Privacy Policy

This Privacy Policy describes the types of personal information BW Academies Inc. ("Wingrove," "we," "us," or "our") may collect from or about you. The policy also describes our practices for collecting, using, maintaining, protecting, and disclosing collected information:

• when you access and use Websites owned and operated by Wingrove ("Websites");
• in email, text, and other electronic messages between you and our Websites;
• when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Policy;
• when you submit information to us or otherwise contact us;
• when you fill out surveys, or enter into contests or other promotions;
• when you apply for admission to Wingrove;
• in connection with your current or prior enrollment at Wingrove;
• when you make a donation online, over the phone, or by mailing a check to our postal address; and
• from third parties and publicly available sources.

This Privacy Policy does not apply to Personal Information collected from current or prospective employees, staff or faculty. Our privacy practices may vary depending on where you live. Please refer to the applicable privacy addendum for your jurisdiction that is attached to this Privacy Policy.

Please read this Privacy Policy carefully. By accessing or using our Websites or services or otherwise providing us with your information, you agree to this Privacy Policy.

How We Collect and Use Personal Information

Wingrove collects and processes information that identifies, relates to, or could reasonably be linked with you ("Personal Information") in a variety of contexts. Personal Information does not include information that is anonymized or otherwise no longer tied to an identifiable person. We collect several different categories of Personal Information, including information you provide to us directly, information collected automatically, and information from third-party sources.

The ways we collect and use your information vary depending on the relationship between you and Wingrove, and on the Wingrove function with which you interact. We have categorized these relationships as follows:

• Website Visitors
• Prospective Students
• Students
• Alumni
• Donors (Current and Prospective)

Generally, we collect the following categories of Personal Information about you depending on your relationship with Wingrove:

• Identifiers (e.g., name, mailing address, email address, telephone number(s), preferred contact method, date of birth, online or unique identifier, emergency contact details)
• Internet or other Electronic Network Activity (e.g., IP address, browser type, device details, location information, information collected through cookies and other tracking technologies, clickstream data, information about the equipment you use to access our Websites, and information on your (i) use of computers, other devices, and other information technology systems and assets, and (ii) interaction with a website or application that occurs on our networks)
• Financial Account Information (e.g., bank account number or credit or debit card information provided in connection with an order or donation made on our websites)
• Government-Issued Identification Numbers (e.g., Social Security number, driver's license, state ID card, tax ID, or Visa/passport numbers)
• Demographic Information (e.g., your date of birth, age range, country of citizenship, citizenship status, gender identity, pronouns, and household information such as your spouse/partner's name and names of your children if relevant to the programs)
• Education History (e.g., your prior schools, academic records such as grades, awards, transcripts; school activities, disciplinary records, and testing history, which may include standardized testing scores)
• Employment History (e.g., employer name, job title, location/work address, and work experience)
• Personal Interest (e.g., interest, extracurricular activities)
• Financial Aid Information (e.g., wages, household income, scholarships and grants, and family support; family member occupations, wages, and savings)
• Health or Medical Information (e.g., doctor's records, surgical records, immunization records, vaccinations and medications; information related to physical or mental disabilities)
• Audio, Visual, or Other Electronic Information (e.g., a photograph of you, video surveillance or camera footage of our premises)
• Alumni Information (e.g., graduation year, event attendance, volunteer interests, organization affiliations, committee participation, awards and honors)
• Payment Information (e.g., credit and/or debit card details and bank account for ACH)
• Donation Information (e.g., information regarding your donations, including dates, amounts, and methods of donating, recurring gift preferences, event registration details and ticket purchases, auction bids or purchases, and your contribution history to Wingrove or our affiliates)
• Engagement and Interest Information (e.g., volunteer interests and availability, committee or board service history, communications preferences, which includes newsletters, fundraising appeals, and event invites, and areas of program interest)
• Consent Records (e.g., opt-ins for email/text, waivers, and release forms for photography)

