Your privacy is critically important to us. At Concordia Theological Seminary (CTSFW), Fort Wayne, we have a few fundamental principles:

• We carefully consider the personal information we ask you to provide and only ask for the information necessary for the operation of our services.
• We store personal information for only as long as we have a reason to keep it.
• We do not share personal information publicly.
• We aim for full transparency on how we gather, use, and share your personal information.

Below is our Privacy Policy, which incorporates and clarifies these principles. It is written in as plain language as possible.

Who We Are and What This Policy Covers

CTSFW is a seminary of the Lutheran Church—Missouri Synod (LCMS). We exist to form servants in Jesus Christ who teach the faithful, reach the lost, and care for all. This Privacy Policy applies to information that we collect about you when you use:

• Our websites (including *.ctsfw.edu, ctsedtech.com, ctsfw.net, and lifeoftheworld.com);
• Any mobile applications developed to assist students, faculty, staff, and constituents; and
• Other users’ websites that use our Services while you are logged in to your account with us.

Throughout this Privacy Policy, we’ll refer to our website, mobile applications, and other products and services collectively as “Services.” If you’d like to learn more about who is the controller of information about you, take a look at the section below on Controllers and Responsible Companies. Please note that this Privacy Policy does not apply to any of our products or services that have a separate privacy policy. Below we explain how we collect, use, and share information about you, along with the choices that you have in respect to that information.

Creative Commons Sharealike License

This Privacy Policy has been adapted from the template made available under a Creative Commons Sharealike license created by Automattic, the creators of WordPress. The original template of this Privacy Policy is available on Github. Automattic welcomes others to copy, adapt, and repurpose it for use. The above links are provided as a courtesy, for convenience, and for informational purposes only; they do not constitute an endorsement or approval by CTSFW of any products, services, or opinions of the corporation or its employees. CTSFW bears no responsibility for the accuracy, legality, or content of the external site or for that of subsequent links. Contact the external site for answers to questions regarding its content.

Information We Collect

We only collect information about you if we have a reason to do so – for example, to provide our Services, to communicate with you, or to make our Services better. We collect information in three ways: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.

Information You Provide to Us

It is probably no surprise that we collect information that you provide to us. The amount and type of information depend on the context and how we use the information. Here are some examples:

• Basic Account Information: We ask for basic information from you in order to set up your account. For example, we require individuals who sign up for a CTSFW.edu account to provide a username, email address, and address. You may provide us with more information, but we do not require that information to create a CTSFW.edu account.
• Transaction and Billing Information: If you attend classes (residential or online), buy something from the bookstore, etc., you will provide additional personal and payment information that is required to process the transaction and your payment, such as your name, credit card information, and contact information. Note that we do not store any credit card or payment information on our servers. All payment transactions are handled by PCI compliant, third-party processors.
• Credentials: Depending on the Services you use, you may provide us with credentials for access to accounts used to support Services you receive, such as access to your Student Portal or MyClasses/MisClases for online course content.
• Communications with Us: You may also provide information to us when you respond to surveys or communicate with our helpdesk about a support question.

Information We Collect Automatically

We also collect some information automatically:

• Log Information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services, such as accessing online course content or making charitable donations on CTSFW.edu.
• Usage Information: We collect information about your usage of our Services. We also collect information about what happens when you use our Services (e.g., page views, support document searches, site searches, and other parts of our Services) along with information about your device (e.g., screen size and browser version). We use this information to get insights into how people use our Services in order to make these Services better and to troubleshoot problems.
• Location Information: We may determine the approximate location of your device from your IP address. We collect and use this information for technical or statistical information, such as calculating how many people visit our Services from certain geographic regions.
• Information from Cookies & Other Technologies: A cookie is a string of information that a website stores on a visitor’s computer and that the visitor’s browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails. CTSFW uses cookies and other technologies like pixel tags to help us identify and track visitors, usage, and access preferences for our Services, as well as track and understand email delivery effectiveness. For more information about our use of cookies and other tracking technologies, including how you can control the use of cookies, please see our Cookie Policy.

Information We Collect from Other Sources

We may also get information about you from other sources. For example, if you create or log in to your CTSFW.edu account through another service (like Google), we will receive information from that service (such as your username, basic profile information, and Friends List) via the authorization procedures used by that service. The information we receive depends on which services you authorize and any options that are available. We may also get information, such as a mailing address, from third-party services about individuals who are not yet our users.

