Juniata Privacy Policy

9/01/18

 

Privacy Policy Overview

This Policy explains how we may Process your information. This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of your information, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make. 

Juniata College is an institute of higher education involved in education and community development. In order for Juniata College to educate its domestic and foreign students and provide community services, it is essential and necessary, and Juniata College has a lawful basis, to collect, process, use, and/or maintain the personal data of its students, employees, applicants, and others involved in its educational and community programs. These activities include, without limitation, admission, registration, delivery of classroom, field, and study abroad education, grades, communications, employment, research, development, program analysis for improvements, and records retention.  Juniata College owns, operates, or provides access to several interactive websites, mobile and connected applications, and other online interactive features and services, including, but not limited to, academic, residential, employment, and alumni systems (collectively “Services”).

This Policy applies to all information collected about you by Juniata College, regardless of how it is collected or stored, and describes, among other things, the types of information collected about you when you interact with the Services, how your information may be used, when your information may be disclosed, how you can control the use and disclosure of your information, and how your information is protected.

This Policy does not cover the practices of third parties who may provide information about you to Juniata College. 

Juniata College takes seriously its duty to protect the personal data it collects or processes. In addition to the College’s overall data protection policy, the European Union General Data Protection Regulation (“GDPR”) imposes obligations on entities, like Juniata College, that collect or process personal data about people in the European Union (“EU”). The EU GDPR applies to personal data collected or processed about anyone located in the EU, regardless of whether they are a citizen or permanent resident of an EU country. Juniata College is committed to comply with the GDPR in the College’s processing of Personal Information.  Among other things, the GDPR requires Juniata College to:

  1. Be transparent about the personal data it collects or processes and the uses it makes of any personal data;
  2. Keep track of all uses and disclosures it makes of personal data; and
  3. Appropriately secure personal data.

In this Policy:

  • Personal Information” means information about a living individual that identifies or could identify the individual.
  • Processing” means the collection, use, or sharing of such Personal Information, whether in paper or electronic form.

 

1. Information We May Obtain From You

Our Website

Our website collects certain data automatically when you visit the website or use any of our applications, including your IP address, browser type, and type of device.  You may also enter Personal Information into form fields on our website and submit that information to us.  We collect this information to analyze traffic and functionality of our website, to respond to your requests, and to provide you with information.

Admissions and Financial Aid

When you apply for admission to Juniata College, we collect and process various types of Personal Information through your application and the application process.  We may solicit additional information through interviews or correspondence.  This information may include your contact information, descriptive and demographic information that you may provide to us, and personal and family financial information.

This information is used primarily to evaluate your application for admission and your eligibility for financial aid, and, if you are admitted and enroll, to provide you with educational and academic services.  This information is processed in order to meet our contractual obligations with you, for the legitimate interest of offering Services to you, and as necessary to comply with our legal obligations.

Once you are admitted to Juniata College, we will continue to use your Personal Information and will generate additional information from and about you to provide educational programs and Services to you, such as academic and co-curricular records.  We also collect your image for student identification and may collect and display photographs captured at a College event or activity.

Alumni and Donors

We collect and use Personal Information about alumni, donors, and prospective donors for the purpose of informing them regarding news and information relevant to the College and to engage with them through interactions, events, gifts, or donations.  If you were a student or studied at the College, some of the information from your student records will be transferred to our alumni records. 

This information may include your contact information, descriptive and demographic information that you may provide to us, information about your family members, personal and family financial information, and payment information.  It may also include your image, such as a photograph that you provided to us or an image captured at a College event or activity. 

This information is processed in order to provide you with opportunities to engage with the College and its students and/or alumni, to communicate with you regarding the College’s Services, to request and receive your donations, and to maintain our relationship with you.  This processing is on the basis of our legitimate interest in maintaining alumni and constituent relations, to meet our contractual obligations (for example, by receiving a payment from you), and to comply with our legal obligations (such as providing tax information).

