through their online profile. Users will be able to correct, amend, or delete personal information that FACES holds if they can demonstrate that such personal information is inaccurate, or has been processed in violation of the Data Privacy Framework. To the extent permitted by applicable local laws, FACES may limit or deny a User’s access to the personal information it holds where the burden or expense of providing access would be disproportionate to the risks to their privacy, the legitimate rights of other persons would be violated, or an exception applies under another applicable law. To request access to, correct, amend, or delete your personal information with FACES, please contact a FACES staff member.
Information Sharing: Your information is normally only visible to you and FACES employees. There are limited instances in which FACES shares your personal information:
With your Consent: We will share personal information with companies, organizations, data processors, and other individuals outside of FACES when we have your consent to do so.
With 3rd parties helping to administer our program: we provide limited personal information to other companies helping us manage or process your data based on our instructions and in compliance with our privacy policy and any other appropriate confidentiality and security measures.
With the U.S. State Department: FACES is designated as an exchange visitor program sponsor by the U.S. State Department and the program is governed by the United States Code of Federal Regulations. Because of this, FACES is required to retain certain personal information in accordance with U.S. State Department and Federal Regulations. Due to the nature of the program, FACES may be required to share your personal information with other U.S. Federal offices like the State Department, the Department of Homeland Security, Immigration and Customs Enforcement, and the like.
For Other Legal reasons: We will share personal information with companies, organizations, or individuals outside of FACES if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable law, regulation, legal process, or enforceable governmental request,
- Enforce applicable Terms of Service, including investigation of potential violations,
- Detect, prevent, or otherwise address fraud, security, or technical issues,
- Protect against harm to the rights, property or safety of FACES, our users or the public as required or permitted by law.
Information Security
FACES protects the information you share with us from unauthorized access, unauthorized alteration, disclosure, or destruction with use of website security measures consistent with current best practices to safeguard our website, email, and other internet connected programs:
- Encrypt our website, requiring the use of a secure browser with encryption, or SSL. Using encryption protects information by scrambling information as it is sent from your computer or device to FACES and vice versa, helping keep your information secure and private.
- Frequently patch or update our systems so that we are using the latest software versions with the most current security technology.
- Engage in system monitoring, regularly reviewing activity logs to identify potential problems. We have systems in place to automatically block and help prevent unauthorized access to your information from unknown or untrusted sources. We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
- We restrict access to personal information to FACES employees, contractors, government authorities, and agents who need to know that information to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
Despite FACES’s efforts, no data transmissions you make to FACES over the internet can be guaranteed to be 100 percent secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us. You understand that any information that you transfer to FACES over the internet is done at your own risk.
Accountability for Onward Transfers
Except as otherwise explained in this Policy, FACES will transfer your personal data to:
- an entity that a User has specifically authorized to receive the data (and its designated representatives),
- third party contractors and other third parties acting as FACES’s agents (e.g., service providers that help host or support FACES’s web site, or that otherwise provide program related assistance), or
- government agencies associated with a User's exchange visitor program.
Furthermore, FACES will transfer personal data to such third parties only if the transfer is for limited and specified purposes and the third party will provide at least the same level of privacy protection as is required by this Privacy Statement and, as applicable, the Data Privacy Network. FACES takes reasonable steps to ensure that its third-party affiliates, contractors, and agents effectively processes the personal information in a manner consistent with FACES’s obligations under the Principles.
FACES may be required to disclose personal information in response to a lawful request by public authorities, including requests to meet national security or law enforcement requirements.
Contact FACES Directly with Comments/Issues Related to Personal Data
In compliance with the Trans-Atlantic Privacy Framework, FACES commits to resolve complaints about our collection or use of your personal information. Trans-Atlantic individuals with inquiries or complaints regarding our Privacy Framework policy should first contact FACES Executive Director at rpalyok@facesinc.org, by addressing your physical mail to FACES, 5 Calendar Court, Suire 101, Columbia, South Carolina USA, or by calling 1-803-782-3902.