Privacy Policy for www.gbhem.org

General Board of Higher Education and Ministry Privacy Policy

Introduction.  The General Board of Higher Education and Ministry, and its affiliates and subsidiaries, (collectively “GBHEM”, “Company”, “us”, “our”, or “we”) has created this privacy policy in order to demonstrate our firm commitment to your privacy.

This privacy policy will inform you of our information gathering and dissemination practices when you visit our websites, applications, or interact with us through other means, such as in person, by telephone, or through our partners or third-party providers. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.

Changes to this Privacy Policy. The terms of this policy may change, so please check it from time to time. This version was last updated on January 11, 2023. We keep our privacy policy under regular review, and we will place any updates on this web page.

The privacy policy below is intended for individuals not located in the European Union (“EU”) or European Economic Area (“EEA”).  If you are an EU data subject, please refer to our EU Privacy Policy for any additional rights and disclosures you may have.

WHO WE ARE

As an expression of Christ’s love for the world, aligned with the Wesleyan theological value of uniting knowledge and vital piety, and committed to re-imagining the historic relationship between the church and academy, GBHEM is called to bring people together to discern, learn, and lead for the church and the academy.

INFORMATION COLLECTION

We collect several types of information from and about you, including:

  • Information provided by you, such as name, address, email address, telephone number, Social Security number, date of birth and/or age, ethnicity, grades, church name, employment information, feedback, and other personally identifying information. For example, we collect information from you when you create a user account, sign up for email  communications and/or products or services; complete an application for a GBHEM administered program through a third-party website; or participate in GBHEM surveys or research.
  • Information collected automatically as you navigate through our websites. Information collected automatically may include usage details, domain address, IP addresses, internet browser, operating system, your internet connection, browser type, date and time of your visit to our website, geographical area, referring URL, the equipment you use to access our website, and other information collected through cookies (see Cookie Policy).
  • Payment information, such as credit card number, credit card expiration date, cardholder name, card security code of credit card, bank name, routing number, account number, and account holder.
  • Information provided by third parties, such as affiliated United Methodist agencies, annual conferences, or foundations.
  • Information from publicly available resources, such as Annual Conference websites, social media websites, and institutional websites.

SOCIAL SECURITY NUMBER PROTECTION POLICY

Social Security numbers are classified as confidential information under our policies. As such, Social Security numbers may only be accessed by and disclosed to our employees and others with a legitimate business purpose in accordance with applicable laws and regulations. Social Security numbers, whether in paper or electronic form, are subject to physical, electronic, and procedural safeguards. These restrictions apply to all Social Security numbers collected or retained by us.

INFORMATION USE

We use information that we collect about you or that you provide to us:

  • to provide you with information, goods or services that you request from us;
  • to make decisions regarding scholarships, course credits, programs, and credentials for which you are applying through GBHEM;
  • to provide on your behalf, and at your request, credentials and other documents required by educational institutions, annual conferences, government agencies, professional associations, employers, and other entities, related to programs administered by GBHEM;
  • to compile annual by-name reports required by the Department of Defense for military chaplains, and for annual conferences as required by the Book of Discipline for clergy endorsed to extension ministries;
  • to provide you with notices about educational services and to improve the provision of services to students (your information helps us to more effectively respond to your requests and support needs and how we may do better in proving our products and services);
  • to notify you about changes to our website or any products or services we offer or provide though it;
  • to provide marketing, such as emailing you about products or services that we believe you may be interested;
  • to invite you to participate in research/surveys about products or services you have utilized, or to learn more about your needs and preferences for products or services;
  • to administer contests, promotions, surveys, or features of our products or services;
  • to allow you to participate in interactive features on our website and to personalize your experience (your information helps us to better respond to your individual needs);
  • to enable communications to you regarding our organization and services such as email, newsletters, and scholarships;
  • to fulfill any other purpose for which you provide it and in any other way we may describe when you provide the information; and
  • for any other purpose with your consent.

DISCLOSURE OF YOUR INFORMATION

We may disclose information that we collect about you or that you provide us directly as described in this privacy policy:

  • within our internal family of companies and to affiliated organizations, including United Methodist partners and organizations; as required to fulfill the requirements of the Book of Discipline or to further the service you have requested;
  • to contractors, service providers, and other third parties we use to support our business, such as educational institutions and professional associations we work with to assist us in providing our services or administering programs;
  • to fulfill the purpose for which you provide it. For example, to process a donation payment, or payment for service or product;
  • for any other purpose disclosed by us when you provide the information; and
  • with your consent.

We may also disclose your personal information:

  • to comply with any court order, law, or legal process, including to respond to any government, regulatory, or law enforcement request;
  • in connection with, or during negotiations of, any merger, sale of Company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company; or
  • if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others.

