Babson College Privacy Statement

1. Babson College (“Babson,” “College,” “we,” “us” or “our”) is a U.S.-based institution of higher learning offering undergraduate, graduate and continuing education programs, curriculum content and services in a traditional campus setting and through our Babson.edu websites (collectively, “Sites”), our Babson portals (collectively, “Portals”), and our mobile applications (collectively, “Apps”) (the Sites, Portals and Apps are collectively referred to in this Privacy Statement (defined below) as “Services”). This privacy statement (“Privacy Statement”) explains how we handle and use the personal information we collect about you, our students, past, present and future supporters, applicants of all kinds, faculty, staff, and visitors (collectively, “you” or “your”). Personal information (“Personal Data”) means any information about you from which you can be identified.
2. This section applies to individuals in the EU (for these purposes, reference to the EU also includes the European Economic Area (EEA) countries of Iceland, Liechtenstein and Norway). Please read below for important information on your rights with respect to the Personal Data we hold about you.

The College is committed to your privacy. This Privacy Statement describes our practices regarding the most common ways we handle and use the personal information we collect about you. By accessing or using the Services, you are consenting to our handling and use of your personal information in accordance with this Privacy Statement. If you do not agree to this Privacy Statement, do not access or use the Services.

Some of our Sites, Portals and Apps may have additional terms and practices applicable to privacy and other matters. Any additional terms and conditions will appear on those Sites, Portals and Apps and you should read any such supplemental privacy notices available on those Sites, Portals and Apps for more information on those practices. To the extent of any conflict or inconsistency between any such additional terms and conditions and this Privacy Statement, this Privacy Statement shall govern and control.

If you are in the European Union, Iceland, Liechtenstein or Norway (the “European Economic Area”), please see the RIGHTS APPLICABLE TO INDIVIDUALS IN THE EUROPEAN UNION (EU) section for additional information about ways that Babson may collect, use, share and disclose Personal Data about you.

For more information about this Privacy Statement or to exercise your rights under this statement please contact us at privacy@babson.edu.

WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?

Personal Data

In addition to Personal Data that is automatically collected through cookies and server logs, which track your IP address and the pages you visit (see the section below on “Information Automatically Gathered”), we may request and collect Personal Data that you voluntarily give us when you visit a Site or Portal or use an App to ask a question, request to be contacted, request particular information about or enroll in one of our programs, inquire about or obtain financial aid, apply or are hired to work at the College or participate in alumni activities such as fundraising, submit a form, request access, and/or make a payment. This Personal Data may include:

• Name, title, age and date of birth
• Social Security Number (SSN) only as required by law for applicants for admission and financial aid, employees and for validation purposes
• Babson College OneCard Number
• Contact information such as addresses, city, state, postal code, country of residence, email addresses, home, cellular and other contact telephone number(s)
• Location information
• Campus address and telephone number
• Emergency contact and notification information (names, phone numbers and email addresses)
• Academic credentials
• Academic, leisure or other interests
• Attendance at College events
• Records of communications between you and the College
• Other basic biographic information about you, including social media contact information
• Other information pertinent to your specific interests and activities at Babson

We also collect information you choose to provide to us when you complete any “free text” boxes in our forms (for example, support requests or blogs or forums).

We may collect other information to assist us in maintaining or managing our systems, diagnosing problems, assisting you with a help request, or informing investigations.

Our admissions departments purchase Personal Data from testing and other companies for use in identifying individuals who may be interested in applying for admission to the College or enrolling in a College course or program.

If you provide information to us about any person other than yourself, you must ensure that he or she understands how the information will be used and has given permission to you to disclose it to us and you to allow us, and our outsourced vendors and third parties, to use it.