Depending on your relationship with Wingrove, we may use your Personal Information for:

• Conducting our operations and administering our educational offerings;
• Maintaining relationships with Wingrove alumni and friends of Wingrove, providing services to alumni and friends of Wingrove, raising funds to support Wingrove's mission and programs, and in communicating information regarding Wingrove's programs and operations;
• Administering fellowships, grants and other programs in support of individual study and research projects;
• Contacting you to respond to your requests or inquiries;
• Processing and completing your transactions including course registration, order confirmation, enrollment in academic groups or other programs, processing payments for online purchases and course registration, and delivering products or services;
• Providing you with newsletters, articles, service alerts or announcements, event invitations, and other information that you request from us or that we believe may be of interest to you;
• Conducting research, surveys and similar inquiries to help us understand trends and needs of our applicants, students, and others;
• Performing internal testing, research, and analysis to develop, improve, or demonstrate our services;
• Performing marketing, promotions, and advertising, either directly or through third parties, including through interest-based and targeted advertising;
• Alerting you about a safety or security announcement;
• Preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or unauthorized access to or use of Personal Information, our Websites, or data systems;
• Complying with our legal, regulatory, and contractual obligations, including responding to subpoenas, court orders, or other legal process; enforcing our agreements; and protecting the health, safety, rights or property of you, us, or others; and
• For any other purpose with your consent or as otherwise permitted by law.

How We Share and Disclose Personal Information

We may share your Personal Information with the following parties:

• Affiliates. We may share your Personal Information with affiliated legal entities with other BW academic units and our affiliates for purposes and uses that are consistent with this Privacy Policy.
• Service providers. We may disclose your Personal Information with our business partners and other third-party service providers who complete transactions or perform services on our behalf or for your benefit, such as:
  • Payment and donation processing;
  • Customer relationship management (CRM) services;
  • Marketing and analytics;
  • Printing and mailing;
  • Advertising or social networking;
  • Processing employment and admissions applications;
  • Alumni and donor outreach and engagement;
  • Event registration and coordination;
  • Providing course platforms or tools that enable or enhance our offerings;
  • Course registration and coordination, as well as evaluations and assessments;
  • Enrollment verification;
  • Research insights and analytics;
  • Educational operations and collaborations;
  • Recruiting and admissions;
  • Performing human resources administration;
  • Assisting with our legal compliance; and
  • System maintenance and security.
• Other academic institutions. We may share your Personal Information with other institutions for the purposes of administering programs and services, including but not limited to:
  • Cross-registration for courses with other BW institutions;
  • Course registration and administration;
  • Course evaluations and assessments;
  • Online education offerings through online platforms;
  • Research arrangements with other institutions or partners; and
  • Events and activities of Wingrove-affiliated clubs and special interest groups.
• Cooperatives and other charitable organizations. From time to time, Wingrove may exchange or share Personal Information, including name and contact information, with cooperatives of charities or other registered non-profits. This allows Wingrove to better utilize its resources to reach new donors and audiences in a more cost-effective manner.
• Volunteers. We may share Personal Information such as contact information with volunteers for the purpose of facilitating or coordinating activities, fundraising opportunities, or events.
• Business transfers. We reserve the right to transfer to relevant third parties any Personal Information we have about you in the event of a potential or actual sale or transfer of all or a portion of our organization or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution, or liquidation).
• Legal process, safety, and rights enforcement. We may disclose your Personal Information to legal or government regulatory authorities as required by applicable law. We may also disclose your Personal Information to third parties as required by applicable law in connection with claims, disputes or litigation, when otherwise required by applicable law, or if we determine its disclosure is necessary to protect the health and safety of you or us, or to enforce our legal rights or contractual commitments that you have made.
• Social media platforms and social networks. We may display targeted advertising to you through social media platforms, such as Facebook, Instagram, or other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our Websites' visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.
• Third-party advertising, audience/traffic measurement services. We use third-party advertising, analytics, and measurement partners ("Advertising, Marketing, and Analytics Partners") to serve you advertisements on our Websites as well as across other sites and services. We also partner with these companies to assist us with our marketing efforts. These third parties may set their own cookies or similar web technologies on the Websites and elsewhere online to collect information about users' online activities over time and across different websites. In some cases, the use of these third-party solutions involves the sharing of your information for purposes of serving you targeted advertising (as defined below). These partners may use cookies and other tracking technologies to collect information about your activities across different websites and services to build a profile of your interests and provide you with relevant advertising ("targeted advertising"). This is typically done based on uniquely identifying your browser and internet device.

