We respect the privacy of website users and have developed this Policy to demonstrate our commitment to protecting your privacy.
SCOPE OF THIS POLICY
This Policy is intended to describe our practices with respect to the collection, use, and maintenance (“Processing”) of personal information relating to users of our website (identified below).
For the purposes of this Policy, the term “Site” shall refer to www.sju.edu and all sites contained within that domain. This policy does not apply to sites not falling within the www.sju.edu domain, including, but not limited to, any site within the domains sites.sju.edu, admission.sju.edu, nest.sju.edu, and sjuhawks.com, which are governed by separate privacy policies. We encourage you to review the privacy policies for those sites to understand their information practices.
In this Policy, “personal information” means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural, or social identity. Personal information does not include aggregate information or de-identified information, meaning that the information can no longer be attributed to an identifiable natural person without the use of additional information.
Personal information is required for us to be able to provide certain services to you. In addition, some of the services we provide require that we disclose your personal information to third parties, such as to companies and organizations that help us to provide our services. If you are not willing to provide your personal information and have it disclosed to third parties in accordance with this Policy, you will not be able to use our services.
Our Site may contain links to other websites that do not operate under this Policy. These third-party websites may independently solicit and collect personal information from you and, in some instances, provide us with information about your activities on those websites. We encourage you to review the privacy statements of all third-party websites you visit to understand their information practices.
While we strongly support the protection of privacy on the Internet, we do not have control over, and cannot be responsible for, the actions of other third parties. We encourage you to review each such third party’s privacy statement and understand its privacy practices before providing personal information directly to it.
PERSONAL INFORMATION WE COLLECT
As described more fully below, we collect personal information to operate effectively and provide you with the best experience with our services and the Site. You provide some of this information directly, such as when you create a profile or submit a request for information. We get some of your information, such as your IP address, by recording how you interact with our Site. We may also get information about you from service providers or other third parties.
We may receive and collect certain personal information automatically, as outlined elsewhere in this Policy, including analytics regarding our Site, information your Internet browser automatically sends when you visit our Site, and information collected by cookies and web beacons. We may collect personal information that can identify you such as your name and email address, and other information that does not identify you.
Information Provided by You
We may ask for and collect personal information about you such as your name, address, email address, birth date and telephone number. We also may request information about your interests and activities, your gender and age, and other demographic information.
The most common of these circumstances where you would provide personal information include the following:
- Creating a profile: In order to use certain features of our Site, some users may be required to create a password-protected user profile and provide us with personal information. Similarly, when you request information or submit an application for admission, you may be asked to submit personal information as part of your profile. We will store and use this information to administer the programs and services in which you choose to participate, and as permitted by this Policy.
- Using Our Site: Our Site may provide you with the ability to enter certain other personal information to help us provide or tailor our services to you.
- Contacting Us: When you contact us – for example, to request information or submit an application – we may ask you to provide, or confirm, personal information so that we can better serve you.
Information that We Collect From You On Our Site
We also may use various technologies to collect information from your computer or device and about your activities on our Site.
- Information collected automatically. We may automatically collect information from you when you visit our Site. This information may include your IP address, your browser type and language, access times, the content of any undeleted cookies that your browser previously accepted from us, referring or exit website address, internet service provider, date/time stamp, operating system, locale and language preferences, and system configuration information.
- Cookies. When you visit our Site, we may assign your computer one or more cookies to facilitate access to our Site and to personalize your online experience. Through the use of a cookie, we also may automatically collect information about your online activity on our Site, such as the web pages you visit, the links you click, and the searches you conduct on our Site. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies please note that you may not be able to sign in or use some of the interactive features offered on our Site. A cookie is a small text file that is stored on a user’s computer for record keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Site. A persistent cookie remains on your hard drive for an extended period of time. For example, when you sign in to our Site, we will record your user or member ID, which is your email address, and the name on your user profile in the cookie file on your computer. We store your unique member ID in a cookie for automatic sign-in. This cookie is removed when you sign-out. For security purposes, we will encrypt the unique member ID and any other user or member account-related data that we store in such cookies. In the case of sites and services that do not use a user or member ID, the cookie will contain a unique identifier. We may allow our authorized service providers to serve cookies from our Site to allow them to assist us in various activities, such as doing analysis and research on the effectiveness of our Site, content and advertising. You may delete or decline cookies by changing your browser settings (click “Help” in the toolbar of most browsers for instructions). If you do so, some of the features and services of our Site may not function properly.
