Scope of this Policy

InterExchange is a not-for-profit organization dedicated to promoting cultural awareness and international understanding through a wide range of work and travel, camp, language programs, volunteer opportunities, professional training, internship and au pair programs within the United States and globally.

This privacy policy (“Policy”) applies to:

• InterExchange, Inc. and our affiliates (collectively, “InterExchange,” “we,” “us,” “our”).
• InterExchange’s online properties, including our websites, and websites or mobile applications that link to it, and our social media pages or handles.
• InterExchange’s programs or services (collectively with the above, “Services”).

This Policy applies when you interact with us through our Services. It also applies anywhere it is linked. It does not apply to third-party websites, mobile applications, or services that may link to the Services or be linked to from the Services. Please review the privacy policies on those websites and applications directly to understand their privacy practices.

We may change this Policy from time to time. If we do, we will notify you by posting the updated version.

If you are located in the European Economic Area, the United Kingdom, or Switzerland, additional rights are described in the section “Privacy Disclosures for Specific Jurisdictions” below.

Information We Collect

We collect information from you directly, from the devices you use to interact with us, and from third parties. We may combine information from the Services together and with other information we obtain from our business records. We may use and share information that we aggregate (compile to create statistics that cannot identify a particular individual) or de-identify (strip information of all unique identifiers such that it cannot be linked to a particular individual) at our discretion.

Information you give us

You may provide the following information to us directly:

• Contact information, including name, email address, telephone number, and postal address.
• Employment information, including professional information, job title, company name, and size.
• Information contained in government-issued identification.
• Demographic information, such as age and gender.
• Information required to perform a background check.
• Audiovisual information and photographs, including recordings of online events.
• Content you may include in survey responses, including information about your hobbies or interests.
• Information contained in your communications to us, including call recordings of customer service calls.
• Information you make available to us via a social media platform.
• Information you submit to inquire about or apply for a job with us.
• Sensitive personal information, including racial or ethnic origin; political opinions; religious or philosophical beliefs; physical or mental health information; sexual orientation; and any information relating to a criminal offense.
• Any other information you submit to us.

In addition to the personal information described above, we may also collect the following information from you depending on the Services we provide:

• Participant application information, such as childcare reference documents, personal references, medical examination results, Visa status, emergency contacts, Accident and Sickness Insurance documentation, and tax identification information.
• Host application information, which may include: providing personal information about members of the household (where applicable); emergency communication channels; and information regarding any payment offered to Participants.
• If you choose to contact us through any messaging channel (for example, by phone call, SMS text, WhatsApp, or other third-party messaging platforms), we will collect your phone number or handle, and any information you provide within those messages. By initiating contact with us via these channels, you consent to our responding to you through the same channel unless you request otherwise.

Information we collect automatically

We and partners working on our behalf may use log files, cookies, pixels, other digital tracking technologies, or third-party integrations to collect the following information from the device you use to interact with our Services. We also create records when you make purchases or otherwise interact with the Services.

• Device information, including IP address, device identifiers, and details about your web browser.
• Analytical information, including details about your interaction with our website, app, and electronic newsletters.
• Diagnostic information, including web traffic logs.
• Advertising information, including special advertising and other unique identifiers that enable us or third parties working on our behalf to target advertisements to you and to measure the effectiveness of that advertising. Our advertising partners may also collect information about you when you visit other websites or apps and use that information to deliver advertising to you on our behalf or measure the effectiveness of our campaigns, including through server-to-server integrations we have with these partners.
• Business record information, including records of your purchases of products and services.

We work with categories of third parties to collect, measure, or process this information. These categories include analytics and website performance providers, digital advertising and retargeting networks, social media platforms, customer relationship management and marketing automation providers, and session-replay and user experience research tools.

For advertising and measurement activities on social media platforms including Meta (Facebook and Instagram) and TikTok, we may use those platforms’ direct integration, pixel, and conversion measurement tools. Personal data shared with these platforms for measurement purposes (including hashed contact information such as email addresses) is processed by Meta Platforms Ireland Limited and TikTok Technology Limited (Dublin, Ireland) for European users, in accordance with each platform’s privacy policy. You can control the use of these tools through our cookie preference center and through each platform’s advertising settings.