We may share personal information for other reasons we may describe to you from time to time or as permitted or required by law.

Your Choices and Rights Regarding Your Personal Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with control over your Personal Information.

• Browser Controls for Cookies: Most web browsers allow some control of most cookies through the browser settings. For more information about how to reject, disable or delete cookies, please review your browser's help menu or visit www.aboutcookies.org. If you choose to reject cookies, you may not be able to take advantage of certain features, services, applications or tools available through our Websites or other online services that are only available through the use of these technologies. We use Google Analytics to better understand how our users interact with our websites and we may use Google Analytics Advertising Features for advertising and marketing purposes. You can learn about Google Analytics' currently available opt-outs at https://tools.google.com/dlpage/gaoptout/ and manage the information collected through Google Analytics Advertising Features through the settings on the relevant browser or device being used.
• Opt-Out of Receiving Promotional Emails from Wingrove: If you do not wish to have your email address used by Wingrove to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us. This opt-out does not apply to information provided to Wingrove as a result of a product purchase, your use of our services, or other transaction.

If you reside in the European Economic Area or the U.K., please see the corresponding privacy addendum attached to this Privacy Policy.

Third-Party Sources of Information

We may obtain certain Personal Information about you from third-party sources (as noted in How We Collect and Use Personal Information above). Third-party sources include:

• Partners and Service Providers. We use partners and service providers, such as payment processors and analytics providers, to perform services on our behalf. Some of these partners have access to Personal Information about you that we may not otherwise have (for example, if you sign up directly with that provider) and may share some or all this information with us. We use this information to administer the services and conduct marketing and advertising campaigns, and to process transactions that you request.
• Single Sign-On. Some of our online services or research activities may allow you to register and login to those services through a third-party platform. When you login to our service through a third-party platform, you allow us to access and collect any Personal Information from your third-party platform account permitted under the settings and privacy statement of that platform.
• Supplemental Information. We may receive additional Personal Information from third-party sources, such as credit reference agencies and public databases, which we may append to existing Personal Information, such as email address verification. We may use this supplemental information to process transactions that you request and to prevent fraud, deliver relevant offers and advertising to you, and to improve our operations, services, and our advertising and marketing campaigns.

Third-Party Sites and Services

Our Websites may contain links to third party websites or services that are not owned or controlled by us. We are not responsible for the privacy practices of such websites or services. The privacy practices of these third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties.

Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. 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 Website or in your operating system.

Do Not Track

Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they "do not track" your online activities. Since there is no uniformly accepted standard for how a website or online service should respond to this signal, at this time we do not take any action in response to such a signal.

Children

Our Websites are not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Websites. We do not knowingly collect Personal Information from children under 16. If you are under 16, do not register on the Websites, make any purchases through the Websites, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 16, please contact us at the contact information below.

Changes to Our Privacy Policy

We may change this Privacy Policy at any time. If we make material changes to how we treat our users' Personal Information, we will notify you by email to the email address specified in your account, through a notice on the Websites' home pages, or using a similar method. The date this Privacy Policy was last revised is identified at the top of the page. Your continued use of our Websites or services, or submission of information to us, after we make changes is deemed acceptance of those changes, so please check this Privacy Policy periodically for updates.

