91Ʋ College Privacy Statement
91Ʋ College is committed to protecting your privacy and the personal information you share with us in the usual course of business. This privacy statement describes in general terms how 91Ʋ College collects personal information from you and governs the usage of that information. Nothing in this statement should be construed as an intent to violate any state or federal legal requirements. Where in conflict, the College will adhere to state and federal regulations while staying committed to protecting and respecting the privacy of all individuals regardless of their geographical location.
When this statement mentions “the College,” “we,” “us,” or “our,” it is referring to 91Ʋ College as the party responsible for your information under this Privacy Statement.
Information we collect
We collect personal, identifiable information through the 91Ʋ.edu website and other College platforms in a manner as described in this statement. If we have your consent to do so or if the information is required for legal processes or to fill internal business needs, we may sell, trade, or transfer to third parties the information you provide to us. 91Ʋ College has no obligation with respect to non-personally identifiable information.
91Ʋ College does not intentionally nor knowingly collect or solicit personal information from children under the age of 13 without prior parental/guardian consent or notification. Such notification will include an opportunity for the parent/guardian to prevent use of the information and/or participation in the activity.
We may collect the following types of personal information about you, including information you provide, information we obtain from third parties, or otherwise:
- your name and contact information such as address, email address, and telephone number, as well as your date of birth, social security number (or other tax identification number), passport number, driver’s license details, country of domicile, and your nationality;
- information relating to your education and employment history, the school(s) and other colleges or universities you have attended and places where you have worked, the courses you have completed, dates of study, examination results, and any conduct concerns. If you are a student, we will also keep records relating to assessments of your work, details of examinations taken, your predicted and actual examination grades, and other information in your student record;
- information about your family or personal circumstances and both academic and extracurricular interests, for example where this is relevant to the assessment of your suitability to receive a scholarship, eligibility for FAFSA, or to provide you with appropriate care;
- sensitive personal information, including:
- information concerning your health and medical conditions (g. disability and dietary needs, care from our health and wellness programs, accommodations for a disability);
- criminal convictions (where provided and authorized in connection with application to the institution or upon application for employment;
- information about your racial or ethnic origin, your gender, your religion, or similar beliefs.
Unless you take steps to browse anonymously or opt-out (see Disabling web tracking below) 91Ʋ College, like most digital platforms, tracks web browsing patterns to inform understanding of how our websites are being used. As a result, we may collect certain information automatically when you use 91Ʋ College websites or services. For example, the following information about you may be automatically collected: browser type, data regarding network connected hardware (devices), IP address, general region, pages visited, and use of 91Ʋ College websites/services. This information is collected in some sections of 91Ʋ College-owned websites by Google Analytics which uses cookies to help us analyze how users use our sites (see Cookies below for more information).
How we collect your information
We may collect your personal information in a number of ways, for example:
- from the information you provide to us when you interact with us before attending, for example when you express your interest in studying at 91Ʋ College;
- from the information you provide to us during event registration and ticketing;
- when you apply to study at 91Ʋ College and complete enrollment forms, applications, and other admission procedures such as immigration related information;
- when you communicate with us in person, by telephone or email, or via our website, for example to make inquiries or raise concerns;
- when you apply for employment or volunteer experiences at 91Ʋ College;
- in various other ways as you interact with us during your time as a student, employee, donor, parent, volunteer, sponsor, or third party of 91Ʋ College, including through photography, social media, and digital image/video;
- from third parties, for example from your previous or current school, College, or employers who may provide a reference about you or who may sponsor your studies or from services where you may have opted-in to receive communication from undergraduate or graduate programs (e.g. standardized testing services or honor societies/student associations).
How we use your information
We may process your personal information because it is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract. In this respect, we use your personal information for the following:
- to interact with you before you are enrolled as a student or before employment as part of the admissions or staff recruitment process (e.g. to send you information or answer inquiries about our courses);
- to interact with you before you decide to donate to the College (e.g. to communicate with you regarding donor opportunities);
- once you have enrolled or been employed, to provide you with the services as set out in our College policies, procedures or contracts;
- to deal with any concerns or feedback you may have;
We may also process your personal information because it is necessary for the performance of our tasks carried out in the public interest or because it is necessary for our or a third party’s legitimate interests. In this respect, we may use your personal information for the following:
- to provide you with educational services which may not be set out in our policies or procedures but which nevertheless are a part of our academic and educational mission;
- to provide you with services usually provided by an employer which may not be set out in our College policies, procedures, or contracts but which nevertheless are a part of our mission and regular course of business;
- to monitor and evaluate the performance and effectiveness of the College, including by training our staff or monitoring their performance;
- to maintain and improve the academic, corporate, financial, real estate, and human resource management of the College;
- to promote equality and diversity throughout the College;
- to seek advice on our rights and obligations;
- to recover money you owe to us;
- for fundraising purposes.
We may also process your personal information for our compliance with our legal obligations. In this respect, we may use your personal information for the following:
- to meet our compliance and regulatory obligations;
- to meet local, state, and federal laws;
- for the prevention and detection of crime;
- in order to assist with investigations (including criminal investigations) carried out by the police and other competent authorities.
We may also process your personal information where:
- it is necessary for medical purposes (e.g. medical diagnosis, provision of health or social care or treatment, or a contract with a health professional);
- it is necessary to protect your or another person’s vital interests; or
- we have your specific or, where necessary, explicit consent to do so.
