The Culinary Institute of America (“the CIA” or “we”), a private, non-profit educational institution, presents this Privacy Notice in the interests of fairness, transparency and accountability regarding the privacy of individuals whose personal data we collect and process (“data subjects” or “you”). Our collection and processing of your personal data is lawfully based on our legitimate interests as a private, non-profit higher education institution.
The CIA understands your use of our online applications to indicate your consent to the collection, processing and use of your personal data as described in this Notice, except where we request active, express consent or where such consent is required by law.
The CIA collects and processes personal information from and about data subjects, who may be prospective students and their family members, alumni/ae, prospective donors, donors, prospective employees, employees, restaurant patrons, food enthusiasts, conference attendees, private event clients, CIA market and store customers, and other members of the public.
The CIA will not knowingly request personally identifiable information from anyone under the age of thirteen without first requesting parental consent.
Our websites contain links to other sites which have their own privacy practices not under the control of the CIA. We encourage you to familiarize yourself with the privacy notices for those external sites.
A text file called a “cookie” may be placed in the browser files of your computer when you visit our online applications. Although the cookie itself does not contain personal information, it provides information about your user session. A cookie file cannot read data off a hard disk or read cookie files created by other websites.
You may block the placement of cookies by changing your browser setting pertaining to cookies. This setting can also be changed to provide notification when a cookie file is placed. Our website does not require cookies to be accepted in order to function.
We understand that you consent to the placement of cookies on our website if you do not change your browser settings as described above. You may change your browser settings to block cookies at any time.
We use the Facebook Conversion Pixel, Google Analytics, Google AdWords Conversion tracker, and other services that place cookies on a browser across the website. These cookies help increase the website’s effectiveness for our visitors. These cookies are set and read by Google, Facebook, or the specific provider. We also share unique anonymous identifiers with third parties to coordinate advertising and reporting across devices and browsers. To opt out of Google and Facebook tracking, please visit http://www.google.com/policies/technologies/ads/ or https://www.facebook.com/help/568137493302217.
Any Google user data may be accessed and/or deleted via My Activity.
We will not sell your personal information. We will not disclose your personal information without your permission unless a legal exception applies (for example, in case of emergency, to protect safety on campus, or in response to a valid subpoena or court order).
We retain your information for a period of time in accordance with our legitimate interests or as needed to comply with applicable law.
We may combine your personal data with device information and location information (with your consent, where required) to serve you specifically, such as to deliver a product to you according to your preferences or restrictions, or for advertising or advertising targeting purposes.
Internal CIA policy governs the use of the CIA’s network and computing resources by CIA employees, contractors and students, and also addresses privacy expectations.
We may collect data about you when you provide it to us voluntarily, such as through your use of our online applications; when you contact us directly by e-mail, telephone, in person or in writing; when you order goods and services; or any other means by which you voluntarily provide personal information to us.
Types of information we collect about you may include but is not limited to: name, e-mail address, address, telephone number, payment information (for example, credit or debit card details), information about your computer (for example, your IP address and browser type), tracking information (for example, which pages you have viewed, the time you viewed them and what you clicked on), information about your mobile device (such as your geographical location), and any other information you provide when completing forms.
The CIA recognizes the sensitivity of personal financial information and accords it the additional strict privacy and security safeguards appropriate to the classification of sensitive/highly confidential. CIA personnel are involved in handling financial information on strictly a need-to-know basis and receive appropriate training in financial information privacy and security. The CIA does not share nonpublic financial information with nonaffiliated third parties without consent.
The CIA may collect and process personal financial information only in very limited contexts for the purposes of accepting or making payment lawfully based on its legitimate interests or in support of or preparation for an agreement. In terms of accepting payment, these purposes include: accepting charitable contributions (usually through the Advancement Office), accepting payment for goods or services (such as at a CIA restaurant), and accepting payment for student educational charges (such as tuition and board, through the Student Financial & Registration Services). We may collect financial information from the credit or debit payment card if you choose to use this method of payment; or from your personal check if you choose to use this method of payment.
In the case of CIA students or prospective students, financial information about a student and/or parents may be collected as part of the process of applying for financial aid. The CIA may collect a student’s Social Security Number only as the official identifier for state and federal financial aid documents and related processing.
The CIA also collects and processes nonpublic financial information from its employees for compensation, benefits and tax and purposes; and from independent contractors for payment and related purposes.
We offer various opportunities to subscribe to electronic communications. If you choose to subscribe, we gather your e-mail address. With your consent, we may contact you at the telephone number that you provide to us by way of direct dial calls, autodialed and prerecorded message calls, and text messages. In this manner we may send you information relating to our products and services, including confirmations and updates, receipts, technical notices, updates, security alerts, and support and administrative messages; and/or communicate with you about contests, offers, promotions, rewards, upcoming events, and other news about products and services offered by the CIA.
You may remove yourself from any public CIA mailing list by unsubscribing on the e-mail’s subscription management page via a link at the bottom of each e-mail. You must unsubscribe from each list you wish not to receive e-mails from. More information about communicating your preferences can be found further in this Notice.
The CIA’s Office of Advancement periodically sends e-mails for the purpose of communication to persons with existing relationships with the CIA, as well as fund-raising campaigns. These e-mails will be identified as coming from the CIA’s Office of Advancement, and the CIA’s Office of Annual Giving, respectively. Recipients of these e-mails can opt out at any time by following the procedures outlined in this Notice.
The CIA uses social media, which may allow you to connect and share your actions, comments, content, and information publicly or with friends. Please remember that any information that is disclosed in these areas becomes public, and consider the privacy concerns of yourself and others when choosing what to share in social media.
Our social media whose privacy practices we do not control. Please contact those sites and services directly to learn about their privacy practices. Use caution when deciding to disclose your personal information.
