Liaison International Privacy Policy

This privacy policy and agreement (the “Privacy Policy” or “Policy“) explains how, with your permission, (as set out below) Liaison International (“Liaison International“, “we” or “us“) collects, uses and treats information that we receive from you through our website (available at www.liaisonedu.com) (the “Website” or “Site“).  The terms “you” and “your” refer to any person or entity providing us with information through our Website including, but not limited to, visitors, Students, Supervisors and School Representatives.  For your convenience, Section 13 (Definitions) provides a set of defined terms used in this Privacy Policy.  This Privacy Policy does not cover information that you provide to us through other means, such as through telephone calls and traditional mailings.
1. Your Consent. Please read this Privacy Policy carefully as your consent to it creates legal obligations on you and on us. By accessing and using our Website, you acknowledge and agree to be legally bound by this Privacy Policy. In addition, for certain activities on the Site we may further confirm your consent by asking you to click an “I accept” button. If you do not agree with the terms of this Privacy Policy, please contact us in accordance with Section 14.6 (Contact Us) or refrain from using our Site.
2. Types of Information You May Provide. Information we may collect from you on our Site falls into three categories: (i) Anonymous Information; (ii) Personal Information; and (iii) Activity Information. These categories are defined as follows:
  • 2.1. Anonymous Information. The term “Anonymous Information” means information that does not identify you individually, and may include, for example, statistical information concerning the pages on our Website that you visit most frequently or the aggregation of Activity Information submitted by multiple Students.
  • 2.2. Personal Information. The term “Personal Information” means information about you that would allow us (or others) to identify and contact you including, but not limited to: (i) your name; (ii) mailing address; (iii) telephone number; (iv) financial account information; (v) email address; and (vi) other, similar information.
  • 2.3. Activity Information. The term “Activity Information” means any information you provide to us through our Site relating to clinical activities including, but not limited to: (i) your scheduled activities; (ii) clients you register; (iii) assessment instruments used; (iv) hours logged providing clinical services; (v) Supervisors and feedback provided by Supervisors; and (vi) other, similar information that you are able to provide through our Site.
3. Our Uses of Your Personal Information. You decide whether you wish to provide us with Personal Information.  We may collect information from you at different points (for example, when you complete our registration process or sign up to receive our Alerts), and use this information as follows:
  • 3.1. Account Registration; Account Types. We collect Personal Information in connection with your registration to obtain either a Student or Supervisor account on our Site, and offer a range of services associated with the different account types available.  We use Personal Information in connection with processing your registration and providing you with the products and services associated with creating an account.  Please see below for a general description of the different benefits associated with each account type.
    • 3.1.1. Student Account. Those users registering to create a Student account may be given access to a variety of services we offer through our Site, such as: (i) uploading Activity Information; (ii) importing Activity Information that you have been tracking using other programs; (iii) designating Supervisors and providing them with access to your Activity Information (linked with Personal Information) for verification; (iv) generating reports based on your Activity Information; and (v) other services that we may make available to you through our Site.
    • 3.1.2. Supervisor Account. Those users registering to create a Supervisor account may be allowed to view that Activity Information (linked with Personal Information) designated by Students in order to verify the accuracy or inaccuracy of the information.
    • 3.1.3. School Representative Account. Those users with a School Representative account may be allowed to view limited Activity Information (linked with Personal Information) of Students that register a Student account using a Coupon, and generate certain reports based on that information.
  • 3.2. Subscription Payments. We collect Personal Information, including contact and financial information, in connection with your registration of a Student account using a credit or debit card. This Information is used for billing purposes and contacting you in the event that there is an issue with your subscription. Please note that Liaison International does not directly collect or store your financial account information – instead, we use a reputable third party company (the”Payment Processing Company”) to collect and process your payment information. Rest assured, however, that we have taken steps to ensure that the Payment Processing Company protects Personal Information it collects from you in compliance with our Privacy Policy.