- Other technologies. We may use standard Internet technology, such as web beacons and other similar technologies, to track your use of our Site. We also may include web beacons in promotional email messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer our Site visitors to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities. Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies. Unlike cookies, which are stored on the user’s computer hard drive, web beacons are embedded invisibly on web pages (or in email) and are about the size of the period at the end of this sentence. Web beacons may be used to deliver or communicate with cookies, to count users who have visited certain pages and to understand usage patterns. We also may receive an anonymous identification number if you come to our Site from an online advertisement displayed on a third-party website.
Information Collected From Other Sources
We may also obtain both personal and non-personal information about you from advertising companies, and ad networks, contractors and other third parties and add it to our profile information or other information we have collected. Examples of such information that we may receive include updated address information and browsing history. We may combine this information with information we collect through our Site or from other sources.
HOW WE USE PERSONAL INFORMATION
As described below, we use the personal information we collect for a variety of purposes, and the legal basis for our processing of personal information will depend on the specific context in which we collect it.
We may use information that we collect about you as follows:
- to send you important information regarding our relationship with you or regarding the Site, including, but not limited to, application and enrollment status, changes to our terms, conditions, and policies, and other administrative information;
- to ensure our compliance with federal, state, or local laws including, but not limited to, the Higher Education Act;
- for our operational purposes, such as application and admissions processing, data analysis, audits, recordkeeping, developing new services, enhancing the Site, improving our services, identifying Site usage trends, optimizing your experience on the Site;
- to investigate, prevent, or take other action regarding illegal activity, suspected fraud, or other wrongdoing;
- to protect and defend the rights, property or safety of the University, our Site users, our employees, or others;
- to comply with applicable law or cooperate with law enforcement;
- to enforce our Site terms and conditions or other agreements or policies;
- to establish or exercise our legal rights or to defend against legal claims; and
- if we intend to collect and use personal information for another purpose, we may seek your permission at the time the information is collected.
We may use any information that does not personally identify you, your computer, or your device, for any purpose.
Lawful Basis for Processing (GDPR)
If the European Union General Data Protection Regulation (“GDPR”) applies, our lawful basis for processing your personal information will depend on the personal information concerned and the specific context in which we collect it.
When we have collected your personal data to provide you with services that you have requested, our legal basis for the processing of that personal data is that it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract. If you refuse to provide us with your personal data, you may be unable to obtain the services from us that you requested.
We also collect and process personal information about you as necessary to provide educational and other services, meet our contractual and legal obligations, and/or fulfill our other legitimate interests (when not overridden by your data protection interests or fundamental rights and freedoms).
If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided below.
How Long We Retain Your Personal Information
We will retain your personal information for as long as is needed to fulfill the purposes set forth in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
SHARING OF PERSONAL INFORMATION
We share your personal information as necessary to provide the services you request, including sharing information with third party service providers; when required by law; to protect rights and safety, and with your consent.
We may share personal information with:
- Authorized service providers: We may share your personal information with our authorized service providers that perform certain services on our behalf. These services may include providing customer service and assistance communications, performing operations analysis, supporting our Site functionality, and supporting other features offered through our Site. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes.
- Other situations: We also may disclose your information:
- in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us;
- to ensure compliance with applicable federal, state, or local laws including, but not limited to, the Higher Education Act;
- when we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of the University, our Site users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our website terms and conditions or other agreements or policies;
- in connection with a substantial organizational transaction, such as the sale of assets, a divestiture, merger, or consolidation; and
- when you provide us with your consent to share your information with third parties.
