KEF USA Summer Camps
KEF USA Privacy Policy
Effective date: [Insert the date this revised policy takes effect]
KEF USA, LLC (KEF USA, we, us, or our) provides educational and travel programs for students. This Privacy Policy explains how we collect, use, protect, and share personal information in connection with our website, inquiries, applications, enrollment, and program activities. It also explains how to contact us about privacy and exercise applicable rights.
1. Information we collect
Depending on your interaction with us and the program selected, we collect:
- Contact information: names, email addresses, telephone numbers, mailing addresses, and parent, guardian, and emergency contact details.
- Student and enrollment information: date of birth, age, selected program and dates, language proficiency, relevant learning needs, application responses, signed permissions, and participation records.
- Health and safety information: relevant allergies, medical conditions, medications, dietary or accessibility needs, insurance details, emergency instructions, and records of incidents or care during the program. We request information needed for safe participation and appropriate support.
- Travel and identity information: arrival and departure arrangements and identification or passport information when necessary for a specified program or travel purpose. We do not request Social Security numbers for routine student enrollment.
- Payment information: billing contacts, payment status, transaction references, and records needed for accounting. Payment providers process card details under their own privacy notices. Please do not send full card numbers or security codes by email or through inquiry forms.
- Communications and permissions: correspondence, requests, complaints, consent records, and authorized photographs or recordings.
- Website information: IP addresses, browser and device information, pages requested, and security logs generated by our website and hosting providers.
We collect information from parents and guardians, adult applicants, authorized representatives, necessary program providers, and our own program records. If information is provided by an agent, school, or group organizer, that person must be authorized to provide it. Their involvement does not replace parental permission where required.
2. How we use information
We use personal information to respond to inquiries; evaluate applications and placement; administer enrollment and payments; deliver instruction and activities; arrange accommodation and transportation; communicate with families; support student health and safety; respond to emergencies; resolve concerns; prevent fraud; secure our systems; and satisfy applicable legal, accounting, and insurance obligations.
We request only information reasonably needed for these purposes. Required application fields are identified. If necessary information is not provided, we may be unable to arrange safe participation or provide the requested service.
Optional promotional communications and promotional use of student images require separate choices. Agreeing to this Privacy Policy or enrolling does not automatically authorize those optional uses.
3. Children and parental involvement
Our programs serve minors, and we collect information about students to administer those programs. Parents or legal guardians must complete enrollment and provide required permissions for students under 18. Our website inquiry and enrollment forms are intended for adults. Children under 13 must not submit personal information through those forms or create website accounts.
We do not knowingly collect personal information directly online from children under 13 without following applicable legal requirements. If a parent believes a child has submitted information without appropriate authorization, please contact us so we can investigate and take appropriate action, including deletion where required.
Before introducing a feature that collects information directly online from children under 13, we will assess its requirements under the Children's Online Privacy Protection Act, provide required notices, and obtain verifiable parental consent where required. This policy alone does not serve as that consent.
If a program uses a third-party learning platform or records online lessons, we will provide relevant information about the provider, collection, access, and recording arrangements before participation and obtain permissions required by law. Parents may contact us about reviewing or deleting their child's information or withdrawing consent. We verify parental authority and explain any lawful retention limits or effects on participation.
4. Health information and emergencies
We limit access to health information to people who need it for student care, safe participation, program administration, or legal obligations. Necessary information may be shared with authorized staff, medical professionals, emergency responders, insurers, and relevant activity providers.
An emergency may require disclosure to protect a student's or another person's life or safety. Our medical treatment permissions are addressed separately in enrollment documents. Please use the designated secure collection process for medical records or identity documents rather than ordinary inquiry forms or email attachments.
5. How we share information
We share information only as needed for the purposes described in this policy, including with:
- Providers supporting website hosting, secure forms, record storage, communications, payments, and technical support.
- Educational and activity providers, accommodation and transportation providers, and authorized organizers involved in the selected program.
- Medical providers, emergency responders, insurers, and professional advisers where appropriate.
- Government authorities or other parties when required by law or necessary to protect safety, investigate fraud, or establish or defend legal claims.
We limit disclosures to the information needed for the recipient's role. Service providers acting on our behalf are subject to appropriate confidentiality, security, and use restrictions. Independent providers, such as payment processors and medical providers, may process information under their own legal obligations and privacy notices.
