European Privacy Statement
We are committed to the privacy and confidentiality of your data. This privacy statement describes our current policies and practices with regard to the processing of personal data.
By using this Site policy, you are agreeing to the terms of this Privacy Statement.
USAAEF (“us”, “we”, “our” and “ours”), a private nonprofit corporation organized and existing under the laws of Texas with offices located at 9800 Fredericksburg Road, San Antonio, Texas 78288.
USAAEF is a “Data Controller,” which means it is the entity that determines how your Personal Data is accessed and used. For more information about Luxembourg Data protection requirements, please refer to the National Commission for Data Protection website at www.cnpd.public.lu/ or phone them on +352 26 10 60 – 1. The term “USAAEF” when used in this Privacy Statement means the USAA Educational Foundation.
What Is Personal Data?
Personal data is data relating to an identified or identifiable individual. Sensitive personal data is personal revealing a person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, membership in trade unions, genetic data, biometric data, and data concerning health, sex life or sexual orientation.
What Personal Data Does USAAEF Collect?
- Collection of Your Personal Data (Including Sensitive Personal Data)
- Additional Data Collected Online
In addition to the information, we collect as described above, we use technology to collect information about the use of our website and other sites you may visit. For example, our web server automatically logs which pages of our website our visitors view, their IP addresses and which web browsers our visitors use. We also use your IP address to help diagnose problems with our server and to administer our website. An IP address is a numeric code that identifies your computer on a network, or, in this case, the internet. Your IP address is also used to gather broad demographic information. We may also perform IP lookups to determine which domain you are coming from (e.g., example.com) to more accurately gauge our users’ demographics. Our website contains hyperlinks to other pages on our website. We may use technology to track how often these links are used and which pages on our website our visitors choose to view.
Third parties, such as our service providers, use cookies and other tracking technologies to collect information about your online activities over time and across different websites, including when you visit our website. We also use third-party web beacons on our website and on other sites to assist in managing and optimizing our online advertising. We use this information to provide relevant marketing to you when you visit our website or third-party websites.
To collect the data described in the preceding paragraph, we may utilize “session cookies” that remain in the cookies file of your browser until the browser is closed at the end of your session and “persistent cookies” that remain on your hard drive until you erase them, or they expire. Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information that is sent to your browser and stored on your computer’s hard drive. Cookies help us determine the effectiveness of various marketing channels, to improve the content of our website and personalize content on our website. Cookies do not damage your computer.
We may collect personal data from different sources. You may choose to receive additional information or services from us. When you access the Site, we request personal data about you, such as your name, email address. The provision of certain elements of your personal data is a contractual requirement. If you do not provide us with personal data when requested, we may not be able access our services.
Cookie Notice
- Who is providing this notice?
This Cookie Notice (“Notice”) is provided by USAAEF, which in this context means The USAA Educational Foundation (legalities – from contract template). This Notice describes the different types of cookies and similar technologies that we use on our Site. As used in this Notice, “Site” means usaaef.org (insert vanity name) and other sites or applications owned and operated by USAAEF, unless a different notice is posted on a particular site or is made available to you and by its terms, supplements or replaces any terms of this Notice. We may change this Notice from time to time and without prior notice to you. If we make changes to this Notice, we will notify you by revising the “Last Updated” date within the Notice, and in some cases, we may additionally notify you of changes we believe to be material by adding a temporary statement to our website or providing you some other form of notification. Your continued use of the Site constitutes your acceptance and agreement to any changes to this Notice. If you have questions, you may contact the USAAEF by writing to us at the following address:
The USAA Educational Foundation
Attn: President
9800 Fredericksburg Road
San Antonio, Texas
78288-0020We retain personal information collected through cookies for the time reasonably necessary to achieve the purposes described in this Notice, or any other notice provided at the time of collection, unless a longer retention period is required or permitted by applicable law, considering applicable statutes of limitation and our records retention requirements and policies.
- What are cookies and other similar technologies?
Cookies are small text files containing information that our website sends to and stores on your computer or mobile device. We use cookies and fingerprinting techniques for a variety of purposes and to enhance your online experience, for example, by allowing us to remember your log-in status, to analyze and customize our Site interactions with you, ensure your privacy and security with the secure portion of our Site, and to tailor and control the advertising displayed on our Site. We use our own (first-party) and partner companies (third-party) cookies to support these activities. We may also work with third-party vendors to capture data in real time, such as through “screen capture” or “session replay” technologies: we may use this information, for instance, to detect security threats, to analyze web traffic, or simply to better understand how our Site is being used.
- What types of cookies do we use?
- How do I disable/enable cookies?
You can click on the below links to find out how to manage cookies on popular browsers.
In addition to browser-based settings, you can manage third-party cookies by visiting aboutads.info/choices/ and youronlinechoices.eu.
Essential/Strictly Necessary Cookies
These types of cookies allow us to provide our essential services to you. These cookies are necessary for our Site to operate, to verify your identity, and to maintain the privacy and security of our Site. These cookies are always on and without these cookies, we cannot provide our services. These cookies are not used for analytics or to target you with online advertising. Although you may be able to set your browser preferences to block or delete these cookies, doing so will impact the functionality of our Site and will cause it to not work.