  • 3.3. Verifying Your Identity. When you purchase services or request information from us via the Website, we may collect additional Personal Information beyond what we originally received in order to verify your identity and process your request. This is designed to further protect you and to reduce the threat of identity theft and fraudulent requests.
  • 3.4. Communications to Us. If you send us an email with questions, comments or requests for additional information, or if you include your Personal Information when providing us with feedback about Liaison International, our Website or our products and services, we may use your email address and other information included in your correspondence to respond to you.
  • 3.5. Staying Updated; Alerts and Other Communications You may provide us with your email address and other Personal Information so that we can send you information concerning Liaison International, our Site, products, services and other information (collectively, the “Alerts”). In addition, we may use your Personal Information to provide you with other information that we believe may be of interest to you. You will have the ability to opt out of receiving these materials as provided in Section 9 (Opting Out).
  • 3.6. Informational Notices and Bulletins. We may periodically send news, bulletins and other information to you, and will use Personal Information to send such communications. If we choose to send such communications, you will have the ability to opt out of receiving some of them. Please refer to Section 9 (Opting Out) for more details.
  • 3.7. Surveys and Contests. We may periodically launch surveys or contests through our Site, and request Personal Information from you in connection with these surveys and contests. Information we collect through surveys and contests will be used in connection with the surveys and contests, and for purposes of monitoring and improving our Site as well as our products and services. In the event that we wish to use Personal Information in a manner different from what is set out in our Privacy Policy, we will notify you of the relevant details when asking you to participate in the survey or contest.
  • 3.8. Promotions. We believe that your experiences can often act as the strongest promotion of our products and services. Accordingly, we may wish to post on our Website or elsewhere, endorsements from you or testimonials you provide about your experiences with us. You agree that your Personal Information and experiences with us may be used and adapted for these purposes (without compensation). If we use your Personal Information and experiences in this manner, and such use discloses other Personal Information, we will obtain your permission before using any other Personal Information.
  • 3.9. Information You Wish to Have Posted on the Website and Alerts. We collect Personal Information from you when you provide us with Submitted Content for posting on our Website or inclusion in our Alerts. We may use this Personal Information to respond to you, verify your identity and for other purposes. Please review Section 5 (Submitted Content) for information concerning how we treat Submitted Content (and any Personal Information) you may post on our Website or include in our Alerts.
  • 3.10. Other Uses. In addition to the uses specifically identified in this Section 3 (Our Uses of Your Personal Information), we may use Personal Information you submit in any other manner we reasonably deem necessary in order to provide you with the information, products and services you request from us such as linking your Personal Information with your Activity Information so that Supervisors can review and verify its accuracy or provide feedback regarding the clinical hours that you recorded.
4. Our Uses of Your Activity Information. You decide whether to provide us with Activity Information. We collect Activity Information in connection with various services that we make available through our Site, such as our psychology hours application. Please note that Personal Information included with Activity Information will be treated as Activity Information, and not as Personal Information, and we will treat any Personal Information included or linked with Activity Information, as Activity Information. Rest assured, however, that you have some control over who is given access to your Activity Information:
  • 4.1. Provision to Supervisors. We will link certain Personal Information, such as your name and email address, to Activity Information in order to provide the same to Supervisors that you designate. Please note that Supervisors are not given access to all of your Activity Information, but only to those portions that you identify.
  • 4.2. Provision to School Representatives. We will link certain Personal Information to Activity Information in order to provide the same to those School Representatives that provided you with a Coupon that you used to pay for your Student account.
  • 4.3. Provision to Students. We will link certain Personal Information with feedback that Supervisors provide about Students regarding their Activity Information, and provide the same Students for their review.
  • 4.4. Exporting. Certain services available on our Site may allow you to export Activity Information, linked with certain Personal Information, to third parties or third party sites, such as AAPI Online. We will use your Activity Information, linked with Personal Information, in order to provide you with these services.
  • 4.5. Other Uses. In addition to the uses specifically identified in this Section 4 (Our Uses of Your Activity Information), we may use Activity Information (whether or not linked with Personal Information) you submit in any other manner we reasonably deem necessary in order to provide you with the information, products and services you request from us.