Sharing your information with others
For the purposes referred to in this privacy notice and relying on the basis for processing as set out above, we may share your personal information with certain third parties. You are given the opportunity to opt out of some of these data sharing arrangements, for example when you register with us, but you should consider carefully the possible impact of doing this. Unless an opt-out is in place for certain data sharing arrangements, we may disclose limited personal information to a variety of recipients. There are three categories in which the sharing of personal information may fall: (1) where 91Ʋ College is legally required to share information; (2) where the student has a relationship that involved 91Ʋ College and another organization/institution and sharing of information between 91Ʋ and the other is necessary or authorized by the student; or (3) where the sharing is authorized by the student. The following personal information that may be shared is organized by these categories:
1 | ||
---|---|---|
Student sponsors (e.g. student loan company, research sponsors); | 2 Student sponsors (e.g. student loan company, research sponsors); | |
Professional and regulatory bodies in relation to the confirmation of qualifications, professional registration and conduct, and the accreditation of courses; | 2 Current or potential education providers (for example, where you take part in an exchange program or transfer to another institution). | 3 Current or potential education providers (for example, where you take part in an exchange program or transfer to another institution). |
Government departments and agencies where we have a statutory obligation to provide information; | ||
Crime prevention or detection agencies; | ||
Parents, guardians, and next-of-kin (where there is a legitimate reason for disclosure in compliance with FERPA). |
*If you are a citizen of the EU or a non-EU citizen located within the EEA, then additional information specific to the EU legal framework for processing your personal information is conducted in accordance with Regulation 2016/679, the General Data Protection Regulation (GDPR).
Your Rights Under GDPR
GDPR gives EU data subjects additional rights over how their personal data is collected, processed, and transferred by data controllers and processors. If you fall under GDPR protection then, upon request and in certain cases, you may have the right to, among other things:
- obtain confirmation from the data controller as to whether or not your personal data is being processed, where it is being processed, and for what purpose it is being processed;
- access to your personal data and related information that an organization has collected about you;
- correct any of your personal information that is inaccurate;
- know the reason for your data being collected and the categories of personal data that an organization processes;
- know the retention period an organization will store your personal data;
- restrict or limit how we use your personal information;
- request the limiting of the organization’s processing;
- object to the processing of your personal information: you have the right to lodge a complaint with a supervisory authority in the member state of your habitual residence;
- request your personal information to be deleted;
- obtain a copy of your personal information in an easily accessible format;
- transmit your personal information to another controller, including to have it transmitted directly where technically feasible;
- withdraw your consent to the processing of your personal information, if processing is solely based on your consent;
- be notified by a breach notification within 72 hours of first having become aware of a breach.
If you withdraw your consent to the use or sharing of your personal information for the purposes set out in this Privacy Statement, you may not have access to all (or any) of the services and we might not be able to provide you all (or any) of the services. Please note that, in certain cases, we may continue to process your personal information after you have withdrawn consent and requested that we delete your personal information, if we have a legal basis to do so. For example, we may retain certain information if we need to do so to comply with an independent legal obligation, if it is necessary to do so to pursue our legitimate interest in keeping the services safe and secure, or if deleting the information would undermine the integrity of a research study in which you are enrolled.
GDPR requires organizations whose core activities consist of processing operations which require regular and systematic monitoring of data subjects on a large scale or of special categories of data or data relating to criminal convictions and offenses to appoint a Data Protection Officer. For that reason, 91Ʋ College has appointed Matt Hawks as its Data Protection Officer.
For additional information, please see our GDPR information page.
Web tracking
This website uses a variety of methods (i.e. cookies and tracking pixels) to improve the users experience while visiting the website. These tools help the College to better understand user behavior; the tools tell us which part of our website you have visited and measure the effectiveness of web searches.
As do many other institutions and organizations, 91Ʋ College dedicates some sections of its website for use by third-party services, such as Google analytics, to track web-browsing patterns. This helps us to better understand how our website is being used. The information is generated by the use of “cookies” and similar technologies and includes data in order to compile website activity and other material relating to navigating throughout our site.
Cookies are small data files that are placed on your computer or mobile device that allow us to collect certain information whenever you visit or interact with our services. Cookies are used to make websites work properly or more efficiently, as well as to provide information to us.
91Ʋ College uses first party, third party, session, and persistent cookies. First party cookies are set by the site you are visiting while third party cookies are set by a third party site separate from the site you are visiting. Session cookies are stored in memory and are permanently lost when the browser is closed. Persistent cookies are stored on your device between browser sessions in order to allow us to remember your preferences or actions across various sites.
Disabling web tracking
Should you decide to disable web tracking, you have a variety of tools to control cookies, including:
- Browser Controls
By changing your web browser settings you have some control to block, reject, and delete most cookies. However, by choosing to reject cookies you may not be able to take advantage of certain features, services, applications, or tools made available using these technologies through 91Ʋ College. - Do Not Track
You should check with your provider or with your preferred browser regarding how to disable web tracking. Some web browsers have the ability to transmit “Do Not Track” signals. Your browser choice and disabling web tracking may impact your experience with our website. - Links to other websites
The 91Ʋ College website(s) may contain links to other websites not affiliated with the College. This Privacy Statement does not apply to these websites nor are we responsible for the privacy practices of these other sites. We encourage you to read the privacy statements of other sites for assurance that their practices safeguard your privacy.
Data retention
91Ʋ College keeps the data it collects in accordance with the retention periods of applicable federal law and the College’s Record Retention Policy.
Changes to this Privacy Statement
91Ʋ College has the discretion to update this privacy statement at any time. Privacy conditions and compliance change over time. This document is updated to the best of our ability. When we do, we will revise the updated date at the bottom of this page. We encourage you to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. It is your responsibility to review this privacy statement periodically and become aware of modifications.