Automatically Collected Data

When you use the Services the following information is created and automatically logged in our systems:

• Log data: Information (“log data”) that your browser automatically sends whenever you visit the Site, or that the Apps automatically send when you use them. Log data includes your Internet Protocol (“IP”) address, browser type and settings, the date and time of your request, your Babson network IF, and how you interacted with the Services. We may use your IP address to identify the general geographic areas from which you are accessing the Services. We may archive this information for historic records.
• Cookies: Our Site uses cookies and other technologies to make it easier for you to use the Services during future visits, monitor traffic on our Services, and personalize informational, educational and other content. For more information please see the “Cookies and Other Tracking Technologies” section below for more about how we use cookies and similar technologies, and your choices with respect to them.
• Device information: Includes type of device you are using, operating system, settings, unique device identifiers, network information and other device-specific information. Information collected may depend on the type of device you use and its settings.
• Carrier related information: Collection of carrier-related information including the name of your wireless carrier, and IDs related to the cell phone hardware in your phone as well as the network to which the device is connected.
• Platform Specific identifiers: Such as Apple’s Identifier for Advertising and Identifier for Vendor, and Android ID or Android’s advertising identifier.
• Geolocation information: Including precise location data.
• Usage Information: Types of content that you view or engage with, the features you use, the actions you take, the other users you interact with and the time, frequency and duration of your activities.

Social Network or Third Party Plug-ins or Widgets

Our Services may include social network or third party plug-ins or widgets that may provide information to their social networks or third-parties about your interactions with our web pages, even if you do not click on or otherwise interact with the plug-in or widget. The information is transmitted from your browser and may include an identifier assigned by the social network or third party, information about your browser type, operating system, device type, IP address, and the URL of the web page where widget appears. Please read the privacy policies of these sites before you visit them or use their tools to learn what information they collect, use, and share. We are not responsible for the privacy policies or data practices of social network or third party sites or their party plug-ins or widgets.

HOW WE USE YOUR PERSONAL DATA

We use your Personal Data to engage in our nonprofit, institutional, educational and/or research activities and pursue our legitimate interests, in particular:

• To process applications for admission to the College’s undergraduate and graduate programs, employment and enrollment in courses and programs
• To administer and assess all our educational programs
• To fulfill public safety obligations to our faculty, staff and students
• To deliver and administer your educational program, record the details of your studies and activities, (including any placements with external organizations or service providers for study-aboard, internships, experiential, and/or academic coursework taken at another institution), and determine/confirm your academic achievements (e.g. results, prizes)
• To administer the financial aspects of your relationship with us and any funders
• To provide facilities to you (e.g. IT, sport, libraries, accommodation, careers)
• To operate security (including CCTV), governance, disciplinary (including plagiarism and academic misconduct), complaint, audit and quality assurance processes and arrangements
• To support your training, medical, safety, welfare and religious requirements
• To report and/or compile statistics and/or conduct research in either case for internal, statutory or industry reporting purposes
• As part of a research study in which you have agreed to participate as research subject or researcher or in which your existing Personal Data are used
• To connect with you via social media platforms about a variety of matters
• To fulfil and monitor our responsibilities under EEO, immigration and public safety legislation
• To administer HR-related processes, including, advertising for and hiring and maintaining our employee workforce, payroll matters, benefits administration, performance/absence management, disciplinary issues and complaints/grievances
• To notify your designated emergency contact(s) of an emergency or crisis that may affect you and/or the College community
• To send you updates and information about new programs and services, upcoming events or other promotions or news. Where required by law, we will only send you marketing information if you consent to us doing so at the time you provide us with your Personal Data. You may opt out of receiving such communications at any time by clicking the respective links in each promotional email we send you. You may also update your information and communication preferences by [_____________emailing privacy@babson.edu.]
• To respond to inquiries and other requests and/or questions
• If you ask us to be removed from our marketing lists and we are required to fulfill your request, we will retain basic data to identify you and prevent further unwanted processing
• To prevent fraud or criminal activity, abuses and/or misuses of our products or services, and ensure the security of our IT systems, architecture and networks
• For internal recordkeeping purposes
• To better understand how visitors interact with our Services (including through the use of cookies and similar technologies) and ensure that our Services are presented in the most effective manner for you
• To create and analyze aggregated (fully anonymized) information about our donors and other supporters for statistical research purposes in support of our educational mission
• To track user trends and for other purposes described in this Privacy Statement
• To (a) comply with legal obligations and legal process, (b) respond to requests from public and government authorities including public and government authorities outside your country of residence; (c) enforce our terms and conditions; (d) protect our operations; (e) protect our rights, privacy, safety or property, and/or that of you or others; and (f) allow us to pursue available remedies or limit the damages that we may sustain.