Information We Collect From Other Sources

We may collect the following information about you from third-party sources:

• Any personal information you provide to International Cooperators or Hosts in order to use our Services.
• Sensitive personal information, including physical or mental health information.
• Contact information, demographic information, and information about your interests and purchases, from consumer data providers.
• Third-party account information, such as email, username, and profile photo, when you use a third-party or social media platform to login to the services via single sign-on.
• Information about your interests, activities, and employment history from social networks and other places where you choose to share information publicly.
• Information about your interaction with advertisements on our Services, or ads that we place on third-party websites, from online advertising companies.
• Background check results.
• If you decide to invite others to the Services, we will collect your and the other persons’ names and email addresses to send an email and follow up with the other person. You agree that you will obtain the other person’s consent before giving us their name and email address. You also agree that you will not send us the name or email address of a minor. We will inform any other person you invite that you gave us their information in the invitation email.

How We Use Your Information

We may use any of the information we collect for the following purposes.

• Service functionality: To provide you with our products and services, including to take steps to enter a contract for our services, process payments, send communications (including renewal reminders), host an event, and conduct general business operations, such as accounting, recordkeeping, and audits. The lawful basis of processing is performance of a contract or taking steps at your request prior to entering a contract. We also respond to inquiries you make by phone, SMS text, WhatsApp, or other messaging channels. By contacting us through these channels, you consent to our responding to you via the same channel unless you request otherwise. We will use your information to communicate with you about your inquiry, provide customer support, and fulfill any other purpose for which you initiated the communication. Where inquiries are not related to a contract (or prospective contract), our lawful basis for processing such data may be our legitimate interest in providing customer service or your consent, as appropriate. In addition, we may collect citizenship information and passport information where the lawful basis of processing for this information is consent.
• Service improvement: To improve and grow our Services, including to develop new products and services and understand how our Services are being used, our customer base and purchasing trends, and the effectiveness of our marketing. The lawful basis of processing is our legitimate interest.
• Personalization: To administer loyalty programs, offer you recommendations, and tailor the Services to your preferences. The lawful basis of processing is consent.
• Advertising and marketing: To send you marketing communications and newsletters, personalize the advertisements you see on our Services and third-party online properties, and measure the effectiveness of our advertising. We may share your information with business partners, online advertising partners, and social media platforms for this purpose. The lawful basis of processing for direct marketing is our legitimate interest; for use of cookies and similar technologies to deliver personalized advertising, it is your consent, where required by law.
• Security: To protect and secure our Services, assets, network, and business operations, and to detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal. The lawful basis of processing is compliance with legal obligations and our legitimate interest.
• Legal and regulatory compliance: To comply with legal process, such as warrants, subpoenas, court orders, and lawful regulatory or law enforcement requests, and to comply with applicable legal requirements including our recordkeeping and reporting obligations as a U.S. Department of State-designated exchange visitor program sponsor. The lawful basis of processing is compliance with legal obligations.
• Sensitive Personal Information: We may use this information for legal compliance, and to provide our Services (such as to facilitate matching with Hosts and to verify eligibility to participate in our programs). The lawful basis of processing is your consent, compliance with a legal obligation, and/or as necessary to protect your vital interests.