Third-Party Privacy Policies
Any third parties to whom we may disclose personal information may have their own privacy policies which describe how they use and disclose personal information. Those policies will govern use, handling and disclosure of your personal information once we have shared it with those third parties as described in this Policy. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties. These entities or their servers may be located either inside or outside the United States.
Aggregated and Non-personal Information
We may share aggregated and non-personal information we collect under any of the circumstances set forth in this Policy. We may also share it with third parties to develop and deliver targeted advertising on our Site and on websites and apps of third parties. We may combine non-personal information we collect with additional non-personal information collected from other sources.
WHERE YOUR INFORMATION IS PROCESSED
We are based in the United States. No matter where you are located, we will process your personal information in the United States. The laws of the United States governing data protection may not be as comprehensive or as protective as the laws in the country where you live.
YOUR PRIVACY RIGHTS
How You Can Access Your Information
If you have a profile with us, you have the ability to review and update your personal information online by logging into your profile via the Site. You can also review and update your personal information by contacting us. More information about how to contact us is provided below.
Your Choices About Collection and Use of Your Information
You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Site because such information may be required in order for you to create a profile or receive important communications from us.
At any time you can choose to no longer receive communications from us by modifying your email preferences by selecting the “Opt-Out” link found in the footer of the communication or on our Site and following the instructions or contacting us at email@example.com with the word “unsubscribe” in the email subject line.
Notice for Students about Data Rights and Choices
If you are an SJU student, you may have additional rights under the federal Family Educational Rights and Privacy Act (“FERPA”). For more information about FERPA, please visit: https://www.sju.edu/ferpa.
GDPR Privacy Rights
If you are an individual located in the European Union, you may have additional rights available to you under applicable laws, including:
You have the right to request access to your personal information, and the rectification of inaccurate personal information concerning you. You have the right to obtain the deletion or the restriction of processing of your personal information in certain circumstances, including when the information is no longer necessary in relation to the purposes for which it was collected or otherwise processed, except when we are required by law to maintain or otherwise process your personal information, for the establishment, exercise, or defense of legal claims, or for the protection of the rights or another person. You may have the right to request that we stop processing your personal information and/or to stop sending you marketing communications. In certain circumstances, you may have the right to be provided with your personal information in a structured, machine readable and commonly used format and to request that we transfer the personal information to another data controller without hindrance. Where our processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal.
You may exercise these rights by contacting us using the contact information provided below. To protect your privacy and security, we may take steps to verify your identity before taking action on your request.
You also have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work, or place of an alleged infringement of the applicable data protection law.
OTHER IMPORTANT INFORMATION
Below, you will find additional privacy-related information you may find important.
The security of your personal information is important to us. We follow generally accepted standards (including by taking physical, electronic and procedural measures) to protect the personal information provided to us.
While we are focused on the security of your personal information and follow strict standards, processes, and procedures that are designed to protect your personal information, you must remember that the Internet is a global communications vehicle open to threats, viruses, and intrusions from others and so we cannot promise, and you should not expect, that we will be able to protect your personal information at all times and in all circumstances.
Users should also take care with how they handle and disclose their personal information and should avoid sending personal information through insecure email. Please refer to the Federal Trade Commission’s website at http://www.ftc.gov for information about how to protect yourself against identity theft.
No Rights of Third Parties
This Policy does not create rights enforceable by third parties.
Changes to this Policy
We will occasionally update this Policy to reflect material changes in our privacy practices. If we make any material changes in the way we collect, use, and/or share your personal information, we will notify you by posting the modified Policy on our Site and indicating at the top of the Policy the date it was last updated. We may also notify you by sending you an email if we have your email address on file. We encourage you to review the Policy each time you visit our Site to see if this Policy has been updated since your last visit and to make sure you understand how your personal information will be processed.