  • 4.6. Disclaimer. You acknowledge and agree that (i) we are providing your Personal Information and Activity Information to third parties pursuant to this Policy based on your request, and that we have no control over these third parties, and (ii) in the event that you have any right, claim or action against any third party receiving any combination of your Personal Information and Activity Information, then you will pursue such right, claim or action independently of, and without recourse to, us.
5. Submitted Content. You may choose to provide to us for posting publicly on our Website or elsewhere, and in certain circumstances you may post directly, information that includes Personal Information and Activity Information. Both Personal Information and Activity Information included with Submitted Content will be treated as Submitted Content, and not as Personal Information or Activity Information. We may choose (in our sole discretion) to publicly post Submitted Content on our Website. Please keep in mind that Personal Information and Activity Information posted in this manner is not subject to the provisions of this Privacy Policy. If you are posting Personal Information and Activity Information concerning an individual other than yourself, be sure that you have permission from that individual to make the posting. Please review our Terms of Use for more information on how we treat the information you wish to post on our Website and elsewhere (referred to as “Submitted Content” in our Terms of Use).
6. Disclosures to Third Parties. We will not disclose (i) Personal Information, or (ii) Activity Information linked with Personal Information (collectively, the “Relevant Information”) about you to third parties without your consent, except in the following circumstances:
  • 6.1. Vendors. We employ other companies to perform functions both on our and your behalf, such maintaining the Website, collecting information, sending and responding to electronic mail and other functions necessary to support Liaison International, the Website and the products and services that we offer (collectively, the “Vendors”). We will provide Vendors with only that Relevant Information reasonably necessary to perform their functions and instruct them not to use Relevant Information for any purpose inconsistent with this Policy. Rest assured, however, that we have taken steps to ensure that our Vendors protect Personal Information it collects from you in compliance with our Privacy Policy.
  • 6.2. Questions of Harm. We may disclose Relevant Information about you on a case-by-case basis to attorneys, private investigation organizations or law enforcement agencies if we believe that you are: (i) in risk of harm from another; (ii) harming or interfering (or will harm or interfere) with others; or (iii) violating (either intentionally or unintentionally) our Terms of Use or other legal obligations.
  • 6.3. Legal. We will provide Relevant Information about you to the extent we reasonably believe we are required to do so by law. If we receive legal process calling for the disclosure of your Relevant Information, we may attempt to notify you via the email address you provided (if any) within a reasonable time before we respond to the request, unless such notification is not permitted. In addition, we may share your Relevant Information with third parties as otherwise permitted by law in order, for example, to protect against fraud, the confidentiality or security of our business records or to comply with applicable legal requirements.
  • 6.4. Transfer of Ownership. We shall be entitled to transfer Relevant Information to a third party in connection with a sale of all or substantially all of the assets of the entity responsible for the information under this Policy, provided the acquiring third party has agreed to safeguard your Relevant Information with protections that in all material respects are the same as, or more protective than, those set out in this Privacy Policy.
7. Our Use of Anonymous Information. We use Anonymous Information to analyze the effectiveness of our Site, to improve our Website, products, services and for other purposes. For example, the fact that a majority of Students accrue clinical hours during the month of September would constitute Anonymous Information, if that information does not identify a particular user. This information provides us with potentially useful data concerning our users’ preferences and the efficacy and interest of our Site, products and services, and various general trends. In addition, we may undertake or commission statistical and other summary analyses of the general behavior and characteristics of users, and the use of our Website and related services, and may share Anonymous Information with third parties. Rest assured that Anonymous Information provided to third parties will not allow anyone to identify you. We may collect Anonymous Information through features of the software supporting our Website through both the means described below and other means.