HOW WE SHARE AND DISCLOSE YOUR PERSONAL DATA

Sharing and Disclosure Within Babson

Your Personal Data may be shared with other departments and units at the College for the purposes described in this Privacy Statement, including without limitation for the delivery, personalization, and improvement of a variety of services (such as educational, employment, administrative, and/or informational) to you by, through or at Babson and its departments, business units and affiliates; to further the advancement of knowledge through research and academic pursuits; and/or to satisfy local, state and federal laws and regulations.

Before Personal Data are collected for research purposes, you will be provided a consent and/or authorization form relating to the specific research project that explains the types of data collected and purposes for which the Personal Data are processed and shared. In such a case, the description of the collection and use of your Personal Data provided the consent and/or authorization form will replace the information here. The Personal Data collected by our research and others on their behalf is collected for the primary purpose of furthering research and understanding in fields of academic understanding.

Sharing and Disclosure Outside Babson

Except as otherwise described in this Privacy Statement, we will not share, sell, rent, or authorize a third party to use your Personal Data without your permission. We may share your Personal Data in the following circumstances:

• Third Parties and Vendors: To perform any and all of the purposes for which Personal Data was collected as described in this Privacy Statement and/or assist us in meeting any of our institutional needs, your Personal Data may be shared with third-parties and/or vendors including, but not limited to, providers of: analytics, hosting, email communication, social media, and support services; payment and contributions processing; admissions application processing; course platforms; course registration and administration services; course evaluation and assessments; customer relationship management (CRM) services; event registration and coordination services; alumni and donor outreach and engagement services; administrative, information security, technology, and/or technical services (including, without limitation Amazon Web Services and Google); providers of recruitment models; enrollment verification; and degree verification and electronic transcript delivery services; as well as to financial institutions; insurance companies; other educational institutions; marketing and advertising firms; employee background check firms; service providers that complete transactions or perform services on our behalf or for your benefit; governmental bodies; ranking organizations; collaborating researchers, research entities and/or research institutions; law enforcement authorities; private organizations with oversight over the College; and/or to enable your participation at events or in other opportunities; and/or to your accommodate special needs. Following our instructions, these parties may access, use, process or store your Personal Data in the course of performing their duties for us. They are contractually prohibited from using or sharing your Personal Data for any purpose other than providing their services to us.
• Legal Requirements: If required to do so by law pursuant to valid legal process, applicable regulation or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend our rights or property, and/or those of you or others (iii) act in urgent circumstances to protect the personal safety of you or others, or the public, or (iv) protect us against legal liability.
• Research: Before Personal Data are collected for research purposes, you will be provided a consent and/or authorization form relating to the specific research project that explains the types of data collected and purposes for which the Personal Data are processed and shared. In such a case, the description of the collection and use of your Personal Data provided the consent and/or authorization form will replace the information here. The Personal Data collected by our research and others on their behalf is collected for the primary purpose of furthering research and understanding in fields of academic understanding.