How We Share Your Information

We may share any of the information we collect with the following categories of recipients:

• Affiliates: We share information with other members of our group of companies.
• Service providers: We engage vendors to perform specific business functions on our behalf, and they may receive information about you from us or collect it directly. These vendors are obligated by contract to use information that we share only for the purpose of providing these business functions, which include:
  • Supporting Service functionality, such as customer service and customer relationship management, list cleansing, postal mailings, and communications (email, SMS).
  • Auditing and accounting firms, such as firms that assist us in the creation of our financial records.
  • Professional services consultants, such as firms that perform analytics, assist with improving our business, provide legal services, or supply project-based resources and assistance.
  • Analytics and marketing services, including entities that analyze traffic on our online properties and assist with identifying and communicating with potential customers.
  • Security vendors, such as entities that assist with security incident verification and response, service notifications, and fraud prevention.
  • Information technology vendors that assist with website design, hosting and maintenance, data and software storage, cloud infrastructure, and network operation, including providers whose platforms incorporate artificial-intelligence features (see “Use of Artificial Intelligence” below).
  • Marketing vendors, such as entities that support distribution of marketing emails.
• Online advertising and social media platforms: We partner with companies that assist us in advertising our Services, including partners that use cookies, similar tracking technologies, and server-to-server integrations to collect information to personalize, retarget, and measure the effectiveness of advertising. This includes Meta Platforms (Facebook and Instagram) and TikTok. If you interact with us on social media platforms, the platform may be able to collect information about you and your interaction with us. To control this sharing of information, please review the privacy policy of the relevant social media platform and use our cookie preference tools.
• Government entities and law enforcement: We may share information when we believe in good faith that we are lawfully authorized or required to do so to respond to lawful subpoenas, warrants, court orders, or other regulatory or law enforcement requests, or where necessary to protect our property or rights or the safety of our employees, our customers, or other individuals. As a designated sponsor of U.S. Department of State exchange visitor programs, we are subject to reporting and recordkeeping obligations under federal regulations and we share information with the Department of State and other federal agencies as required.
• Other businesses in the context of a commercial transaction: We may change our ownership or corporate organization while providing the Services. We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information as described in this policy.

Use of Artificial Intelligence

We use artificial-intelligence (“AI”) tools, including large language models, to support our operations. Typical uses include drafting and editing communications, summarizing or analyzing documents, translating content, and supporting customer-service interactions. In the course of these activities, personal data you have provided may be processed by these tools.

The AI tools we use are accessed through enterprise services provided by our cloud-infrastructure, productivity, and customer-engagement vendors, under agreements that provide that your personal data is processed within those vendors’ secure environments and is not used to train or improve generative-AI models.

Where an interaction with us is handled by an AI tool, for example, an automated chat agent providing first-line support, you may request to be connected with a human staff member instead.

Security

We use a combination of physical, technical, and administrative safeguards to protect the information we collect through the Services. While we use these precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.

Your Options and Rights Regarding Your Information

Your Account: Please visit your account page to update your account information.

Email Unsubscribe: If you do not wish to receive marketing information from us or wish to opt out of future email promotions from us, please contact us at [email protected]. All promotional email messages you receive from us will also include an option to opt out of future email communications. Please note that your unsubscribe request only applies to promotional messages, and not to administrative messages that we are required to send as part of our business relationship. Examples of administrative messages include, but are not limited to, email messages regarding program compliance, urgent updates about weather or health alerts, reminders about confirming departure from a host country, and/or completing a SEVIS check-in.

Ad choices and cookie preferences: You have options to limit the information that we and our partners collect for online advertising purposes.

• You can adjust your cookie preferences at any time using the cookie preference tool available on our websites.
• You may disable cookies in your browser or mobile device using their settings menus. Your mobile device may give you the option to disable advertising functionality. Because we use cookies to support Service functionality, disabling cookies may also disable some elements of our online properties.
• The following industry organizations offer opt-out choices for companies that participate in them: the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Digital Advertising Initiative.

If you exercise these options, you may still see advertising, but it will not be personalized, nor will exercising these options prevent other companies from displaying personalized ads to you. If you delete your cookies, you may also delete your opt-out preferences.

Do Not Track: Your browser or device may include “Do Not Track” functionality. The information collection and disclosure practices and the choices that we provide to you will continue to operate as described in this privacy policy, whether a Do Not Track signal is received.

Interaction with AI tools: Where an interaction with us is handled by an AI tool, you may request to be connected with a human staff member at any time.

