The University of the South PRIVACY POLICY Privacy Policy PRIVACY NOTICE As a student, prospective student, alumnus, employee, prospective employee, research subject, or customer of the University of the South, your privacy is important to us. It is our policy to protect you and your family from unauthorized use of information provided in the course of doing business with us. Information provided by you will be used only for the educational, research, philanthropic and other legitimate nonprofit purposes of the University. We will not give away, sell or otherwise disclose any information that personally identifies you, except as necessary to perform service and with appropriate safeguards for the privacy and security of your information. Sensitive personal information will be shared with third parties only with your consent unless required or otherwise allowed by federal, state or international law or regulations. INFORMATION PROVIDED TO US The University receives information from you as needed to process transactions such as admissions, registration, financial aid, bill payment, research and employment processing. The University may receive “Personal Information” (which is information that can be used to identify or contact a specific individual, such as your name, email address and IP address), demographic or other information (such as your school, gender, age or birth date and zip code and information about your interests and preferences), and for some purposes “Sensitive Personal Information” (which includes race, ethnic origin, religious or philosophical beliefs, health data, sexual orientation, and criminal convictions).1 We will also receive payment information (typically, credit card account information) if you choose to enroll in courses or purchase products or services through the University. We gather information when you enter and/or submit that information through an online form and/or similar method. We also gather information through “cookies” as described below. Finally, we may receive information about you from third parties, such as schools, employers, parents/family members or references. Your personally identifiable Personal Information and Sensitive Personal Information may be used by us to provide information and services and to fulfill the legitimate educational nonprofit interests of the University. INFORMATION WE COLLECT ABOUT YOU The University website passively gathers information about you through cookies, pixel tags, and other technologies. The information gathered may include: Your computer’s IP address Individual pages accessed within a University website Access and session times Type of browser software and operating system you are using This information generally is used as aggregate data to help us maintain our website, enhance our website, detect problems, determine trends, maintain security, and overall, to assist us in improving the offering of information and services. Your IP address may also be used to identify your specific interests and to provide you with additional information. The University website uses three methods to collect this data: 1) cookies, 2) third-party tracking services, 3) server logs. Cookies are used to help manage secure website sessions such as online forms or surveys. A cookie is a piece of data that is either maintained only for the duration of a particular session visit or is stored on the user's computer to support future visits. We use both types of cookies. In addition, the University also uses third-party tools or services such as Google Analytics to collect, monitor, and analyze visitor data in aggregate. This data is gathered through cookies set by the third-party service. Third-party tracking services (cookies) may also be transmitted to other third parties such as Facebook so that you may see advertisements from the University when you visit other websites.2 The University web servers create logs about site usage that contain basic user information such as IP address, and date and time of access in order to monitor site usage. HOW WE USE YOUR INFORMATION The information provided by you will be used for the University’s legitimate institutional purposes. We may use your information in one or more of the following ways: To communicate with you To provide the information or services you requested To conduct statistical analysis To further the mission of the University Other uses with your consent INFORMATION SHARING WITH THIRD PARTIES The University will share your information with third parties under the following circumstances and conditions: We are compelled to do so by federal, state and/or international law or regulations We need to share information to protect your interests in the event of an emergency and you are incapacitated and unable to provide consent We have the express permission of the user to share Sensitive Personal Information to fulfill contractual or other legitimate purposes of the University To provide you with additional information that may be of interest to you and is related to the University mission, such as charitable giving opportunities We need to disclose it to service providers with whom the University has contracted to support the administration of University operations and/or to process transactions on behalf of the University. Information shared with third parties is subject to the imposition of appropriate contractual provisions regarding the security of your information and the prevention of unauthorized re-disclosure of your information. HOW WE RETAIN YOUR DATA Data will be retained and deleted in accordance with applicable state, federal and international law and the University’s data retention standards. Your information will be deleted upon your request unless applicable law prevents the University from deleting the information or if the information retained by the University at the time of your request is necessary for the University to fulfill the mission or critical functions of the University. HOW WE PROTECT THE SECURITY OF YOUR DATA To protect against the loss, misuse, theft, or otherwise unauthorized access of personally identifiable information, as well as to protect the overall integrity of all information and services offered, we maintain stringent security measures for our websites and associated systems. We take technical, contractual, administrative, and physical security steps to protect personally identifiable information and associated systems. In certain instances, such as when logging in and/or when you provide credit card information in the purchasing of products or services, Secure Sockets Layer (SSL) encryption technology may be further employed to protect your personally identifiable information. Although we take appropriate measures to protect personally identifiable information, we cannot guarantee that this information will never be accessed in a manner that is inconsistent with this policy. CHANGES TO OUR PRIVACY POLICY The University of the South reserves the right to amend this Privacy Notice at any time, for any reason, without notice to you. Your continued use of the University website indicates your acceptance of any changes to the University’s privacy policy. Any changes will be published here, and you should check our website to access our current Privacy Notice. This Privacy Notice was last updated on December 20, 2018. YOUR RIGHTS You have the right to request access to, a copy of, rectification, restriction in the use of, or erasure of your information in accordance with all applicable law. The erasure of your information shall be subject to the retention periods and in accordance with applicable state, federal and international law. If you have provided consent to the use of your information, you have the right to withdraw consent without affecting the lawfulness of the University’s use of the information prior to receipt of your request. You may exercise these rights by contacting privacy@sewanee.edu. Information sent from the European Union will be transferred out of the European Union to the University. If you feel the University has not complied with applicable foreign law regulating such information, you have the right to file a complaint with the appropriate supervisory authority in the European Union. CONTACT US Questions, concerns, requests, or complaints regarding this Privacy Notice and the processing of personal information by the University of the South should be directed to privacy@sewanee.edu. At the point that you provide us with Sensitive Personal Information, you will be requested to affirmatively consent to our use of the Sensitive Personal Information for the purpose for which it is provided. The first two of these methods may involve the collection of data through cookies. You may refuse the use of cookies by selecting the appropriate settings on your browser or operating system; however, please note that if you do this you may not be able to use the full functionality of this website. 1 At the point that you provide us with Sensitive Personal Information, you will be requested to affirmatively consent to our use of the Sensitive Personal Information for the purpose for which it is provided. 2 The first two of these methods may involve the collection of data through cookies. You may refuse the use of cookies by selecting the appropriate settings on your browser or operating system; however, please note that if you do this you may not be able to use the full functionality of this website. 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