ACCENT PRIVACY POLICY

This Privacy Policy seeks to inform you about privacy practices of Accent International Consortium for Academic Programs Abroad d/b/a Accent Global Learning (hereinafter “Accent”) and choices you can make with respect to your personal information. When you visit or use services on www.accentglobal.com, we collect data to facilitate your study abroad experience.

By using this site, you consent to Accent’s collection, use, and sharing of information about you, described below. Please review this policy. If there is any part you do not agree with, or if you do not think this policy provides enough protection, you should exit this site and not stay or visit it. If there is information you do not wish to consent to our receipt, collection or use of, you should not visit, use or remain at this site.

    1. Commitment to Comply with the Data Privacy Framework Program: Accent complies with the EU-U.S. Data Privacy Framework and the UK Extension thereto (hereinafter the “DPF Frameworks”), as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and/or the United Kingdom to the United States. Accent has certified to the Department of Commerce that it adheres to DPF Frameworks Principles. If there is any conflict between the terms in this privacy policy and the DPF Frameworks Principles, the DPF Frameworks Principles shall govern. For more information concerning the Data Privacy Framework Program, visit https://www.dataprivacyframework.gov/.
    2. Independent Recourse Mechanism for Complaints relating to the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF: In compliance with the DPF Frameworks Principles, Accent commits to resolve complaints about our collection or use of your personal information. EU/UK individuals with inquiries or complaints regarding our DPF Frameworks policy should first contact Accent at: (341) 333-0544 (info@accentglobal.com) Accent has further committed to refer unresolved complaints to JAMS Data Privacy Framework Dispute Resolution Program, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.
    3. Information Collection, Storage and Sharing:  We are the sole owner of information collected on this site. We have access to and collect information you voluntarily give us by email or other contact from you. This includes information such as your name, address, email address, username, password, and any other information about you that you provide. Our system may automatically store information related to your use of this site. We collect any information you enter on our site, or that your device provides to our site, or that you give us any other way. Regardless of the information you send us, the only data we will knowingly maintain through this site is the following:
      • Name (first and last)
      • Birthdate
      • Address
      • Phone Number
      • Email Address
      • Family Member Names
      • Financial Information
      • Passport Information
      We cannot rule out that our system may automatically maintain other information, such as metadata.
    4. Purposes of Processing and Data Sharing Under the EU-U.S. Data Privacy Framework and the UK Extension: Accent processes personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. Data Privacy Framework and the UK Extension to the EU-U.S. Data Privacy Framework for legitimate and limited purposes related to the operation of its international education and study-abroad programs, including:
      • administration and delivery of academic programs, travel, housing, and student support services;
      • enrollment management, academic advising, program communications, and health and safety coordination;
      • human resources administration, payroll, benefits, and contractor management;
      • financial administration, billing, accounting, tax compliance, audit, and internal controls;
      • information technology, security, data hosting, and operational support; and
      • compliance with applicable legal, regulatory, and institutional obligations.
    5. Types of Personal Data Processed: The personal data we process may include information relating to students and program participants, applicants, employees, contractors, faculty, and institutional partners. Depending on the context, such data may include contact details, identification information, academic and enrollment records, travel and housing details, financial and payment information, employment and compensation data, and exchanges of communication.
    6. Type of Third Parties to Which Accent Discloses Personal Information: Accent does not sell or give away any personal information about you to an unrelated company, organization, or individual without your permission, except that if our company were to merge or be sold, the other party would acquire the information. Accent discloses personal information only as necessary to operate and administer its international education and study-abroad programs and related business functions. As such, personal information submitted through Accent’s websites, email communications, or program systems may be used to identify individuals, administer and support study-abroad programs, communicate regarding logistics or emergencies, and fulfill Accent’s contractual and legal obligations. Depending on the context, Accent may share personal information with the following categories of recipients:
      • Accent’s affiliates operating in the United States, the United Kingdom, the European Union, and other jurisdictions;
      • airlines, travel providers, apartment owners, and student housing providers in connection with travel, housing, and program logistics;
      • partner colleges, universities, and academic institutions for academic administration, enrollment, health and safety, and compliance purposes;
      • service providers acting on Accent’s behalf, including information-technology and cloud-hosting providers, web-management vendors, payroll and benefits providers, accounting and audit firms, consulting providers, and customer-support platforms; and
      • government authorities, embassies, or regulators where disclosure is required by law or necessary to meet legal, regulatory, or public-safety obligations.
      All third-party service providers receiving personal information are required to process such data solely on Accent’s instructions and in accordance with applicable data-protection requirements.
    7. Right to Access Your Personal Information: You have the right to access your personal data and you can control the accuracy of the information you provide us. We encourage you to review information for accuracy before you send it to us. Please contact us by email or U.S. Mail to: 1) See what data we have about you, if any; and/or 2) Change/correct any data we have about you. If you believe we may have incorrect information and you want us to correct it, or if you want us to take other action, you can ask us to delete or correct information or stop using information you provided, by emailing a request to us at info@accentglobal.com or sending a letter with your request to Accent Global Learning, 2560 Ninth Street, Suite 315A, Berkeley CA 94710.
    8. Your Choices for Limiting the Use and Disclosure of Your Personal Information: You have the right to access your personal data and you can contact Accent to limit the use and disclosure of your personal data. You may opt out of future contacts with us at any time. Please contact us by email or U.S. Mail to: 1) Tell us any concern you have about our use of data about you; 2) Ask us to stop processing data about you; and/or 3) Ask us to remove data about you in part or in whole. If you want to limit the use and disclosure of your personal information please send your request by emailing us at info@accentglobal.com or sending a letter with your request to Accent Global Learning, 2560 Ninth Street, Suite 315A, Berkeley CA 94710.
    9. Accent is Subject to Regulation by the Federal Trade Commission: Accent is subject to the investigatory and enforcement powers of the United States Federal Trade Commission (FTC).
    10. Your Right to Invoke Binding Arbitration: If you have a complaint and Accent is not able to resolve it, you may invoke binding arbitration by the International Centre for Dispute Resolution (ICDR) of the American Arbitration Association (AAA). Accent is willing to enter into binding arbitration with written notice provided that all pre-arbitration requirements are met.
    11. Accent’s Duty to Disclose Your Personal Information in Response to Legal Process: Accent is required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Accent may disclose personal information if in good faith, Accent believes disclosure is necessary or advisable (for example, without limitation, to protect rights or property of Accent, or to identify, contact, or bring legal action against someone who may be causing interference with our rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by such activities). We may cooperate in providing personal information to law enforcement representatives if asked voluntarily to do so.
    12. Accent’s Liability for Onward Transfer of Your Personal Information to Third Parties: Accent uses third-party service providers to provide travel related services. If Accent becomes aware that a service provider can no longer meet its obligation to meet the principles of the European Union General Data Protection Regulation (“EU GDPR”) and/or the United Kingdom General Data Protection Regulation (“UK GDPR”), Accent will take steps to stop or remediate unauthorized processing. In onward transfers of data, received pursuant to the DPF Frameworks, Accent is potentially liable for actions of an agent taken on Accent’s behalf. Accent is also liable for unauthorized onward transfers to third parties.
    13. Application of Accent’s Privacy Policy: Accent’s Privacy Policy covers all data collected via the on-line registration for Accent’s study abroad programs and applies only to information collected by this site or Accent. Accent’s Privacy Policy may change. Updates will be publicly available on this page. If you feel we are not abiding by this privacy policy, you should contact us immediately by phone at 341.333.0544 or by email at info@accentglobal.com.
    14. Contact Us: You can contact us with inquiries, questions, comments, suggestions or concerns in relation to our Privacy Policy at info@accentglobal.com or sending a letter with your request to Accent Global Learning, 2560 Ninth Street, Suite 315A, Berkeley CA 94710.