At IENA we take your privacy seriously. Below outlines how we collect, use and disclose and process your personal data.
This is the policy of International Exchange of North America Inc (IENA, American Summers). We are a US based company with offices at 699 Washington Street, Suite 203, Hackettstown, NJ 07840.
When we say “we”, “us”, “our” and “IENA” we are referring to International Exchange of North America Inc which owns and operates all of the International Exchange of North America brands, trademarks and websites.
When we say “you”, “your” and “customer” we are referring to someone who has signed up for our service.
IENA does not sell its customer data or mailing lists and will not share your Personal Data with any third party companies for the purposes of direct marketing.
Our privacy policies will be overridden when the safety and welfare of children are at stake, or if we are required to do so by law or US State Department regulation. We give the highest possible priority to the safety and welfare of children and will in all circumstances cooperate with police and government authorities
What this Applies to
All services provided by IENA, including websites, subdomains and mobile versions.
Collection of Data
We collect and process the following types of information:
Personal Data
We collect personal data in the following ways:
- When you create an application to participate in one of our programs
- When you contact us in any way, for example, phone, online
- When you opt to join our mailing lists
- When you request more information about our programs
If you apply to be placed on a J-1 or other IENA program, we may collect and store information such as your full name, E mail address, phone number, photo, work history, passport details, references, criminal background checks, etc.
Sensitive Personal Data
We collect information such as a criminal background check or medical data to comply with program and visa requirements set by international governments. We do ask for sensitive data such as religious backgrounds to assist us in matching you with an appropriate employer or placement. Providing this information is voluntary.
Your information is stored from the time of application, during the time you are on the program and for a period of 3 years after, in compliance with United States government regulations.
If you apply to our program and do not take part in our program, you have the option to remove all your data from our system by e mailing privacy@iena.org
Lawful Basis for Processing Personal Data
On certain occasions, we process your personal data when it is necessary for the performance of a contract to which you are a party, such as to provide services to you. We may also process your personal data to respond to your inquiries concerning our products and services.
On other occasions, we process your personal data where required by law. These include immigration purposes, including visa processing. We may also process your personal data if necessary to protect your interests or the interests of a third party. The United States Department of State, who administers our program, legally requires us to keep all applicants data on file for 3 years.
The Inland Revenue Service requires us to keep all financial records for 7 years.
Additionally, we process your personal data when necessary to do so, to effectuate the following legitimate interests:
- Making applicant determinations
- Administration of our program
- Utilizing service providers
- Human resource functions
- Hosting events
These legitimate interests are not overridden by your data protection rights. Where we process your personal data for these purposes, our legitimate interest is to carry out our activities that will improve the IENA experience for clients and employees.
For more information about the lawful basis of processing data in line with EU regulations, please visit the ICO website.
Financial Data
We collect this information but do not store it on our servers for security reasons. All financial information is processed using a third-party processor. Financial Data is used only as necessary to process a transaction.
Website, Cookies and similar things
We process device data when you interact with cookies and similar technologies. We may receive this data from third parties.
In line with our legitimate interests in providing and improving the user experience and improving our services, and understanding our demographics, we use this information:
- For essential and functional purposes, such as your browser remembering your username and password and to personalize your experience
- For analytics and site performance, such as tracking how our services are used, website performance, what users visit our site and how they interact with our site
- For the purpose of displaying advertisements to users who may have demonstrated and interest in our services
How do we protect your information?
We implement a variety of security measures to maintain the safety of your personal information when you place an order or enter, submit, or access your personal information.
We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorized with special access rights to such systems and are required to keep the information confidential.
After a transaction is completed, your private information (credit cards, financials, etc.) will not be stored on IENA’s system
How we disclose or share data
Where we work with third party contractors to perform services for IENA, we may need to disclose your personal information in order to provide our services to you. Under these circumstances, we take steps to ensure that those third party contractors who process personal data on our behalf do so in a way which safeguards the information and that it is used for the purposes for which it was supplied.
We will not disclose your personal information to any third parties unless we have your consent or we have a legal basis to do so (for example to progress our legitimate interests or to fulfil a contract we have with you) or disclosure is either necessary to prevent a threat to life or health, authorised or required by law, reasonably necessary to enforce the law or necessary to investigate a suspected unlawful activity.
IENA does not sell or share Personal Data to unaffiliated third parties or companies for marketing purposes. Further information about our third party providers can be found HERE
California Online Privacy Protection Act Compliance
Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore are required to disclose, upon request, the identity of any third parties to whom we disclose their personal information.
To make such a request, please contact IENA at privacy@iena.org
Children’s Online Privacy Protection Act Compliance
We are in compliance with the requirements of COPPA (Childrens Online Privacy Protection Act).
Terms and Conditions
Please also visit our Terms and Conditions section establishing the use, disclaimers, and limitations of liability governing the use of our website at AGREEMENT
Your rights
You are entitled at any time to a copy of the information we hold about you and to correct any inaccuracies. Please make this request in writing via post or email.
You have a right to ask in writing not to receive any direct marketing material from us, such emails or physical letters. You can amend your preferences in all of our email newsletters by hitting “unsubscribe”. Once notified we will take all the necessary steps to stop using your information for direct marketing.
If the processing of personal data is necessary and there is no statutory basis for such processing, we will ask for your consent to process your personal data. You have the right to withdraw your consent to processing of personal data at any time.
If you wish to exercise the right to withdraw consent, contact IENA at privacy@iena.org.
Contacting Us
If there are any questions regarding this privacy policy, please contact IENA at privacy@iena.org
Updated 5/16/2018