If you have any questions about this Policy or our privacy practices, please contact us by email or postal mail as follows:
Office of the General Counsel
5600 City Ave
Philadelphia, PA 19131
Personal Information Our Company Collects and How It Is Used
a. Introduction. We collect information in different ways from Visitors and Members who access the various parts of our Services and the network of websites accessible through our Services. This includes personally identifying information such as names, usernames, postal and email addresses, phone numbers, billing information (such as a credit card number), the type of device being used to access the Services, the content you watch, and other personal information. We use this information primarily to provide a customized experience as you use our Services. We also use this information to customize the content and layout of our Services, to improve our content, for editorial and feedback purposes, and for recordkeeping. We generally do not share this information with third parties. However, we may disclose personal information collected if we have received your permission beforehand or in very special circumstances, such as when we believe that such disclosure is required by law or other special cases described below. In order to access certain content, features, services, products, or benefits on our Services, you may be required to provide us with certain information, including some types of personally identifying information such as your name, postal and email addresses, interests, and phone number. If you do not wish to provide such information through our Services, you may not be able to obtain certain content, features, services, products, or benefits of our Services. From time to time, we may need to contact you regarding information you submitted to us, updates to our Services, and new products or services. You agree that we may use your personal information for such contact with you. We may also desire to contact you for market research purposes or to provide you with marketing information that we believe would be of particular interest. If you wish to opt-out of receiving promotional emails at any time, please click the “unsubscribe” link at the bottom of the email.
b. Registration. Members may be asked to provide certain personal information when they sign up for our Services. This may include your name, username, physical and email addresses, phone number, billing information (such as a credit card number), the type of device being used to access the Services, and other personal information. The personal information collected from Members during the registration process is used to manage each Member’s account (such as for billing purposes) and as set forth above. This information is not shared with third parties, unless specifically stated otherwise or in special circumstances as described below.
c. Partners and Sponsors. We may offer you products and services in conjunction with a third party, such as an affiliate, an independent contractor, a non-affiliated partner of our company, or a sponsor of our Services. To provide you with these products and services, the third-party partners and sponsors may collect and maintain personal information. In these instances, you will be notified before any such data is collected or transferred, and you may decide not to use that particular service or feature. Additionally, we may share non-identifying and aggregate information, but not personal information, with such third parties in order to administer the products or services offered. In instances where we jointly promote our Services with a third party, we may provide the third party with certain personal information (such as the names, usernames, postal and email addresses, and other personal information of persons who become Members as a result of the joint promotion) in order to provide and assess the results of the promotion. In this instance, personal information may not be used by the third party for any other purpose.
d. Online Shopping. If you order services or products directly from Green Flower, we will use the personal information you provide only to process that order. We do not share this information with outside parties except to the extent necessary to complete that order. At some websites linked to our Services, you can purchase third-party products and services or register to receive materials, such as a newsletter, catalog, or new product and service updates. In many cases, you may be asked to provide contact information, such as your name, username, physical and email addresses, phone number, and credit/debit card information. If you complete an order for someone else, such as an online gift order sent directly to a recipient, you may be asked to provide information about the recipient, such as the recipient’s name, address, and phone number. Our company has no control over the third parties’ use of any personal information you provide when you purchase products or services from a third-party website or register to receive materials from a third party. Please exercise care when doing so.
e. Online Advertisements. We may display online advertisements. We do not share personal information about our Visitors and Members with these advertisers. However, we do share aggregated and non-identifying information with these advertisers about our Visitors and Members, including information collected through the registration process as well as through online surveys and promotions. Additionally, in some instances, we use this aggregated and non-identifying information to deliver tailored advertisements. For instance, an advertiser tells us the audience they want to reach and provides us an advertisement tailored to the audience. Based upon the aggregated and non-identifying information we have collected, we may then display or send the advertisement to the intended audience.