UPDATING PERSONAL DATA ABOUT YOU

If any of the Personal Data you have provided to us changes, (e.g., your email address) or if you become aware of any inaccurate Personal Data about you, please let us know by sending an email to privacy@babson.edu. or contacting the Office of Information Security, at Babson College, Office of Information Security, 231 Forest St., Babson Park, MA 02457. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

There are some instances where we may not remove or revise Personal Data. For example, we may decline to remove or revise the following types of information, including, but not limited to:

• information required to be maintained by the College as part of student or employment records, or pursuant to local, state or Federal law or regulation, or in performance of contractual obligations; or
• information compiled in reasonable anticipation of, or for use in a civil, criminal or administrative action or proceeding.

The College will respond to such requests as promptly as possible no later as permitted under applicable law.

SECURITY

To perform the functions listed above, we use risk-assessed administrative, technical and physical security measures to protect your Personal Data from unauthorized access, use, disclosure or destruction. Where feasible, systems that solicit or display personally-identifiable information are protected by authentication and authorization controls and Web-based experiences involving Personal Data are generally secured by SSL (Secure Sockets Layer protocol) with 128-bit encryption. We use firewalls and regular monitoring to evaluate any attempts at accessing our systems without permission. However, no transmission over the internet nor method of storage is 100% secure. Therefore, while we strive to protect your Personal Data, we cannot guarantee its absolute security.

RETENTION

We consider our relationship with our learning community to be lifelong. This means we will keep your Personal Data until such time as you tell us we no longer wish to keep in touch or pursuant to our retention schedules which authorize retention for as long as reasonably necessary for the purposes described in this Privacy Statement, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longest.

If you have elected to receive marketing communications from us, we retain information about your marketing preferences until you opt out of receiving these communications and in accordance with our policies.

To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

PUBLICLY POSTED INFORMATION

This Privacy Policy does not apply to any information you elect to post to any public areas of the Sites, Portals or Apps. This includes, but is not limited to, comments to Babson College blogs or fora. Comments posted to public areas may be viewed, accessed and used by third parties subject to privacy practices and policies of those third parties.

LINKS TO OTHER WEBSITES

The Services may contain links to other websites not operated or controlled by us (“Third Party Sites”), including social media websites and services. We are not responsible for the privacy policies, data practices or content of Third Party Sites. By providing these links we do not imply that we endorse or have reviewed Third Party Sites. Read the privacy policies of Third Party Sites to understand their privacy practices and policies.

FORWARDING EMAIL: PRIVATE EMAIL ADDRESS

If you forward email from your College-assigned email address to a non-Babson College email address, we may send email to either or both addresses. We may also share your non-Babson College email address with service providers inside and outside the College as provided in this Privacy Statement.

CHILDREN

The Services are not intended to be directed to children under 13 years of age. Babson College does not knowingly solicit or collect Personal Data from users under the age of 13. If you believe we have inadvertently collected information about a child under 13 through the Services, please contact us at privacy@babson.edu and we will endeavor to delete the information.

CHANGES

The Privacy Statement may be amended from time to time. Any such changes will be posted to this page. Please regularly review the Privacy Statement for any changes. Where and as required by law, we will notify you if we make any significant changes.

DO NOT TRACK

Do-Not-Track is a public-private initiative that has developed a “flag” or signal that an Internet user may activate in the user’s browser software to notify websites that the user does not wish to be “tracked” by third-parties as defined by the initiative. The online community has not agreed on what actions, if any, should be taken by the websites that receive the “do not track” signal, and therefore Do-Not-Track is not yet standardized. Our Services do not alter behavior or change services if any of them receives a “do-not-track” flag or signal from your browser.

COOKIES AND OTHER TRACKING TECHNOLOGIES

We and our third party service providers and vendors use certain technologies to collect information about your use of our Services to operate the Services, conduct analytics, improve your user experience and for advertising purposes. By choosing to use our Services you, among other things, also agree to this Cookies statement and the use of cookies by us as described in this Privacy Statement. You have the ability to accept or decline cookies by changing your browser settings. If you choose to decline cookies, some features of our Services may not work properly.