Employees and Job Applicants

We collect Personal Information if you apply for employment with the College.  This information may include your contact information, personal information (including criminal history), information about your family for medical and employment benefits.  During your employment, we will collect and process further data about you in furtherance of that employment relationship.  We process this information to fulfill our contractual obligations, in support of our legitimate interest in providing Services, and in furtherance of the employment relationship.

Study Abroad Programs in the EEA

We conduct educational and study-abroad programs in the EEA and collect Personal Information in the course of offering and administering these programs.  This information will be collected and used under the same conditions as Personal Information collected in connection with our U.S.-based educational programs and Services.

Research

If you agree to participate in a research study, our faculty and researchers may collect your Personal Information as a part of that study based upon your explicit authorization.  The categories of information to be collected and the terms processing of your information for research purposes will be more fully disclosed in the consent and/or authorization forms provided to you in connection with such a study.

 

2. Personal Information That We Obtain From Third Party Partners and Service Providers

We may collect or obtain your Personal Information from third parties who provide it to us. This may include offline channels such as through telephone, fax, or direct mail efforts; from vendors, suppliers, third parties.  Third parties may provide us with your data, including application vendors such as the Common Application and the College Board.

 

3. Legitimate Interests

In addition to processing Personal Information in furtherance of a contract or prospective contract for admission to or employment with the College, we have legitimate interests in collecting, processing, and sharing your Personal Information.  These interests include:

  • Offering and improving our services and programs;
  • Administration of the College’s operations;
  • Performing and advancing research and academic study;
  • Staying in touch with our current and former students;
  • Connecting with alumni, donors and prospective donors, and soliciting donations to advance our services and programs;
  • Monitoring and ensuring the secure and reliable use of information technology systems;
  • Ensuring the safety and security of our students, faculty, employees and others; 
  • Complying with the law and enforcing our legal rights, identification and mitigation of fraudulent activity, and compliance audits in relation to internal policies;
  • General business and financial management purposes, including: economic, financial and administrative management; planning and reporting; personnel development; accounting; finance; audit; and compliance with legal requirements.
  • Surveying you for the purposes of obtaining your views on our Services;
  • Marketing to current and prospective student, donors, alumni, and employees who have indicated an interest in Juniata in order to further generate and promote our college. Such efforts include sending marketing emails or conducting phone calls.

 

5. Direct Marketing

We may Process your Personal Information to contact you via email, telephone, fax, direct mail, SMS or other methods of communication to provide you with information regarding the Services that may be of interest to you. We may send information to you regarding the Services, upcoming events and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.

You may unsubscribe from our marketing contact lists at any time by following the unsubscribe instructions included in every email we send. We will not send you any emails from a list you have selected to be unsubscribed from, but we may continue to contact you to the extent necessary for the purposes of any other Services you have requested or for additional emails you have signed up for. You may opt out of any telephone or SMS marketing by contacting us at the contact details set out in Section 14 below.

 

6. Cookies, Similar Technologies and Online Behavioral Advertising

We may collect or Process your Personal Information using cookies.  Cookies are small bits of text that are downloaded to the devices you use to reach and use the Service. Your browser or device holds these cookies and makes them available every time you visit a site again so that it can recognize you and remember important information about you.  The types of information typically collected by cookies include information relating to your use of the Service, your device’s IP address and browser type, how you arrived on one of the Services, your name, and email address if you are logging in, etc.

 

What Cookies Do We Use?

Below is a list of each category of cookies we use and why we use each cookie. First party cookies are our own cookies set by Juniata College, controlled by us and used to provide information about the usage of the Service.

