Effective date: February 25, 2019
This privacy notice describes how Champlain College Incorporated of 163 South Willard St., Burlington, VT 05401 ("we", "our", "us" or the "College") collects, processes, and protects personal information about you through www.champlain.edu and all other College websites that link to this policy (the "Services"), and describes your rights in relation to this information. Personal information is information, or a combination of pieces of information, that could reasonably allow you to be identified.
[For details about how we collect and otherwise process personal information in the context of admissions and throughout the application process, please refer to our Admissions Privacy Notice, available here: https://www.champlain.edu/privacy/admissions-privacy-notice-for-eu-applicants.
1. Personal information we collect and use
We collect personal information about you from a variety of sources, including from you directly (e.g. when you contact us or request information), information we generate about you in the course of our relationship with you (e.g. information collected from cookies and other similar technologies as described below) and information we collect about you from other sources, including commercially available sources, such as public databases (where permitted by law). Note that we may be required by law to collect certain personal information about you, or as a consequence of any contractual relationship we have with you. Failure to provide this information may prevent or delay the fulfillment of these obligations.
1.1 Information we collect directly from you
The categories of information that we collect directly from you include the following:
(a) personal details (e.g. name, date of birth);
(b) contact details (e.g. phone number, email address, postal address or mobile number for yourself, your parents or guardians, and/or other emergency contacts);
(c) account details (e.g. username and password);
(d) transaction details (e.g. when you make purchases or respond to offers);
(e) communications (e.g. when you participate in message boards or forums, participate in polls or surveys, write a review or contact us with a question, comment or request);
(f) gender identity, if you consent to provide such information by answering an optional question on a Residential Life housing form;
(g) immigration information (for international students) (e.g. passport and visa information)
(h) employment information (e.g. your resume, work history and job title);
(i) information about your family/guests (e.g. names of relatives who may be attending an event);
(j) information about your preferences (e.g. those related to housing and academic and extracurricular activities);
(k) photographs for use in identification; and
(l) emergency contact details (e.g. names of your emergency contacts and their contact information and information about your next of kin).
1.2 Information we generate about you
In addition, we may generate the following categories of personal information about you in the context of your use of the Services:
(a) Student identification numbers;
(b) Records of our interactions with you;
(c) Internal notes, including notes about your inquiry into our programs and services.
1.3 Information we collect about your use of the Services
The following are examples of other categories of information which we automatically collect from you over time and across different websites when you use the Services, including through the use of "cookies", which are small text files that the Services save on your computer using your web browser and access when you return:
(a) Technical information collected from your computer or mobile device (e.g. your IP address, browser type, operating system);
(b) Information about your usage of our Websites (e.g. the pages you visit when using the Services, the search terms you enter on the Services, how often you use the Services, and the pages you access before and after accessing the Services);
(c) Information which we generate as a result of your use of the Services (e.g. our understanding of your interests as a result of your use of the Services and whether you are a regular or occasional user of the Services).
For more information about cookies and how we use them on our websites, please refer to our Cookies Policy here: https://www.champlain.edu/privacy/cookie-policy.
1.4 Information we collect from other sources about you
The following are examples of the categories of information we collect from other sources, including, but not limited to, lead generation and marketing companies; educational testing agencies; other academic institutions; and the federal government:
(a) personal details (e.g. name, date of birth);
(b) contact details (e.g. phone number, email address, postal address or mobile number);
(c) details about advertising preferences (e.g. products purchased, interaction with advertisements online);
(d) feedback, recommendations, or evaluations from your teachers or other individuals; and
(e) academic details (e.g. academic history or transcripts provided by other institutions or third party digital credential services; testing information; college application history).
1.5 Sensitive information we collect and use
Some of the categories of personal information that we collect are considered special categories of personal data under European Union law. In particular, we may process the following types of sensitive information:
Information about your health, which is either provided by your health care providers (if you authorize such information being provided to us) or obtained from information you provide by answering a questionnaire at the time of registration or enrollment, or as requested by the Health Center (e.g. medical history, physician's report, information about disabilities or related accommodations, information about allergies or dietary restrictions, and health insurance information). To the extent we process health information, we do so to comply with obligations under social protection laws (e.g. to provide disability accommodations) or, where not required by law, to provide medical services under the responsibility of authorized medical professionals or when such processing is necessary to protect the vital interests of you or another person. In some contexts, this information may be processed with your consent;
1. How we use your personal information and the basis on which we use it
We use your personal information for the following purposes:
- Identification and authentication: We use your identification information to verify your identity when you access and use our Services and to ensure the security of your personal information. This is so we can comply with our contractual obligations to you.
- Operating the Services: We process your personal information to provide the Services you have requested. This is so we can comply with our contractual obligations to you.
- Improving our Services: We analyze information about how you use our Services to provide an improved experience for our customers of all our Services, including product testing and site analytics. It is in our legitimate business interests to use the information provided to us for this purpose, so we can understand any issues with our Services and improve them.
- Communicating with you: We use your personal information when we communicate with you, for example if we are providing information about changes to the terms and conditions or if you contact us with questions throughout the application process; or for sending you Champlain College newsletters and publications. It is in our legitimate interests that we are able to provide you with appropriate responses and provide you with notices about our Services. Where required by law we will obtain your consent before sending you marketing communications.