Cookies

Unless you block them, our Services use “cookies,” web beacons, and similar technologies to collect or receive information from our Sites, Portals and Apps and elsewhere on the Internet and use that information to provide measurement services and target ads. If you block all cookies, you may not be able to access Services. Cookies are text files placed on your device when you visit our Sites that help us understand how you use our Site and save your preference for future visits. We also compile aggregate data about Site traffic and Site interaction so that we can offer betters Site experiences in the future. Some of these Cookies are managed by third parties we do not control, such as Google Analytics. Some cookies remain on your computer after you leave the Sites, Portals or Apps. (These are sometimes called “persistent” cookies).

We use the following cookies:

• Session/Strictly necessary cookies – These are temporary cookies that remain in the cookie file of your browser until you close the browser. They are used to operate the Services and provide users with the Services available through our Services, including log-in and access to secure areas. These cookies are essential for using and navigating the Site and without them basic functions of our Site would not work. Because these cookies are strictly necessary to deliver the Site and the Services, you cannot refuse them.
• Functionality/Persistent cookies – Enhance the performance and functionality of the Site and our Services but are non-essential to the use of our Services.
• Analytical/customization cookies – Third party cookies used to better understand the behavior of the users on our Services and improve our Services accordingly, for example by making sure users are finding what they need easily. Google Analytics – A web analytics service provided by Google Inc. (“Google”). The information collected by Google (including your IP address) will be transmitted to and stored by Google on servers in the United States. How long a Google Analytics cookie remains on your computer or device depends on what it is and what it is used for. Some Google Analytics cookies expire at the end of your browser session, while others can remain for up to two years. You can prevent your data from being collected by Google Analytics on our Site by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser.

Advertising – We sometimes use cookies from third parties that enable such parties to serve ads to you based on your use of the Services. These interest-based advertisements are also known as “online behavioral advertising.” Online behavioral advertising is advertising that is directed to you based, at least in part, on your Internet browsing behavior across websites and over time. Although we do not share Personal Data with the third parties that conduct interest-based advertising operations on our behalf, these third parties and their affiliates do collect certain information as a result of their javascript “tags” and other technologies such as web beacons or pixels being used on our Site. The information that they collect includes the names of web pages you view (URL’s), unique identifiers, your IP address, timestamp, and certain types of technical information.

Local shared objects (“Flash” cookies) are associated with non-browser software like Flash Player. Local shared objects can be used like cookies to distinguish your device from others, but will not be deleted or blocked using browser cookie controls. Please visit adobe.com to learn how to delete and block Flash cookies.

HTML5 local storage enables browsers to distinguish your device from others and remember data that may be important for the functioning of the website. Typically HTML5 local storage is only deleted if all Internet history, cache, and cookies are deleted. Please check your browser software for how to delete HTML5 local storage.

E-tags are used to prevent duplicative downloading of content to your browser, which can enhance browser performance. E-tags use unique identifiers for content that can also be used to distinguish your browser in certain instances from others. Typically e-tags are only deleted if all Internet history, cache, and cookies are deleted. You should check your browser software for how to delete e-tags in your particular case.

Our mobile applications may use the following technologies for features, services, advertising, or analytics:

• Collection of device identifiers, such as Android ID, MAC address, or UDID
• Collection of geolocation, including precise geolocation

Sharing Cookies and Technical Information with Third Parties

We have relationships with authorized third-party providers whose services are accessed through a Portal or Site. We may automatically send one or more of your cookies to the third-party site or service to enable you to access third-party services without re-entering your Babson user ID and password, or other required information, each time.

Cookies may be set by parties other than the College. These “third party cookies” may, for example, originate from websites such as YouTube, Facebook, Twitter or other social media services for which the College has implemented “plug-ins.” Since the cookie policies of these sites change over time, you should determine their policies by visiting the privacy pages of those sites directly.