We occasionally conduct optional surveys. We use the data from survey responses to better target content to our audiences.
We offer online registration for CIA events, such as admissions information, courses, conferences, and restaurant reservations. Registration features invite you to voluntarily provide personal information, which may include contact information (name, telephone number and/or e-mail address).
We use information request forms that invite you to voluntarily provide personal information such as names, addresses, and telephone numbers. We may send text messages to cellular telephone numbers within our database so that interested individuals can be contacted by one of our representatives. By providing a cellular telephone number, you agree to be contacted by the CIA on your cellular telephone by such means. You may change your mind and decline to be contacted in this manner by contacting us at the information below.
We may track your traffic patterns throughout our online applications in a de-identified manner. We do not correlate this information with identifiable data about you. We may break down overall usage statistics according to a visitor’s domain name, browser type, and Multipurpose Internet Mail Extension (MIME) type by reading this information from the browser string (information contained in every online application user’s browser).
We may also track and catalog some online application user data, including the search terms entered and actions taken, but this tracking information is not associated with individual online application users.
We use aggregated tracking information to determine which areas are preferred by users and to tailor our content to users’ needs.
We do not share aggregated tracking information with any third party, with the following exceptions: to a contractor engaged to conduct collection or processing for our legitimate interests; in accordance with the law or valid legal process; or to protect the personal safety of our online application users or the public.
Where permitted or authorized by law, we may receive information about you from third-party databases or services that provide information about business people and companies, or from third parties from whom we have purchased information (including an individual’s name). We may combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, prospective students or donors, and provide information about opportunities, products and services that may be of interest to you.
We may use your personal information for the following purposes: to provide you with the opportunities, information, services, products, and functionality offered on our online applications; to fulfill your requests, including but not limited to making reservations, paying for services, joining e-mail lists, sending CIA gift cards to recipients that you designate; to communicate with you about your account or your use of our online applications, services, products and/or functionality; to respond to, or follow up on, your comments and questions; to provide customer service otherwise; to communicate with you about special offers and other marketing communications; to communicate with you about employment opportunities; to operate and improve our online applications, products, services, and functionality; to process and deliver contest entries and rewards; to authenticate your credit or debit card account information, if applicable; to personalize your experience on our online applications; in combination with other information we may get from third parties, to help understand your needs and to provide you with better service; to perform statistical analysis; to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity; to comply with our policies, procedures and legal obligations; to support our education mission and administrative operations; and as otherwise consented to by you and as required or permitted by applicable law.
You may at any time change your preferences about which if any communications you would like to receive.
Upon receipt of an opt-out request, we will update our records as promptly as practical. Note, however, that you may receive additional communications after requesting removal while we process your request. Additionally, information may exist in multiple lists within our system, and our technology limits the processing of opt-out requests to the specific list source. For this reason, we recommend that you adjust your e-mail preferences rather than opting out completely. We will continuously assess our responsiveness to opt-out requests with respect to new technologies, business practices and our visitors’ needs.
To opt out, you may choose from the following methods:
To unsubscribe from an e-mail list:
For any other privacy preferences, questions, or concerns, please contact the Director of Compliance & Information Privacy at 845-451-1429. Complaints about privacy may be made via the CIA’s confidential Hotline at 845-905-4477 or CIAHotline@culinary.edu.
The CIA is not a covered entity or business associate under the Health Insurance Portability and Accessibility Act (HIPAA) or the Health Information Technology for Economic and Clinical Health (HITECH) Act.
Student health information is provided to the CIA by students for public health, safety, and treatment purposes. The CIA handles student health information in strictest confidence, with respect for individual autonomy, and with appropriate safeguards for sensitive information as required by law and CIA policy.
California residents who provide “personal information” (as defined in the statute) in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the personal information we shared, if any, with other businesses for marketing uses. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared such personal information for the immediately prior calendar year. To obtain this information, please contact us by sending a letter or calling us at the contact information above.
This section applies if you are a data subject located in the European Union (EU). The EU General Data Protection Regulation (GDPR), effective May 24, 2018, is a complex piece of legislation which may in some cases conflict with U.S., state, or other privacy laws and rules. The CIA will approach any conflict of laws on a case-by-case basis.
The CIA is the data controller for the processing of your personal data on the lawful basis of our legitimate interests in most cases, and possibly on other permitted lawful bases depending on the context of the data collection and processing, such as the contractual basis or legal obligation. The person serving in the role of data protection officer is the CIA’s Director of Compliance & Information Privacy, who can be reached at 845-451-1429; or The Culinary Institute of America, 1946 Campus Drive, Hyde Park, NY 12538 USA; or CIAHotline@culinary.edu.
Subject to the GDPR, you have the following rights in relation to your personal data:
To ensure appropriate security and confidentiality of personal data, including the prevention of unauthorized access to or use of personal data and the equipment used for processing, the CIA has a comprehensive information privacy and security program which is reviewed and enhanced regularly. Nonetheless, perfect security of information provided to the CIA cannot be guaranteed. Visitors to our websites should use reasonable care in disclosing personal data online, and persons interested in communicating with the CIA may choose other means than the Internet to do so. For more information about our information privacy and security programs, please contact the Director of Compliance & Information Privacy at 845-451-1429.
This privacy statement will be continuously assessed with respect to new technologies, business practices and our visitors’ changing needs. The CIA may change its privacy practices from time to time. If we make any changes, we will update this privacy notice accordingly (the date of the most recent change is displayed at the bottom of this notice).
If you have any questions about this privacy statement, the practices of the website, or your dealings with the website, you may contact:
The Culinary Institute of America
1946 Campus Drive
Hyde Park, NY firstname.lastname@example.org
Last updated on April 17, 2019