We do not sell personal information or disclose it for third-party targeted advertising. We do not authorize service providers to use student health records, identity documents, or enrollment records to train general-purpose AI models.
6. Photographs, videos and recordings
Promotional photography and video involving identifiable students are covered by a separate optional parental media permission. Declining promotional permission does not prevent enrollment.
The permission explains the intended uses and publication channels. You may withdraw permission for future uses by contacting us. We will stop new promotional uses covered by the withdrawal and take reasonable steps to remove material we control where appropriate. We cannot guarantee retrieval of printed materials already distributed or copies independently shared by others. Any instructional recording is addressed separately before recording begins.
7. Cookies and website technologies
Our website uses cookies and related technologies needed for operation, security, and choices you make. Under our website configuration, we do not use advertising pixels, behavioral advertising, or optional visitor analytics.
Your browser can block or delete cookies, although this may affect website functions. Links to third-party websites lead to services governed by their own privacy notices. We will update our notices and obtain any legally required consent before adding optional tracking technologies.
8. How long we keep information
We keep information for defined purposes and delete it or securely anonymize it when it is no longer needed, subject to legal holds and applicable recordkeeping obligations.
Our retention schedule is:
- Inquiries that do not result in enrollment: [insert approved period and starting event].
- Enrollment, permissions, and participation records: [insert approved period and starting event, taking account of records involving minors].
- Health, medication, and incident records: [insert approved period and starting event, consistent with applicable obligations and insurance requirements].
- Travel documents and identification copies: [insert the shortest approved period after their specified purpose ends].
- Financial and tax records: [insert approved period and starting event].
- Website security logs: [insert approved period].
- Promotional media and consent records: [insert approved periods and withdrawal process].
Restricted backup copies are deleted through our normal backup cycle of [insert period]. Where a law, claim, investigation, or insurance requirement requires longer retention, we restrict the information to that purpose and delete it when the requirement ends.
9. Security
We use reasonable administrative, technical, and physical safeguards appropriate to the information, including restricted staff access, multifactor authentication for systems holding sensitive records, secure transmission, staff confidentiality practices, and secure disposal. We review providers that handle sensitive information on our behalf.
No system is completely secure. If an incident requires notice under applicable law, we will notify affected people and authorities as required. Please contact us promptly if you suspect unauthorized access or an improper disclosure.
10. Your choices and privacy requests
Contact us to request access to or correction of information, deletion where available, withdrawal of optional consent, or information about our practices. Depending on applicable law, you may also have rights to restrict or object to processing, receive a portable copy, appeal a decision about a request, or complain to the relevant data protection authority.
We verify identity and, for student requests made by an adult, parental authority or other authorization before releasing information. We respond within applicable legal deadlines. Some information must be retained or used for safety, required records, or legal claims; we will explain applicable limits.
You may unsubscribe from promotional emails using the link in the message or by contacting us. We may still send necessary enrollment, safety, payment, and program communications. Withdrawing permission for information necessary to provide the program may affect our ability to provide it; we will explain the consequences.
11. International information processing
KEF USA operates in the United States. Information provided from other countries is processed in the United States and in locations used by our approved providers: [identify actual additional processing locations or the provider information page describing them]. Other countries may have different privacy laws.
Where European or other applicable data protection law requires a legal basis, we rely on the basis appropriate to each purpose, such as administering a contract with an adult customer, legitimate interests in safe program administration and secure operations where those interests do not override individual rights, legal obligations, or valid consent. Health and other specially protected information require an additional lawful condition; we obtain explicit consent where required, with emergency exceptions only as permitted by law.
Where international transfer safeguards are required, our applicable safeguards are [identify the verified transfer mechanism and how a person can request details or a copy]. Submitting information or using the website does not, by itself, provide consent to a transfer that requires separate safeguards or express consent.
12. Changes to this policy
We update this policy when our practices or legal requirements change. The effective date identifies when the revision applies. For material changes, we provide appropriate notice and obtain additional consent where required before carrying out the new processing.
13. Contact us
KEF USA, LLC
Privacy contact: kefsummer@gmail.com
Mailing address: [insert current business mailing address]
Website: [insert final public website address]
Please write Privacy Request in the subject line. Do not include medical records, passport copies, full payment details, or other sensitive attachments in your initial message. We will explain the appropriate secure next step.