Contact Us

If you have questions about Wingrove's privacy practices or want to opt-out of certain uses of your Personal Information, please contact:

info@wingroveacademy.org

European Economic Area and United Kingdom (GDPR) Addendum

Effective August 2025

Introduction

This GDPR Privacy Addendum (the “GDPR Privacy Addendum”) supplements the information contained in our Privacy Policy (our “Privacy Policy”) and applies solely to the (i) visitors of our Websites, (ii) our prospective and current students, and (iii) donors and alumni of Wingrove Academy ("Wingrove") who are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”).

We adopt this GDPR Privacy Addendum to comply with the European Union’s General Data Protection Regulation, and any laws implementing the foregoing by the UK (including the UK Data Protection Act and the UK GDPR) or any member states of the EEA (collectively, the “GDPR”). Unless otherwise defined in this GDPR Privacy Addendum, any terms defined in the GDPR or our Privacy Policy have the same meaning when used in this GDPR Privacy Addendum. When this GDPR Privacy Addendum is applicable to you, it takes precedence over anything contradictory in our Privacy Policy.

Data Controller and Representative

Wingrove is the controller of your Personal Information.

Information We Collect About You and How We Collect It

The Personal Information we collect and the ways in which we collect it is described above in our Privacy Policy.

Lawful Basis for Processing Your Information

The processing of your Personal Information is lawful only if it is permitted under the GDPR. We have a lawful basis for each of our processing activities as set forth in our Privacy Policy (except when an exception applies as described below):

• Consent. By using our Websites, you consent to our collection, use, and sharing of your Personal Information as described in our Privacy Policy. If you do not consent to the terms of the Privacy Policy, please do not use the Websites. We may also ask for your consent to process your Personal Information in certain circumstances, such as to: (i) send you marketing, promotional, and similar materials about Wingrove and our events and offers via email, or (ii) deploy cookies (not deemed to be strictly necessary) and/or related technologies onto your browser or device when you visit our Websites.
• To Fulfill Our Obligations to You under our Contract. We process your Personal Information in order to fulfill our obligations to you pursuant to our contract with you to deliver our goods and services to you.
• Compliance with Legal Obligations. To meet our regulatory and legal obligations, we may need to process some of your Personal Information.
• Legitimate Interests. We will process your Personal Information as necessary for our legitimate interests. Our legitimate interests are balanced against your rights and freedoms and we do not process your Personal Information if your rights and freedoms outweigh our legitimate interests. We process your Personal Information only so far as is necessary to achieve the purpose outlined in our Privacy Policy. Our processing activities will not unreasonably intrude on your privacy and ultimately benefits you in optimizing our provision of Websites and services to you. Specifically, we rely on several legitimate interests for processing your Personal Information, such as:
  • Facilitating communications between Wingrove and you;
  • Providing, improving, and customizing our educational offerings;
  • Administering our operations;
  • Promoting the success of our current and former students;
  • Furthering research and understanding in fields of academic study;
  • Maintaining an ongoing relationship with alumni, donors and prospective donors, and helping to connect them with others;
  • Requesting gifts or donations;
  • Offering attendance to events and opportunities to volunteer;
  • Conducting admissions research;
  • Understanding how our online platforms are being used;
  • Exploring ways to develop and grow our operations;
  • Ensuring the safety and security of our students, faculty, fellows, employees and others;
  • Safeguarding our IT infrastructure;
  • Enhancing protection against fraud, spam, harassment, intellectual property infringement, crime and security risks; and
  • Meeting our obligations and enforcing our legal rights.

Special Categories of Personal Information

Some Personal Information processed by Wingrove may be considered sensitive, including Health or Medical Information. Wingrove processes this information only for the purposes described above in the How We Collect and Use Personal Information section of our Privacy Policy.