How and Why We Use Information

Purposes for Using Information

We use information about you as mentioned above and for the purposes listed below:

• To provide our Services (for example, to set up and maintain student and constituent accounts, to provide online course content, or to send statements or receipts for charitable contributions);
• To further develop and improve our Services (for example, adding new features that we think our students and constituents will enjoy or will provide more meaningful and timely information);
• To monitor and analyze trends and better understand how users interact with our Services, which helps us improve these Services and make them easier to use;
• To measure, gauge, and improve the effectiveness of our communications and to better understand user retention and attrition (for example, we may analyze how many individuals react to certain news releases or requests);
• To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of CTSFW, our students, constituents, and others, which may result in us declining a transaction or the use of our Services;
• To communicate with you, often through email, to keep you up to date on CTSFW news, about promotions, continuing education, requests for support offered by CTSFW and other associated organizations, or to solicit your feedback; and
• To personalize your experience using our Services, provide content recommendations, and target our messages to groups of our users (for example, those who support a particular program or have been our users for a certain length of time).

Legal Bases for Collecting and Using Information

For those in the European Union, please note that our legal grounds for processing information about you under EU data protection laws are based on: (1) The use is necessary in order to fulfill our commitments to you under our Terms of Service or other agreements with you, or is necessary to administer your account; or (2) The use is necessary for compliance with a legal obligation; or (3) The use is necessary in order to protect your vital interests or those of another person; or (4) We have a legitimate interest in using your information, to do such things as provide and update our Services, to improve our Services, to safeguard our Services, to communicate with you, to measure, gauge, and improve the effectiveness of our education, to better understand user retention and attrition, to monitor and prevent any problems with our Services, and to personalize your experience; or (5) You have given us your consent (for example, the use of cookies to retain user preferences, as described in our Cookie Policy).

Sharing Information

How We Share Information

We do not sell our users’ private personal information. We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:

• Associate Organizations, Employees, and Independent Contractors: We may disclose information about you to our associate organizations, such as the LCMS, our employees, and individuals who are our independent contractors who need to know the information in order to help us provide our Services or to process the information on our behalf. We require our associate organizations, employees, and independent contractors to follow this Privacy Policy for personal information that we share with them.
• Third-Party Vendors: We may share information about you with third-party vendors who need to know information about you in order to provide their services to us or to provide their services to you. This group includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, and postal and email delivery services that help us stay in touch with you, software service vendors who provide our student experience portals and online education solutions, those that assist us with our community building efforts by providing tools that identify specific groups or improve our news and financial campaigns, those that help us understand and enhance our Services, like analytics providers, who may need information about you in order to provide technical or other support services to you). We require vendors to agree to privacy commitments before sharing information with them. Other vendors are listed in our more specific policies (e.g. our Cookie Policy).
• Legal Requests: We may disclose information about you in response to a subpoena, court order, or other governmental request. For more information on how we respond to requests for information about CTSFW.edu users, please see our Legal Guidelines.
• To Protect Rights, Property, and Others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of CTSFW, third parties, or the public at large. For example, if we believe there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
• With Your Consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties you authorize, such as the social media services that you connect to your logins.
• Aggregated or De-Identified Information: We may share information that has been aggregated or reasonably de-identified so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services, and our constituent management provider will pool aggregate contribution information from their non-profit customers to provide these customers with comprehensive national giving data and trends.
• Published Support Requests: If you send us a request via a support email or one of our feedback mechanisms, we reserve the right to publish that request in order to help us clarify or respond to your request or to help us support other users.

Information Shared Publicly

Information that you choose to make public is, by nature, disclosed publicly. At this time, we have no public forum other than that provided through our Facebook, Twitter, YouTube, or Instagram presence. Note that the use of social media is governed by the provider’s privacy policies. We have no control over your social media settings.

How Long We Keep Information

We generally discard information about you when we no longer need the information for the purposes for which we collect and use it (described in the section above on How and Why We Use Information) and we are not legally required to continue to keep it. For example, we keep web server logs that record information about a visitor to our websites, such as the visitor’s IP address, browser type, and operating system, for a minimum of 90 days. We retain the logs for this period of time in order to, among other things, analyze traffic to CTSFW’s websites and to investigate issues if something goes wrong on one of our websites.

Security

While no online presence is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks.