  • 7.1. IP Addresses; Logs. Either directly, or through our hosting service provider, we may automatically receive and record information from your internet browser, including your IP address (the internet address of your PC), your computer’s name, the type and version of your web browser, referrer addresses, where the computer is routing from and other generally-accepted log information. We may also record page views (hit counts) and other general statistical and tracking information that will be aggregated with information about other users in order to understand how our Website is being used, and for security and monitoring purposes.
  • 7.2. Cookies. A cookie is a small amount of data that often includes an anonymous unique identifier that is sent to your browser from a website’s computers and stored on your computer’s hard drive. Cookies can be used to provide a tailored user experience and to make it easier to use a website upon a future visit. We may include cookies on our Website and use them to recognize you when you return to our Site. In addition, other third-party websites may recognize our cookies stored on your computer, and use that information to provide you with information related to the content of our Website. You may set your browser so that it does not accept cookies, though cookies must be enabled on your web browser if you wish to access certain personalized features of our Site.
  • 7.3. Tags. We may use “pixel tags,” – small graphic images (also know as “web beacons”, “single-pixel GIFS”, or “web bugs”) – to tell us what parts of our Website have been visited, to measure the effectiveness of searches users perform on our Site and for other purposes. Pixel tags also enable us to send email messages in a format users can read, and inform us whether emails have been opened, to help ensure that our messages are of interest to recipients. None of this data includes Personal Information, and you can opt out of receiving these types of emails from us by following the directions provided in Section 9 (Opting Out). Personal Information collected using such tools will be subject to the terms of this Privacy Policy.
  • 7.4. Click-Throughs. We may send emails that use a “click-through URL” linked to content on our Website. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We track this click-through data to help determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked simply do not click text or graphic links in the email, or notify us in accordance with Section 9 (Opting Out).
8. Any Anonymous Information Linked with Personal Information is Protected as “Personal Information.” To enable us to better understand your characteristics and/or to provide services tailored to your needs, we may link Personal Information with Anonymous Information (collectively,”Linked Information”). Linked Information will be treated and protected as Personal Information under this Privacy Policy.
9. Opting Out. Because we respect privacy rights, we allow you to opt out of receiving certain information. If we choose to send bulletins, Alerts or other communications to you, we will provide you with the ability to decline, or opt out of, receiving such communications. In addition, you have the option to unsubscribe to our Alerts, and we will take reasonable steps to comply with this request in a timely manner. Instructions for opting out will be provided if and when we determine to send such a communication. Please understand that you will not be allowed to opt out of formal notices concerning the operation of our Website, and legal and other related notices concerning your relationship to us and our Website.
10. Access; Removing Information. To allow you appropriate control over your Personal Information, you can request us to change, update or delete Personal Information that you have previously submitted to us. We will take reasonable steps to verify your identity before fulfilling such requests. You may also delete your name and other Personal Information from our databases. Please understand, however, that it may be impossible to remove Personal Information completely due to system backups and records of deletions. In addition, if you request the deletion of your Personal Information, you will be unable to utilize the services associated with that Personal Information. We will fulfill deletion requests within a reasonable time.
11. Third-Party Sites. Our Site and Alerts contain links to other sites and certain services available on our Site may allow you to export Personal Information and Activity Information to other sites. Please be aware that we are not responsible for the privacy practices or content of other sites. We encourage you to be aware when you leave our Site and to read the privacy policies of each website that collects or receives Personal Information or Activity Information. This Privacy Policy applies solely to information collected on our Site and does not apply to information collected by a site operated by a third party. Rest assured, however, that Personal Information we receive from third-party sites will be treated by us as Personal Information pursuant to this Privacy Policy, unless such information is included with Submitted Content.
12. Security. We have put in place security systems, physical and technical safeguards, and quality controls designed to prevent unauthorized access to, or disclosure of, Personal Information (collectively, the “Security Safeguards”). Our Security Safeguards are structured to deter and prevent unauthorized users and others from accessing Personal Information. Please understand that our Security Safeguards are not fail-proof and, due to the nature of internet communications and evolving technologies, we cannot provide, and expressly disclaim (to the extent permitted by law), assurance that the information we receive about you via the Website will remain free from loss, misuse or alteration by third parties who, despite our efforts, obtain unauthorized access. Please note that you play a key role in protecting the security of your Personal Information. For example, you should guard your password to our Website, and not give it to others to use. In addition, you should close your browser when have finished viewing your information on our Website in order to prevent others from viewing your Personal Information.