- Marketing: we use your personal information to build a profile about you and place you into particular marketing segments in order to understand your preferences better and to appropriately personalize the marketing messages we send to you. It is in our legitimate interest to provide more relevant and interesting advertising messages. Where necessary, we will obtain your consent before sending such marketing messages.
- Complying with our obligations: we process your personal information to, for example, carry out fraud prevention checks or comply with other legal or regulatory requirements, where this is explicitly required by law.
- Customizing your experience: when you use the Services, we use your personal information to improve your experience of the Services, such as by providing interactive or personalized elements on the Services and providing you with content based on your interests. It is in our legitimate interests to provide you with a customized experience.
- Admissions and Financial Aid: we use your personal information to analyze and make decisions about admissions and financial aid. This is for purposes of the performance of the pre-contractual relationship we have with you and to serve our legitimate interests in selecting a diverse and qualified student body.
- Responding to emergencies, such as contacting you or your family in the event of an incident. This processing is necessary to serve our legitimate interests in supporting the health and wellbeing of our students;
- For purposes of program planning and development. This processing is necessary to serve our legitimate interests in the efficient management and administration of our academic programs and extracurricular activities;
- Keeping our campus and associated facilities safe and secure. This processing is necessary to serve our legitimate interests in protecting our students, property and facilities; and
- Keeping our records accurate and up-to-date. This processing is necessary to comply with legal obligations and to serve our legitimate interests in efficient management and administration.
We may also anonymize your personal information in such a way that you may not reasonably be re-identified by us or any other company, and use this anonymized information for any other purpose.
2. How and when we Share Your Personal Information
- With each other: Champlain College Incorporated and Champlain College Dublin Limited share personal information with each other for the purposes set forth above. To the extent we collect information in person in Europe, we may share personal information about you with other Champlain College personnel located at our campus in the United States or elsewhere.
- Service providers and business partners: we share your personal information with our service providers and business partners that perform marketing services and other business operations for us for the purposes set forth above. For example, we partner with companies to process secure payments, fulfill orders, optimize services, serve online behavioral advertising, send newsletters and marketing messages, support email and messaging services, and analyze information. These service providers and business partners include advertising agencies and fraud prevention agencies which will use your personal information only in the ways described in this policy.
- Where required by law: we share your personal information with law enforcement agencies, courts, other government authorities or other third parties where we believe necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
- In the context of a transaction: we share your personal information with potential transaction partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business. Should such a sale or transfer occur, we will use reasonable efforts to obligate the entity to which we transfer your personal information to use it in a manner that is consistent with this Privacy Notice.
3. Your rights over your personal information
Where applicable under local law, you may have certain rights regarding the personal information we hold about you. These may include the rights to access, correct, delete, restrict or object to our use of, or receive a portable copy in a usable electronic format of your personal information. You also may have a right to lodge a complaint with your local data protection or privacy regulator. We encourage you to contact us at the contact information set forth below to update or correct your information if it changes or if the personal information we hold about you is inaccurate. Where you have provided your consent to any use of your personal information, and where applicable under local law, you can withdraw this consent at any time.
Please note that we may require additional information from you in order to honor your requests.
If you would like to discuss or exercise any rights you have under law, please contact us at the contact information set forth below.
We do not currently respond to web browser "do not track" signals. For more information about these signals, visit www.allaboutdnt.org.
4. Automated decisions about you
If you browse our website, we also make automated decisions about you based on your personal information in order to deliver personalized offers, discounts or recommendations to send you based on your browsing history, interactions with our marketing campaigns and academic areas you have expressed interest in.
Subject to local legal requirements and limitations, you can contact us to object to our use of automated decision-making.
5. Information Security and Storage
We implement physical, technical, and organizational security measures designed to safeguard the personal information we process through the Services. These measures are aimed at providing on-going integrity and confidentiality for your personal information. We evaluate and update these measures on a regular basis. However, no information system can be 100% secure, so we cannot guarantee the absolute security of your information.
We retain your personal information for as long as we have a relationship with you. When deciding how long to keep your personal information after our relationship with you has ended, we take into account our legal obligations. We also retain records to investigate or defend against potential legal claims. If there is any information that we are unable to delete entirely from our systems for technical reasons, we will put in place appropriate measures to prevent any further processing or use of the information.
6. International Data Transfer
Your personal information may be transferred to, stored, and processed in a country (such as the United States), that is not regarded as providing the same level of protection for personal information as the laws of your home country. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to provide adequate protections for your personal information. For more information on the appropriate safeguards in place and to obtain a copy of such safeguards, please contact us at the contact information set forth below.
7. Contact Us
Champlain College Incorporated is the controller responsible for the personal information we collect and process. We are represented in the European Union by Champlain College Dublin Limited. If you have questions or concerns regarding the way in which your personal information has been used, please contact our Data Privacy Officer at firstname.lastname@example.org We are committed to working with you to obtain a fair resolution of any complaint or concern about your privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to make a complaint to the appropriate data protection authority. Contact information for the EU data protection authorities can be found at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
8. Changes to the Policy
We may modify or update this privacy notice from time to time. If we make any revisions that materially change the ways in which we process your personal information, we will notify you of these changes before applying them to that personal information.