  1. Essential Cookies or Strictly Necessary Cookies: These cookies are essential to the Service in order for you to move around the Service and to use its features. Without these cookies, certain features could not function. No information about your browsing habits is gathered by these cookies.
  2. Functional Cookies: These cookies remember how you prefer to use the Service and enable us to improve the way the Service works. We can remember your settings and help provide you with relevant ads or information. Functional Cookies are persistent cookies that the Service remembers when your computer or device comes back to that Service.
  3. Analytics Cookies: This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text  files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States . Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.  To opt-out of Google Analytics cookies altogether by linking to this Google Analytics Opt-Out Add-on (https://tools.google.com/dlpage/gaoptout?hl=en).
  4. Behavioral Advertising Cookies: Behavioral Advertising Cookies are used to deliver relevant content to users both on and off the Service. We analyze what pages you visit on our sites, what products or services you view, and whether you view or click on content that is shown to you. We may also use a cookie to learn whether you take action based on viewed content. We use this information to send you interest-based communication and may also share this information with third parties. Similarly, our partners may use a cookie to determine whether we’ve shown an ad and how it performed, or provide us with information about how you interact with ads. We may also work with a partner to show you an ad on or off the Service, such as after you have visited a partner’s site or application. 

You can control the use of certain cookies and similar technologies by:

If you choose to reject certain cookies and similar technologies, you may still use our websites and online services, although your access to some functionality and features may be restricted.  If you have any questions regarding our use of cookies and other similar technologies, please contact us as set forth in Section 14 below.

 

Geolocation Information and Similar Technologies

Some devices allow applications to access real-time location-based information (for example, GPS). Some photos or other content you place within the Service may contain recorded location information. We may use this information to optimize your experience. Also, some of the information we collect from a device, for example IP address, can sometimes be used to approximate a device’s location. 

In addition to cookies and geolocation information, we may also use other similar tracking technologies on our services, such as pixel tags (also known as clear GIFs, pixels or web bugs), web beacons, eTags and local storage. We use these technologies to do things like store user settings video viewing history, gather demographic information about our user base as a whole or track users’ movements around the Service, to serve interest-based ads, or to improve our understanding of things like site traffic, visitor behavior and promotional campaigns. Pixel tags are small blocks of code installed in or on a web page, mobile app, or advertisement and are a method for passing information from your device to a third party website. Web beacons are electronic files that allow a website to count users who have visited that page or to access certain cookies. Local storage, such as HTML 5, allows a website or mobile app to store and retrieve data on an individual’s device. eTags are tags used to analyze trends by us and our service partners.

 

7. What Information We Disclose to Third Parties

 We may disclose your Personal Information to:

  • Legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
  • Outside professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of confidentiality;
  • Any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights;
  • Any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security;
  • Any relevant third-party acquirer(s), in the event that we sell or transfer all or any relevant portion of our college or assets;
  • Any relevant third-party provider, where our Services use third party plugins or content. If you choose to interact with any such plugins or content, information about your activities on the Services to provide you targeted advertising based upon your interests may be shared with the relevant third-party provider;
  • Any sponsors of college related events or programs, the registration data for such events is to be used by us as part of Personal Information, and may be shared with the sponsor and others, subject to this Policy and the sponsor’s privacy policy. We may also share your information with third party vendors involved in the administration of such events.

We may engage third party providers to assist with the collection, storage and segmentation of online data and the providers are required to maintain the confidentiality of this information. These third-party providers may collect Personal Information from our Services for their own purposes, including but not limited to monitoring fraud around the web.

If we engage a third-party Processor to Process your Personal Information, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Information in accordance with an agreed upon contract; and (ii) use measures to protect the confidentiality and security of the Personal Information; together with any additional requirements under applicable law.

Some third party Services contain links to other sites or partners whose information practices may be different from ours. You should consult the privacy policy of these third parties to learn how your privacy is protected.

 

8. Data Security

We implement appropriate technical and organizational security measures to protect your Personal Information. Please ensure that any Personal Information that you send to us is sent securely.

We have implemented appropriate technical and organizational security measures designed to protect your Personal Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. Juniata College will not process personally identifiable information in any way that is incompatible or inconsistent with the purpose for which such information was collected. You also have a significant role in protecting your information. No one can see or edit your Personal Information without knowing your user name and password, so do not share these with others.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us are sent securely.