13. Definitions.
  • 13.1. Anonymous Information. The term “Anonymous Information” has the meaning set forth in Section 2.1 (Anonymous Information) of this Privacy Policy.
  • 13.2. Coupon. The term “Coupon” means the pre-paid Student subscription that School Representatives can purchase directly from Liaison International and provide to Students.
  • 13.3. Personal Information. The term “Personal Information” has the meaning set out in Section 2.2 (Personal Information) of this Privacy Policy.
  • 13.4. School Representative. The term “School Representative” means the educational institution that registers offline with Liaison International to become a School Representative.
  • 13.5. Student. The term “Student” means those Site users that register through our Site to become a Student.
  • 13.6. Submitted Content. The term “Submitted Content” has the meaning set out in our Terms of Use.
  • 13.7. Supervisor. The term “Supervisor” means those Site users that register through our Site to become a Supervisor.
14. Additional General Provisions.
  • 14.1. Privacy Protection for Children. Our Website is not directed at children and we will not accept or request Personal Information from individuals we know to be under 13 years old. In accordance with the Children’s Online Privacy Protection Act (“COPPA”), if we learn that a child under 13 years old has provided Personal Information, we will either (i) delete this information from our databases in accordance with our deletion procedures set out in Section 10 (Access; Removing Information), or (ii) obtain verifiable parental consent in accordance with COPPA.
  • 14.2. Changes to Our Privacy Policy. We may change our Privacy Policy from time to time. If we make any changes regarding the Privacy Policy, we will post the new Policy on our Website. Changes to the Privacy Policy will become effective upon your consent pursuant to Section 1 (Your Consent), at which point the new Privacy Policy shall govern information we collect from you.
  • 14.3. Disclaimer Notice. We make no claims, promises or guarantees about the accuracy, currency, completeness or adequacy of the content of this Website, products and services available through the Site or Submitted Content, and expressly disclaim liability for errors and omissions in the related content. No warranty of any kind, implied, express or statutory, including but not limited to warranties of non-infringement of third party rights, title, merchantability, fitness for a particular purpose and freedom from computer virus is given with respect to the Website, products and services offered through the Site, Submitted Content, embedded links to other internet resources or other communications. Although we have put in place security systems (as described in this Privacy Policy) that are designed to prevent unauthorized disclosure of your Personal Information, due to the nature of internet technologies we cannot provide assurances as to the security of this information, and expressly disclaim any such obligation.
  • 14.4. Site Privileges. You agree to refrain from all activity that imposes an unreasonable burden on the Site, and we reserve the right, in our sole discretion, to limit the access of any user violating this Privacy Policy.
  • 14.5. Choice of Law and Jurisdiction; Translations. This Privacy Policy shall be construed in accordance with the laws of the Commonwealth of Massachusetts, without regard to any conflict of law provisions. Any dispute arising under this Privacy Policy shall be resolved exclusively by the state or federal courts sitting in the judicial district that includes Boston, Massachusetts. This Privacy Policy may be translated into languages other than English (collectively, the”Translations”). Any communications sent by us to you shall be sent in English. Dispute resolution procedures arising out of either this Privacy Policy or the Translations shall be conducted in English, and the English version of this Privacy Policy shall control over the Translations.
  • 14.6. Contact Us. If you have any questions about this Privacy Policy, the practices of this Site, or your dealings with this Website, please contact us at: questions@liaisonedu.com
  • 14.7. Complete Agreement. This Privacy Policy must be read in conjunction with our Terms of Use, and the provisions of our Terms of Use are incorporated herein. To the extent the Terms of Use conflicts with the terms of this Privacy Policy, the terms of this Privacy Policy shall control.