Specifically, we process this information only with your explicit consent or as otherwise permitted by the GDPR, including when our processing of such sensitive Personal Information:

• is carried out in the course of our legitimate activities with appropriate safeguards;
• relates to such Personal Information that you have manifestly made public; or
• is necessary for the establishment, exercise, or defense of legal claims or whenever courts are acting in their judicial capacity.

Automated Decision-Making

Wingrove does not use your Personal Information with any automated decision-making process, including profiling, which may produce a legal effect concerning you or similarly significantly affect you.

How We Use and Disclose Information

With the exception of cookies and similar technologies described below, we use your Personal Information as described in our Privacy Policy and do not share or otherwise disclose your Personal Information for purposes other than to the entities and for the purposes described in our Privacy Policy.

Use of Cookies and Similar Technologies

Except for those cookies that are strictly necessary for the operation of our Websites, we will only use cookies if we have your explicit consent to use them in the UK and the EEA. Please bear in mind that if you have given your consent to a cookie, you may withdraw your consent at any time utilizing the cookie setting of the applicable website.

Your Rights

Applicable data protection laws may provide you with additional rights with regards to our processing of your Personal Information:

• Access and Update or Corrections. You can review and change your Personal Information we have about you by notifying us through the Contact Information below of any required changes or errors to ensure that it is complete, accurate, and as current as possible. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
• Restrictions. You have the right to restrict our processing of your Personal Information under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Information is determined to be unlawful, or if we no longer need your Personal Information for processing but we have retained it as permitted by law.
• Portability. You have the right to request that we provide you a copy of, or access to, all or part of such Personal Information in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Information to another controller, when technically feasible.
• Withdrawal of Consent. To the extent that our processing of your Personal Information is based on your consent, you may withdraw your consent at any time by contacting us through any of the methods listed under Contact Information below. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Information.
• Right to Erasure or Right to be Forgotten. You have the right to request that we delete all of your Personal Information. We will only delete your Personal Information when we no longer have a lawful basis for processing your Personal Information or after a final determination that your Personal Information was unlawfully processed. We may not accommodate a request to erase your Personal Information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Information as set forth in this policy. In addition, we cannot completely delete your Personal Information as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies.
• Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. If you are located in the United Kingdom, you must lodge such a complaint with the Information Commissioner’s Office in the United Kingdom. You can also contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
• How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods listed under Contact Information below. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Information, you may be charged a fee subject to a maximum set by applicable law.

Data Retention Periods

We will retain your Personal Information for as long as is necessary for the purposes set out in this GDPR Privacy Addendum unless a longer period is required under applicable law, or as needed to resolve disputes or protect our legal rights or otherwise to comply with legal obligations.

Where we are processing Personal Information based on our legitimate interests, we generally will retain the data for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of the data subjects.

Where we are processing Personal Information based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship.

Where we are processing Personal Information based on your consent, we generally will retain the information for the period of time necessary to carry out the processing activities to which you consented, subject to your right, under certain circumstances, to have certain of your Personal Information erased.

International Data Transfers

If you are a resident of the EEA or UK, in order to provide our Websites and services to you, we may send and store your Personal Information outside of the EEA or the UK, including to the United States. Accordingly, your Personal Information may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Information. Your information may be processed and stored in the United States, and United States federal, state, and local governments, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your information through the laws of the United States. By using our Websites or other services, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Information outside the country where you reside or are located, including in the United States.

Changes to this GDPR Privacy Addendum

Wingrove reserves the right to amend this GDPR Privacy Addendum at our discretion and at any time, as further described in our Privacy Policy. When we make changes to this GDPR Privacy Addendum, we will post the updated notice on the Websites and update the addendum’s effective date. If we make material changes to how we treat our users’ Personal Information, we will notify you by email to the email address specified in your account, through a notice on the Websites’ home pages, or using a similar method. Your continued use of our Websites or services, or submission of information to us, following the posting of changes constitutes your acceptance of such changes.

Contact Information

To contact Wingrove Academy (Controller): info@wingroveacademy.org