Jurisdiction-specific rights: You may have certain rights with respect to your personal information depending on your location or residency. Please see “Privacy Disclosures for Specific Jurisdictions” below. Please contact us to exercise your rights.

Special Information for InterExchange Job Applicants

When you apply for a job with us, we may collect information from you, including:

• Information you provide in connection with your application.
• Information that you make available in your social media accounts.
• Information about you that is available publicly.
• Information that you authorize us to collect via third parties, including former employers or references.

In certain circumstances, you may submit your application for employment through a third-party service that displays our job posting. We do not control the privacy practices of these third-party services. Please review their privacy policies carefully prior to submitting your application materials.

Other Important Information

Data retention

We may store information about you for as long as we have a legitimate business need for it.

Cross-border data transfer

We may collect, process, and store your information in the United States and other countries. The laws in the United States regarding information may be different from the laws of your country. Any such transfers will comply with safeguards as required by relevant law.

Information about children

The Services are intended for users age thirteen and older. We do not knowingly collect information from children. If we discover that we have inadvertently collected information from anyone younger than the age of 13, we will delete that information. Please contact us at [email protected] with any concerns.

Sharing of Medical or Health Information

To the extent that we receive protected health information about you, that information is subject to electronic disclosure to the extent permitted by applicable law.

Privacy Disclosures for Specific Jurisdictions

European Economic Area, United Kingdom, and Switzerland

We process “personal data,” as that term is defined in the European Union’s General Data Protection Regulation (“GDPR”) and the equivalent provisions of UK and Swiss data protection law. Please see the “How We Use Your Information” section above for our lawful bases for processing.

Controller: InterExchange, Inc., 1 State St. Fl 17, New York, NY 10004, USA, is the controller of personal data collected through the Services. You may contact our privacy team at [email protected].

Your rights under the GDPR and equivalent laws

If you are located in the EEA, U.K., or Switzerland, you have the following rights with respect to your personal data:

• Access and Portability: Request access to personal data we hold about you or request transmission of your data to a third party.
• Correction: Request that we rectify inaccurate or incomplete personal data we store about you.
• Erasure: Request that we erase personal data when such data is no longer necessary for the purpose for which it was collected, when you withdraw consent and no other legal basis for processing exists, or when you believe that your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.
• Restriction of processing: Request that we restrict our processing of personal data if there is a dispute about the accuracy of the data; if the processing is unlawful; if the processing is no longer necessary for the purposes for which it was collected but is needed by you for the establishment, exercise, or defense of legal claims; or if your request to object to processing is pending evaluation.
• Objection to processing: Object to processing of your personal data based on our legitimate interests or for direct marketing (including profiling). We will no longer process the data unless there are compelling legitimate grounds for our processing that override your interests, rights, and freedoms, or for the purpose of asserting, exercising, or defending legal claims.
• Transfers: Obtain information about and a copy of the safeguards we use to transfer personal data across borders.
• Complaints: Lodge a complaint with the data protection supervisory authority in your country. Contact details for data protection authorities are available via the European Commission website.

Contact Information, Submitting Requests, and Our Response Procedures

Please contact us if you have questions or wish to take any action with respect to information to which this privacy policy applies.

• Email: [email protected]
• Telephone: 212-924-0446
• Mail: 1 State St. Fl 17, New York, NY 10004

How to Exercise Your Rights or Submit a Request

If you have an online account with us, you can update your account information through your account.

If you would like to request access, modification, correction, or deletion of personal data that you have provided to us or that you believe we may have collected about you, please contact us at [email protected]. We may not be able to delete your personal data without also deleting your user account. You will not be permitted to examine the personal data of any other person or entity. In order to verify your identity, you may be required to provide us with personal data prior to accessing any records containing information about you. We may not accommodate a request to change or delete personal data if we believe doing so would violate any law or legal requirement, or cause the information to be incorrect.

We will honor any legal right that you have to access, modify, or erase your personal information. To request access and to find out whether any fees may apply, if permitted by applicable state, federal, or national law (outside of the United States), please contact [email protected].