Children. Parents or legal guardians should always provide Personal Information or permission for collection of Personal Information from persons under the age of 13. If, outside of this disclosure or permission, your children disclose information about themselves to Juniata, consequences may occur that are not intended for children. If it is discovered that we have collected Personal Information from someone under 13, we will delete that information immediately.

 

9. Data Accuracy

We take every reasonable step to ensure that your Personal Information that we Process is accurate and, where necessary, kept up to date, and any of your Personal Information that we Process that you inform us is inaccurate (having regard to the purposes for which they are Processed) is erased or rectified.

 

10. Data Minimization

We take every reasonable step to ensure that your Personal Information that we Process is limited to the Personal Information reasonably necessary in connection with the purposes set out in this Policy or as required to provide you services or access to the Services.

 

11. Data Retention

We take every reasonable step to ensure that your Personal Information is only retained for as long as they are needed. We take every reasonable step to ensure that your Personal Information is only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will keep your Personal Information are as follows: we will retain copies of your Personal Information in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. Unless there is a specific legal requirement for us to keep the information, we plan to retain it for no longer than is necessary to fulfill a legitimate business need.

 

12. What Can I Do to Control My Information?

You can directly take steps to change your preferences as outlined in this section.

If you are an EU resident, you may have certain rights. You may decline to share certain information with us, in which case we may not be able to provide some or all of the features and functionality of the Services. Where we process your information on the legal basis of a contractual relationship or legitimate interest, you have the right to transparency, request access to, and rectify your information. Where we process your information on the legal basis of consent, these rights include, in accordance with applicable law, the right to request access to, right to rectification, right to erasure, right to portability and right to object to or request the restriction of processing of your information. Also, where we process your information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal and does not prevent the Processing of your Personal Information in reliance upon any other available legal bases). We may require proof of or need to verify your identity before we can give effect to these rights.

You may directly take steps to change your preferences as follows:

Subscriptions. You can opt out or unsubscribe to email marketing lists at any time by following the instructions at the end of the emails you receive. Please allow five to ten business days for changes to take effect. On some Services, contractual-related communications are an integral part of such Services to which you subscribe, and you may continue to receive emails as part of that particular portion of the Services unless you withdrawal from or leave Juniata College, even if you opt out of the email list. If you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe each email address you have provided.

Cookies and Pixel Tags. You may stop or restrict cookies and pixel tags on your computer or purge cookies from your browser by adjusting your web browser preferences. However, if you “turn off,” purge, or disable cookies or pixel tags, although you may still use the Services, you may not be able to use all of the features, functions, or services available on the Services.

Location Based Services. You may opt-out of having your Precise Location Data collected by Juniata College at any time by editing the appropriate setting on your mobile device (which is usually located in the Settings area of your device).

Requests should be submitted by contacting us (using the contact instructions in Section 14 below). If you are an EU resident and have any unresolved privacy concern that we have not addressed satisfactorily after contacting us, you have the right to contact the appropriate EU Supervisory Authority and lodge a complaint.

 

13. How this Privacy Policy May Change

We may change this Policy from time to time, and all changes will be effective at the time we post them. If we believe there is a significant change to this Policy or our data collection and use practices, we will indicate on our websites that our Policy has changed prior to the change becoming effective. The then-posted version of the Policy supersedes all prior versions. Your continued access to or use of any of the Services shall be deemed your acceptance of the Policy.

If you have a College email address or otherwise register your email address with the College, we will notify you by email of any changes to this Privacy Policy.  We otherwise urge you to come back to this web page and review this Privacy Policy regularly so that you remain aware of the terms and conditions that apply to you.

14. Contact Details

If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of Personal Information carried out by us, or on our behalf, you may contact us at the addresses set out below or by emailing privacy@juniata.edu.

Juniata College
Attention: Privacy
1700 Moore Street
Huntingdon, PA 16652