1. Introduction

This Privacy Policy explains how The Scriptorium Initiative (“TSI,” “we,” or “us”) collects, uses, and protects your personal information when you use our website and services. We are committed to respecting your privacy and handling personal data responsibly.

2. Information We Collect
2.1 Information You Provide

We may collect:

• Name
• Email address
• Billing information (processed by third-party payment processors)
• Account credentials
• Course enrollment and completion data
• Communications with us

2.2 Automatically Collected Information

We may collect:

• IP address
• Browser type and device information
• Pages visited and usage data
• Cookies and similar technologies

3. How We Use Your Information

We use your information to:

• Provide access to courses and content
• Process payments and transactions
• Communicate about courses, updates, or support
• Administer continuing education participation and records
• Improve our services and Site functionality
• Comply with legal and regulatory obligations

We may send administrative or educational communications related to your enrollment. You may opt out of non-essential communications at any time.

4. Legal Bases for Processing (GDPR)

For users in the European Economic Area (EEA), United Kingdom, or similar jurisdictions, we process personal data under the following legal bases:

• Performance of a contract (e.g., course enrollment and delivery)
• Consent (e.g., optional communications or cookies)
• Legitimate interests (e.g., site improvement, security)
• Compliance with legal obligations

For purposes of the General Data Protection Regulation (GDPR), Hellenic College, Inc. is the data controller for personal data processed through The Scriptorium Initiative.

5. Payment Processing

Payment information is not stored on our servers at any time. Payments are handled securely by Stripe, subject to their own privacy policies.

6. Cookies and Analytics

We may use cookies and analytics tools to:

• Understand Site usage
• Improve performance
• Remember user preferences

You may disable cookies in your browser settings; however, some features may not function properly.

7. Sharing of Information

We do not sell personal information.

We may share information:

• With service providers necessary to operate the Site (hosting, email, payment processing)
• To comply with legal or regulatory requirements
• To protect the rights, safety, or integrity of TSI, Hellenic College, Inc., or others

8. International Users and Students

If you access the Site from outside the United States, your information may be transferred to and processed in the U.S., where data protection laws may differ from those in your jurisdiction. By using the Site, you consent to such transfer and processing.

Participation in The Scriptorium Initiative’s continuing education programs does not create an academic student record with Hellenic College, Inc. unless explicitly stated. Continuing education records maintained by TSI are administrative and educational in nature and are not governed by the Family Educational Rights and Privacy Act (FERPA) unless otherwise required by law.

9. Data Retention

We retain personal information only as long as necessary to fulfill educational, administrative, continuing education, or legal purposes.We retain personal information only for as long as necessary to fulfill educational, administrative, continuing education, legal, promotional, and institutional development purposes. This includes retaining personal contact information to communicate with individuals about programs, events, fundraising initiatives, and other activities related to the mission and advancement of Hellenic College, Inc.

10. Data Security

We implement reasonable administrative, technical, and physical safeguards to protect personal data. However, no system is completely secure, and we cannot guarantee absolute security.

11. Your Rights

Depending on applicable law, you may have the right to:

• Access your personal data
• Correct or update inaccurate data
• Request deletion or restriction of processing
• Object to certain processing activities
• Withdraw consent where applicable
• Requests may be sent to the contact email below. Requests will be responded to within the timeframes required by applicable law.
• If you are located in the European Economic Area, you also have the right to lodge a complaint with your local data protection authority.

12. Children’s Privacy

This Site is not directed to children under 13. We do not knowingly collect personal information from children.

13. Changes to This Policy

We may update this Privacy Policy periodically. Updates will be posted on this page with a revised effective date.

14. Contact Us

The Scriptorium Initiative
Hellenic College, Inc.
50 Goddard Avenue
Brookline, MA 02245
scriptorium@hchc.eduadmin@thescriptoriuminitiative.org