Your Privacy And Choices

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links on the following popular browsers for guidance on how to modify your web browser’s settings:

• Internet Explorer
• Mozilla Firefox
• Google Chrome
• Apple Safari

If you reject, turn off or block cookies, as stated above some parts of our Sites, Portals and Apps may not function correctly. Also, blocking cookies will not stop third-parties from collecting IP address, data stored in “Flash” cookies, and certain other types of technical information that may uniquely identify your browser.

You can make decisions about your privacy and the ads you receive. You can choose to disable cookies through your individual browser options (some are mentioned above) or you can opt out of the collection and use of this information through tools like the Network Advertising Initiative Opt-out page. You can control whether companies serve you on-line behavioral advertising by visiting the Digital Advertising Alliance (“DAA”) website and using its opt-out: http://www.aboutads.info/choices/. The DAA opt-out requires that cookies not be blocked in your browser. If you are located in the EU, visit the European Interactive Digital Advertising Alliance’s Your Online Choices opt-out tool here.

As an alternative to the DAA opt–out, you can also elect to block browser cookies from first parties (such as those from our website) and browser cookies from third parties (such as advertisers) by using the cookie blocking options built into your browser software.

Digital Marketing and Ad Networks

Third Parties may collect Personal Data from other sources. Some third parties involved in advertising operations may maintain their own proprietary consumer databases that allow them to personally identify or track website visitors. Other third parties have proprietary technologies to determine what additional devices you may use, on which it can display relevant advertisements.

RIGHTS APPLICABLE TO INDIVIDUALS IN THE EUROPEAN UNION (EU)

Data Controller. Babson College is the data controller for your Personal Data, and may be contacted at Babson College, ATTN: Office of Information Security, 231 Forest St, Babson Park, MA 02457, U.S.A. and also at privacy@babson.edu. Any questions, comments, requests, concerns about this Privacy Statement or other privacy-related matters should be directed to the foregoing email or physical address.

Your Rights. Subject to EU law, you may have the following rights in relation to your Personal Data:

• Access: You have the right to request a copy of the Personal Data that we hold about you. There are exceptions to this right, so that access may be denied, if for example, making information available to you would reveal Personal Data about another person. If you require additional copies, we may need to charge a reasonable fee.
• Rectification: Although we aim to keep your Personal Data accurate and complete, if your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, and if you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
• Erasure: You may ask us to erase your Personal Data in some circumstances, such as where we no longer need it or you withdraw your consent (where applicable). We will retain a core set of Personal Data to ensure we do not contact you inadvertently in the future, as well as any Personal Data necessary for the College’s archival proposes. We also may need to retain some Personal Data for legal purposes, including without limitation, U.S. IRS compliance. If we shared your information with others, we will alert them to the need for erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
• Restrict Processing: You may ask us to restrict or “block” the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
• Porting: You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
• Objecting: You may ask us at any time to stop processing your Personal Data, and we will do so:
• If we are relying on a legitimate interest (described below) to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing; or
• If we are processing your Personal Data for direct marketing.
• Rights in relation to automated decision-making: You have the right to be free from decisions based solely on automated processing of your Personal Data, unless this is necessary in relation to a contract between you and us or you provide your explicit consent to this use.
• Withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw, in whole or in part, that consent at any time, but this will not affect any processing of your data that has already taken place.
• Lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

You may, at any time, exercise any of the above rights by emailing privacy@Babson.edu. To protect your Personal Data that we hold, we may also request further information to verify your identity when you seek to exercise these rights.