f. Responses to Email Inquiries. When Visitors or Members send email inquiries to us, we reply using the return email address provided. We do not use the return email address for any other purpose, and we do not share the return email address with any third party.
g. Voluntary Customer Surveys. We may periodically conduct surveys. We encourage our Visitors and Members to participate in these surveys because they provide us with important information that helps us to improve the types of products and services we offer and how we provide them to you. We keep your personal information and survey responses confidential. If a third party conducts the survey for us, we require that third party to keep your personal information and survey responses confidential. Participation in our surveys is voluntary. We may aggregate survey responses to create broader, generic responses to the survey questions (such as gender, age, residence, hobbies, education, employment, industry sector, or other demographic information). We then use the aggregated information to improve the quality of our Services and to develop new services and products. This aggregated, non-personally identifying information may be shared with third parties.
h. Special Cases. We do not to use or share your personal information in ways unrelated to the ones described above without also providing you an opportunity to opt out or otherwise prohibit such unrelated uses. However, we may disclose personal information about Visitors or Members, or information regarding your use of the Services or websites accessible through our Services, for any reason if, in our sole discretion, we believe that it is reasonable to do so, including for collections-related and credit-related purposes to credit agencies, collection agencies, and merchant database agencies; as required by law enforcement or to satisfy laws such as the Electronic Communications Privacy Act, the Child Online Privacy Act, applicable regulations, or governmental or legal requests for such information; to disclose information that is necessary to identify, contact, or bring legal action against someone who may be violating our Terms of Service or Acceptable Use Policy or other user policies; to operate the Services properly; and to protect our company, our Members, and our Visitors.
2. “Cookies” and How Our Company Uses Them
3. Public Forums
Please remember that any information you may disclose in any Member directory, or any other public areas of our websites or the Internet, becomes public information. You should exercise caution when deciding to disclose personal information in these public areas. We assume no liability for the accuracy of such information, no duty to update or correct such information, and no liability for such communications arising under the laws of copyright, libel, privacy, obscenity, or otherwise.
4. Our Company’s Commitment to Children’s Privacy
Protecting children’s privacy is especially important to us. It is our policy to comply with the Children’s Online Privacy Protection Act of 1998 and all other applicable laws. Therefore, we restrict our Services to persons eighteen (18) years old or older. YOU MUST BE EIGHTEEN (18) YEARS OLD OR OLDER TO ACCESS THIS WEBSITE. IF YOU ARE UNDER EIGHTEEN YEARS OF AGE, YOU ARE NOT PERMITTED TO ACCESS THIS WEBSITE FOR ANY REASON. DUE TO THE AGE RESTRICTIONS FOR USE OF THIS WEBSITE, NO INFORMATION OBTAINED BY THIS WEBSITE FALLS WITHIN THE CHILD ONLINE PRIVACY ACT (COPA) AND IS NOT MONITORED AS DOING SO.
5. Our Company’s Commitment to Data Security
Services and websites we sponsor have security measures in place to protect the loss, misuse, and alteration of the information under our control. While we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining this information. Moreover, the security and confidentiality of any communication or material transmitted through the Internet or any wireless network, including via our Services, email messages, or text messages, cannot be and is not guaranteed. You acknowledge that the technical processing and transmission of content via our Services may be transferred unencrypted and may involve (i) transmissions over various networks; and (ii) changes to conform and adapt to technical requirements of connecting networks or devices. Accordingly, we are not responsible for the security of information transmitted via the Internet or any wireless network.
6. California Residents
Under California Civil Code Section 1798.83 (the “Shine the Light” law), California residents who provide personal information in obtaining products or services from Green Flower are entitled to request and obtain from us once per calendar year information about the customer information about them that we have shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2018 will receive information regarding 2017 sharing activities). If you are a California resident and would like a copy of this information, please submit a written request to: Green Flower Media, Inc. Attn: California/Shine the Light 4744 Telephone Road, Suite 3-289 Ventura, California 93003
8. Revisions to this Policy