We may disclose aggregated information about our users and deidentified data or information that does not identify an individual.

COOKIE POLICY

GBHEM uses first- and third-party cookies to help us provide information to you more effectively. We receive your opt-in consent when utilizing cookies. A cookie is a unit of data stored on the user’s hard drive that helps us remember you and your preferences.

You can accept or refuse to use cookies by making changes in your browser or confirming whether you want to opt-in to cookies by using our cookie banner on our website. Please note, however, that if you delete, turn off, or refuse cookies, you may not have access to some of the features that make your experience on our sites and apps smoother, you may not be able to store your preferences, and some of our services may not function properly.

SECURITY

We have implemented reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Our security safeguards include encrypting data at rest, using secure internet protocols, and establishing login credentials, where allowed, to grant access to certain information and data.

LINKS

Our websites may contain third-party links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.

CHILDREN UNDER THE AGE OF 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information to or on this Website or through any of its features. If We learn We have collected or received personal information from a child under 13 without verification of parental consent, We will delete that information. If you believe We might have any information from or about a child under 13, please contact us in one of the ways provided in the Contact Information section, below.

FOR CALIFORNIA RESIDENTS

If you are a California resident under the age of 18 and a registered user of our sites or apps, you may request and obtain the removal of content or information you have publicly posted. Your request should include a detailed description of the specific content or information to be removed. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

To make these requests, please contact us through any of the methods listed in the “Contacting Us” section below.

DO NOT TRACK

Our websites are not configured to read or respond to “do not track” settings or signals in your browser headings.

CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page.

CONTACTING US

If there are any questions regarding this privacy policy you may contact us via email at data@gbhem.org or via mail at the following address:

General Board of Higher Education and Ministry

Attn: Privacy

PO Box 340007

Nashville, TN 37203

EU Privacy Policy

Introduction. GBHEM has created this privacy policy specifically for individuals located in the EU, to provide additional information into your rights under EU law. This EU policy supplements our general policy.

The Data We Collect

GBHEM may collect, use, store and/or transfer different kinds of data (including personal data) about you which we have grouped together follows:

  • Identity Data includes first name and last name, gender, date of birth, ethnicity, Social Security number, military rank and involvement and country you are located in.
  • Contact Data includes address, email address, telephone and other contact numbers.
  • Financial Data includes credit card number, credit card expiration date, card security code of credit card, cardholder name, bank name, routing number, account number and account holder.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased and/or used from us, including your relationship to the United Methodist Church.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
  • Technical Data: Information collected automatically as you navigate through our websites. Information collected automatically may include usage details, domain address, IP addresses, internet browser, operating system, your internet connection, the equipment you use to access our website, and information collected through cookies.
  • Research or Survey Data: includes information you voluntarily provide via surveys or research.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect Special Categories of Personal Data about you unless there is a clear reason for doing so, i.e., if you share information about your religious affiliation or relationship with the United Methodist Church when you are applying for a scholarship, using our products or services, participating in research, or endorsement. We will only collect and store special categories of personal data with your consent.

Children Under 16

GBHEM does not collect personal data on individuals under 16 without parental consent. If we become aware that a child under 16 has provided us with personal data, we will take steps to require that consent is given or authorized by the holder of parental responsibility over the child. If you become aware that a child under the age of 16 has provided us with Personal Information without parental consent, please contact us in one of the ways provided in the Contact Details section, below.

How We Collect Your Personal Data

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity Data, Contact Data, Financial Data, Transaction Data and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • Register an account with us;
  • Request our products or services;
  • Sign up to receive our newsletter or other publications;
  • Purchase our products or services;
  • Participate in any of our research or surveys; or
  • Visit our website.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from analytics providers, such as Google based outside the EU;
  • Identity Data and Contact Data from providers of services as set out in the “Service Providers” section below;
  • Identity Data and Contact Data from publicly availably sources;
  • Identity and Contact Data from conferences, directories and foundations;
  • Identity Data and Contact Data from third-party social networks such as Facebook and LinkedIn;
  • Technical Data from other third-party organizational websites;
  • Information from publicly available websites.

How We Use Your Personal Data

We are the sole owner of the information collected on this site. We will not sell, swap or rent this information.

The legal basis that we rely on for processing your data will depend upon the circumstances in which it is being collected and used, but will in most cases fall into one of the following categories:

  • where you have provided your consent to allow us to use your data in a certain way;
  • where the processing is necessary to carry out for the performance of a contract with you;
  • where the processing is necessary for us to comply with a legal obligation; or
  • where it is in our legitimate interests to perform our functions, for example, sending you administrative communications where our legitimate interest is to provide services to you.