Our legal bases for Processing your Personal Data: We rely on a number of legal bases to lawfully process your Personal Data. We consider the processing of your Personal Data to be:

• necessary for the performance of our contractual obligations with you (e.g., to manage your student or employee experience and welfare while you are enrolled at or employed by Babson);
• necessary in order to take steps at your request prior to entering a contract with you;
• necessary for compliance with a legal obligation (e.g., equal opportunity and nondiscrimination monitoring);
• necessary for the performance of tasks we carry out in the public interest (e.g., teaching and furthering research and understanding in fields of academic study);
• necessary for the pursuit of the legitimate interests of the College or a third party (e.g. to create and sustain relationships with our alumni; conduct fundraising activities; provide, improve and customize our educational offerings; and/or employee services); or
• With your consent, where applicable, such as for marketing activities and/or the provision of information to you, where required by the law. Where our legal basis for processing your Personal Data relies on your consent, we will obtain your consent at the appropriate time and you can withdraw this at any time. In the limited circumstances where we might use Personal Data to carry out wholly automated decision-making that affects you, we will inform you of the automated processing at the point where any such data is collected.

1. We will retain your Personal Data for as long as is necessary for the purposes set forth in this Privacy Statement unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights or otherwise comply with legal obligations. Upon expiration of the applicable retention period, we will destroy your Personal Data in accordance with applicable laws and regulations.
2. creating and maintaining relationships with our students and alumni;
3. conducting fundraising activities;
4. working to prevent fraud and other criminal activity on or through our Services;
5. working to ensure the safety and security of our students, faculty, staff and others;
6. providing, improving and customizing our educational offerings for you;
7. administration of our operations;
8. promoting the successes of our current and former students;
9. offering attendance to events and opportunities to volunteer; and
10. understanding how our online platforms are used.

Where we are processing Personal Data based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with the law or that represents the statute of limitation for legal claims that could arise from the contractual relationship.

Where we are processing Personal Data based on the public interest, we generally retain information for the period of time that continues to serve that underlying interest.

Where we are processing Personal Data based on our legitimate interests, we generally will retain the Period Data for a reasonable period of time based on the particular interest, taking into account your fundamental interest and data protection rights and freedoms.

Where we are processing Personal Data based on your consent, we generally will retain the information for the period of time necessary to carry out the processing activities to which you have consented, subject to your right, under certain circumstances, to have certain of your Personal Data erased (as described above).

“Legitimate interests” means our interests in conducting our business as an institution of higher education, and managing and delivering the best Services to you. For example, our “legitimate interests” include but are not limited to the following:

We will not use your Personal Data for these activities where the impact on you overrides our interests, unless we have your consent or those activities are otherwise required or permitted by law.

Collecting, Using, Sharing and Disclosing Personal Data. In addition to the statements made under this section, we collect, use, share and disclose your Personal Data in the ways described in this Privacy Statement under the headings “What Personal Data Do We Collect About You,” “How We Use Your Personal Data,” and “How We Share and Disclose Your Personal Data” and the related sub-headings.

1. The statements made under the headings entitled “Overview,” “Security,” “Publicly Posted Information,” “Links to Other Websites,” “Forwarding Email,” “Children,” “Do Not Track,” and “Cookies and Other Tracking Technologies” and also apply to you.
2. We may change this Privacy Statement from time to time. If we make any significant changes in the way we treat your Personal Information we will make this clear on our Site or otherwise as required by law. You can determine when this Privacy Statement was last updated by checking the Latest Update date in this Privacy Statement. Please check back regularly to see any updates our changes to this Privacy Statement.

Consent to Transfer of Personal Data. The College is primarily located in the United States. With respect to transfers of Personal Data outside the EU, the College may rely on applicable derogations. By providing information directly to the College, you consent to the transfer of your Personal Data outside of the EU and/or the EEA to the United States and/or other countries outside of the EU and EEA. You understand the current laws and regulations of the United States, including without limitation, any State of the United States, and other countries may not provide the same level of protection as the data privacy laws of the EU or the EEA. In some circumstances, the College may enter into standard contractual clauses governing the import or exports of Personal Data or rely on your consent. In all cases, the College endeavors to apply suitable safeguards to protect the privacy and security of your Personal Data and to use it in a manner that is consistent with the Privacy Statement. Unless you have a contract with us, you do have not a statutory or contractual obligation to provide Personal Data to us.