Analytics Cookies
These types of cookies in this category are used to allow us to analyze your use of our Site and to evaluate and improve the performance of the Site. They may also be used to provide a better user experience, for example, by providing us information about how our Site is used or by helping us to identify issues you may have when using our Site. These cookies are not used to target you with online advertising.
For What Purposes Does USAAEF Process Personal Data?
| Purposes of Processing | Legal Basis for Processing |
|---|---|
| For internal reporting and analytics – to analyze our financial health, forecast profitability, determine trends and otherwise assess our products and services | Legitimate interests – USAAEF’s interest in maintaining financial health, growth and stability |
| For compliance with legal obligations – to respond to court orders, government investigations, subpoenas and litigation, and as otherwise required by law | Compliance with a legal obligation |
| For additional purposes – to process personal data in a manner not described in this privacy statement | With your consent |
What Personal Data Does USAAEF Disclose or Share With Others?
- Sharing and Disclosure of Your Personal Data
We do not share, sell or distribute your personal data with third parties, except as otherwise provided for in this privacy statement.
For the purposes of the processing identified above, we transfer or share personal data with third-party service providers including those in the United States of America. These third-party service providers process personal data for our benefit and on our behalf in accordance with the purposes for which the data was originally collected or for purposes to which you have subsequently consented. For example, sometimes a third party may have access to your personal data in order to support our information technology functions.
We may also share, transfer or disclose personal data to comply with a legal requirement; for the administration of justice, interacting with anti-fraud databases or for other actions to prevent fraud; to protect your vital interests; to protect the security or integrity of our databases or this website; to take precautions against legal liability in the event, re-organization, dissolution or similar event; to process your transactions; to service your accounts; and for other routine business purposes. The types of third parties who may receive personal data in these circumstances are parties to a litigation; USAAEF service providers; government entities; and third parties involved in re-organization or similar event. We will inform you of any such transfer or disclosure to the extent required by law.
- Transfer of Data Abroad
To allow us to issue and administer your policy, we will transfer your personal data abroad. When we transfer your personal data outside of the European Economic Area or another jurisdiction not deemed to provide “adequate” protection by the European Commission, we will do so in accordance with applicable data protection law using a valid cross-border transfer mechanism. Our transfer of personal data to the USAAEF entities in the United States is based on controller-to-processor and controller-to-controller standard contractual clauses. Our transfers to other jurisdictions, such as India, also are based on standard contractual clauses. If you would like to obtain a copy of our relevant standard contractual clauses, please contact our Data Protection Officer as described below.
If you are visiting USAAEF’s website, www.usaaef.org, from any country outside the United States of America, this will result in the transfer of information across international boundaries. USAAEF’s servers are located in the United States of America.
What Are Your Rights With Respect to Your Personal Data?
You have the right to request access to and rectification or erasure of your personal data, the restriction of the processing of your personal data, or to object to the processing of your personal data in accordance with applicable data protection law. You also have the right to data portability in accordance with applicable data protection law. In addition, you may withdraw any previously provided consent at any time. If you want to exercise any of these rights, you may email EDFOUNDATION_GDPR@USAAEF.ORG, ATTN: Data Protection Officer.
We will respond to your request in accordance with applicable law. If we cannot resolve your request to your satisfaction or you have other concerns regarding our processing of your personal data, you may lodge a complaint with our supervisory authority.
How Can You Change How USAAEF Uses Your Personal Data?
- To Limit Our Notification to You:
With your consent, we may, from time to time, email or mail you information to make you aware of our other products and services that may be of interest to you. If you do not wish to receive emails or post from us for these purposes, please email us at the address given below under “Feedback” indicating in the subject heading “Email Unsubscribe” for emails, or “Do Not Solicit” for post.We hope you will be delighted with our products and services. However, if you do not wish to receive marketing emails from us and want to be removed from our electronic mailing list, please email or write to us with “Email Unsubscribe” in the subject heading using the addresses in Contact USAAEF given below.If you wish to be removed from our postal marketing database, please email or write to us with “Do Not Mail” in the subject heading using the addresses in Contact USAAEF given below.If you do not wish to receive any direct marketing from us, please email or write to us with “Do Not Solicit” in the subject heading using the addresses in Contact USAAEF given below.Please include your USAA number in the body of the email or letter so that we may apply your request to your records.
- Disabling or Enabling Cookies
You can set your browser to notify you when you receive a cookie so that you may accept or decline the cookie. See our Cookie Notice section above for more details.
How Long Is Your Personal Data Stored?
We store records containing personal data in accordance with our retention schedule. Pursuant to our retention schedule, we store the majority of our policy service records for 12 years, but certain policy service records are retained for different time periods. We also generally course study records for seven years after the claim is closed. Under our retention schedule, we may store personal data (outside of insurance records) for longer periods for legal and compliance reasons and to protect against fraud. For more information about our retention schedule or practices, please contact us as described below.
Contact USAAEF
If you have any questions about this Privacy Statement or any part of our service, you may contact us by emailing EDFOUNDATION_GDPR@usaaef.org
ATTN: Data Protection Officer (“DPO”) in your correspondence or indicate to the representative that your question or comment is for the DPO.
Notification of Changes to Privacy Statement
We are continually improving our methods of communication and adding new functionality and features to this website and to our existing services. Because of these ongoing changes, changes in the law and the changing nature of technology, our data practices will change from time to time. If our data practices change, we will notify you and the local data authority where required by law. We encourage you to check this page frequently.