From time to time, we may request information from you via surveys. Participation in these surveys is completely voluntary, and you may choose whether or not to disclose your information. Information requested may include contact information and demographic information. The information that we collect through surveys will be used for the purposes of monitoring or improving the use and satisfaction of our products and services or for learning more about your needs and preferences for new products and services.

When you make a purchase from our online store, we will collect certain information from you including your name, address, phone number, email address, marketing preferences and payment details, so that we can process your product shipment or contact you if we have any queries regarding your transaction.

GBHEM uses Internet Protocol addresses to analyze trends, administer our websites, track user movement, and gather broad demographic information for aggregate use. Internet Protocol addresses are not linked to personally identifiable information.

Marketing Communications

Depending on your relationship and communications with us, we may use your personal data in order to send you marketing and fundraising communications in connection marketing activities and services:

You decide how you want us to contact you, whether by mail, email or by phone and you can update your communication preferences at any time by contacting us at the Contact Details below.

How We Share Your Personal Data

Within the GBHEM Network

We may share your information within GBHEM’s family of companies, including affiliates and subsidiaries, to help us provide our services or conduct processing on our behalf.

Service Providers

GBHEM may share your information with certain outside vendors and service providers.

Outside vendors are used in collecting and storing information we receive from you or from other sources, such as processing an application or payment information and helping you sign up for an account. We only use companies who agree not to retain, share, store, or use personally identifiable information for any secondary purposes. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Some of these companies have payment gateways operated on behalf of and under contract to us. Further information about the collection and use of your data will be provided on the relevant payment gateway for you.

We also partner with certain third parties to provide specific services. When you sign up for these services, such as creating in account, which will be identified to you before or during the sign-up process, we will share names or other contact information necessary for the third-party to provide these services. These parties have agreed not to use personally identifiable information except for the purpose of providing these services.

Due to our global presence, the collection and processing of personal data may involve the transmission of data on an international basis. This means for instance that data you pass to us may be transferred and processed outside the EEA. In such cases where such transfer occurs, we endeavor to maintain an adequate level of protection in accordance with GDPR, including, where appropriate requiring contractual commitments between companies transferring personal data, as these clauses bind the parties and require them to protect the privacy and security of the data and/or obtaining express consent to the transfer of your personal data.

Institutions

We may share your information with third party education and accrediting institutions, as required by law or contract, to further our provision of products or services to you.

Legal Requirements

Notwithstanding the foregoing, we will consider, and may release, personally identifiable information to third parties: (1) to comply with valid legal requirements such as a law, regulation, search warrant, subpoena, or court order; or (2) in special cases, such as a physical threat to you or others.

Cookies

Refer to our Cookie Policy in our general privacy policy above to learn more about our collection practices and use of cookies. We will only utilize cookies to collection information from you with your consent.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  Different laws require us to keep different data for different periods of time, for example:

  • Certain regulations we are subject to, including the United States Internal Revenue Code require that we keep records of financial transactions for seven years.
  • Certain regulations we are subject to in the United States of America require that we retain information on former employees for up to three years after termination of employment.
  • Data on former members and supporters is typically retained for up to three years after last contact. However, we will keep your data during your lifetime if you have included us in your will, estate planning, or trust.
  • Information that does not need to be accessed regularly, but which still needs to be retained, is archived or placed offline.

Correction/Updating Personal Information

You can help us keep our records up to date by telling us when your contact details and other personal information change. You can also change your mind at any time about how we contact you or ask us to stop contacting you altogether.

Please contact our office and they’ll make the changes for you:

  • By email: Data@gbhem.org
  • write to: General Board of Higher Education and Ministry, 1908 Grand Avenue, Floor 3, Nashville, TN 37212.

If you tell us that you no longer want to receive further contact from us and you are in our donor or member database, it may take a short while before our communications stop altogether as selection of donor or member information for some of our communications is completed a few weeks in advance. If you request to receive no further contact from us, we will keep the information we hold on you and add you to our suppression lists to ensure that you do not receive unwanted materials in the future.

Your Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.  If you wish to exercise any of the rights set out below, please email us at Data@gbhem.org or contact us in one of the ways provided in the Contact Details section below.  You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us:

  • By email: Data@gbhem.org
  • Write to: General Board of Higher Education and Ministry, 1908 Grand Avenue, Floor 3, Nashville, TN 37212

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Contact Details

If you have any questions, comments or suggestions, please let us know by contacting us:

  • By email: Data@gbhem.org

Write to: General Board of Higher Education and Ministry, 1908 Grand Avenue, Floor 3, Nashville, TN 37212