Choices

You have several choices available when it comes to information about you:

• Limit the Information that You Provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services may not be accessible.
• You may opt out of receiving commercial messages from us. Each message we send has an opt-out link as prescribed by the CAN-SPAM Act of 2003. If you opt out of commercial messages, we may still send you other messages, like those about your account, information necessary for students, and legal notices.
• Set Your Browser to Reject Cookies: You can usually choose to set your browser to remove or reject browser cookies before using CTSFW’s websites, with the drawback that certain features of CTSFW’s websites may not function properly without the aid of cookies. For example, cookies are necessary for the use of our online learning tools and Student Portal.
• Close Your Account: Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above. For example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations, such as law enforcement requests, or is reasonably needed for our legitimate business interests.

Your Rights

If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation (GDPR), data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

• Request access to your personal data;
• Request correction or deletion of your personal data;
• Object to our use and processing of your personal data;
• Request that we limit our use and processing of your personal data and
• Request portability of your personal data.

You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you are not able to do that or you would like to contact us about one of the other rights, scroll down to How to Contact Us to find out how to reach us. EU individuals also have the right to make a complaint to a government supervisory authority.

Please note that as an educational institution, we are governed by the Family Educational Rights and Privacy Act (FERPA). In order to protect our student and family rights, any of the above requests require definitive positive identification that you are the person whose data is affected.

Controllers and Responsible Companies

CTSFW’s Services are accessible worldwide. Different associate organizations are the controller (or co-controller) of personal information, which means that they are the organizations responsible for processing that information based on the particular service and the location of the individual using our Services. Depending on the Services you use, more than one organization may be the controller of your personal data. Generally, the “controller” is the organization that entered into the contract with you under the Terms of Service for the product or service you use. In addition, CTSFW is the controller for some of the processing activities across all of our Services worldwide.

CTSFW is controller for all services directly associated with Concordia Theological Seminary, Missionary Formation Certification, and Spanish-speaking Church Worker Formation.

The Lutheran School of Theology (Församlingsfakulteten i Göteborg) is the controller for the MST Gothenburg program.

The LCMS is the controller for rostered church worker information.

How to Reach Us

If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned in the Your Rights section above, please contact us using the “Contact Us” link at the bottom of any page.

Other Things You Should Know

Transferring Information

Because CTSFW’s Services are offered worldwide, the information about you that we process when you use the Services in the EU may be used, stored, and/or accessed by individuals operating outside the European Economic Area (EEA) who work for us, other members of our associate organizations, or third-party data processors. This is required for the purposes listed in the How and Why We Use Information section above. When providing information about you to entities outside the EEA, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy, as required by applicable law. These measures include:

• In the case of US-based entities, entering into European Commission-approved standard contractual arrangements, ensuring they have signed up to the EU-US Privacy Shield,
• In the case of entities based in other countries outside the EEA, entering into European Commission-approved standard contractual arrangements.

Feel free to ask us for more information about the steps we take to protect your personal information when transferring it from the EU.

Ads and Analytics Services Provided by Others

We do not sell advertisements on our sites. We do use Google Analytics to track user traffic to our pages, which helps identify which pages are generally more useful to our visitors. A full description of Google Analytics collection practices can be found in their Data Privacy and Security section. Please note this Privacy Policy only covers the collection of information by CTSFW and does not cover the collection of information by any third-party analytics providers. To opt out of Google’s data collection, see Google’s Opt-Out page.

Visitors to Our Users’ Websites

CTSFW provides a web presence to a limited number of LCMS churches as a free service. We also process information about visitors to these websites on behalf of our users and in accordance with our user agreements. Please note that the processing of that information on behalf of our users for their websites is not covered by this Privacy Policy. We encourage these organizations to post a privacy policy that accurately describes their practices on data collection, use, and sharing of personal information.

Privacy Policy Changes

Although most changes are likely to be minor, CTSFW may change its Privacy Policy from time to time. CTSFW encourages visitors to check this page frequently for any changes to its Privacy Policy. If we make changes, we will notify you by revising the change log below. In some cases, we may provide additional notice, such as adding a statement to our homepage or sending you a notification through email. Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy.

Standard Disclaimer for External Links

These links are provided as a convenience and for informational purposes only; they do not constitute an endorsement or approval by CTSFW of any of the products, services, or opinions of the corporation, organization, or individual. CTSFW bears no responsibility for the accuracy, legality, or content of the external site or for that of subsequent links. Contact the external site for answers to questions regarding its content.

Please note: Web pages on the CTSFW Site containing one or more links to external Internet sites may carry the above statement in its entirety or link to this page, and external links may be followed with this icon.