Effective Date: March 27, 2020
PART A: General Privacy Notice
This part of our Privacy Notice describes the data processing practices of the St. Louis University campuses in St. Louis, Missouri and in Madrid Spain. This Notice applies if you are a prospective student, an applicant for admission, a current student, or an alumnus at ΘνΓΓΙη (St. Louis or Madrid Campuses) (ΘνΓΓΙη) or an applicant for employment at ΘνΓΓΙη. This Privacy Statement does not apply to ΘνΓΓΙη employees.
If your relationship is with the St. Louis University campus in Madrid, please also see Part B below (GDPR Notice).
ΘνΓΓΙη values your privacy and your desire to know how we handle and use your information. Therefore, we provide this Privacy Statement, which explains our information practices. This statement applies to information, including Personal Data (which means any information relating to an identified or identifiable natural person), that we may collect, store, and/or disclose about students, alumni, applicants, website visitors and other individuals interacting with ΘνΓΓΙη, its websites (the "Site"), products, and services.
This Privacy Statement may be updated from time to time. We will notify you of any changes to our Privacy Statement by posting the new Privacy Statement on our Site and updating the Effective Date listed above. The most current version of the Statement may be reviewed by clicking on the "Privacy" link located at the bottom of our Site. Please note that there is a separate Terms of Service found in the "Terms of Service" hyperlink located at the bottom of our Site. The purpose of this Privacy Statement is to explain the types of information we collect, how it is used, how it may be shared with others, and your choices about its use and disclosure. If you are visiting our site from the European Union ("EU") or the UK or where applicable EU/UK data protection laws apply, please see the "EU Section" below.
What Personal Data We Collect
As you interact with ΘνΓΓΙη websites, you can provide us information directly if you choose to do so. Additionally, we may collect certain information from or about you as further described below.
- Information you provide to us directly or when you interact with us. We collect the information you provide to us directly or when you interact with us, such as through technology when you visit or use this website, use ΘνΓΓΙη and third-party digital properties (including social media sites), or during other interactions such as recruiting events, campus visits, etc.
- Information from third parties. We receive information about you from third parties such as:
- Your high school or other academic institutions. Examples of information we receive include transcripts and other records, recommendations, etc.
- Testing boards, such as the College Board, ACT.org, etc.
- Other third parties, such as companies with whom we work to obtain information about potential candidates.
We may combine information that we receive from the various sources described in this Privacy Statement, including third-party sources, with personal information we hold and use or disclose it for the purposes identified below.
ΘνΓΓΙη will collect data about you in the course of our interactions with you as a prospective, current, or former student; for example, when you apply, when you enroll, and as you progress through your course work. If you are a prospective, current, or former student, examples of the data that ΘνΓΓΙη may hold about you include:
- Your name and contact details, including emergency contacts
- Your date of birth
- Your nationality and ethnic origins (Only collected by ΘνΓΓΙη St. Louis for students enrolling at ΘνΓΓΙη St. Louis)
- Information about your family status and other relevant relationships
- Your academic background and qualifications
- Your academic record and involvement in organizations and activities while at ΘνΓΓΙη, including details of any degrees which you are awarded
- Any disabilities which you have disclosed to us (Only collected by ΘνΓΓΙη St. Louis for students enrolling at ΘνΓΓΙη St. Louis)
- Medical information, such as information held by the counseling service (Only collected by ΘνΓΓΙη St. Louis for students enrolling at ΘνΓΓΙη St. Louis)
- Financial information and scholarship details
- Information about your interests
- Information about your use of ΘνΓΓΙη facilities such as the library
- Any disciplinary action taken against you
- A digital photograph of you, which is used to produce your student ID, and for security and identification purposes
If you are an applicant for employment, examples of the data that ΘνΓΓΙη may hold about you include:
- Your name and contact details (including, but not limited to, address, e-mail address, and phone number(s))
- Your academic background and qualifications
- Details of your employment history
- Your date of birth and Social Security Number
How We Use Your Personal Data
When you apply, and accept an admission offer from us, you enter into a contract with ΘνΓΓΙη and we process your personal information for administrative and educational purposes. The purpose of processing includes, but is not limited to:
- Administering and providing education and training
- Managing and administering student services, including accommodation services and meal services
- Administering grants and loans
- Providing advice and support to you, including health care services, health and safety, attendance monitoring, welfare and pastoral services, and career guidance
- Managing behavioral or disciplinary issues and complaints
- Recruitment, admission and enrollment
- Providing you with information about educational programs and services
- Maintaining your student record and managing academic processes
- Administering financial matters including payment of fees
- Managing University services including library services and events
- Monitoring quality and performance
- Maintaining graduation and other records, such as confirmation of awards
- Maintaining Alumni membership information and contacting Alumni
- Using for statistical and archive purposes
Communications to students and former students may be sent by post, telephone or electronic means.
Information collected from applicants for employment will be used to evaluate and consider their application for employment and manage the application process.
With Whom We Share Your Personal Data
Your Personal Data may be shared between ΘνΓΓΙη entities (between the St. Louis and Madrid campuses) for any or all of the purposes described above.
We may also provide some of our services through contractual arrangements with ΘνΓΓΙη service providers that process your Personal Data on our behalf, such as for IT support, hosting and maintenance services and mailing or delivery/transport services.
We may share data with select third parties, such as business partners, for the purposes of contacting you about attending our university or applying for employment with us.
We may also anonymize or aggregate Personal Data about you and use or share the de-identified information with third parties.
We do not sell any of your Personal Data, including your name, mailing address or email address.
Occasionally, we may be required by law enforcement or other public authorities as well as judicial authorities, courts or tribunals to share Personal Data with them or other parties. We will disclose Personal Data upon receipt of a court order, subpoena, warrant, or other legal process to the extent necessary to meet legal, national security, public interest, or law enforcement obligations or defend our interests in legal, administrative or other proceedings, which may require us to share Personal Data with other parties to the proceedings and their external counsel. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.
We may buy or sell or merge with another university all or part of our university. All or part of your Personal Data may be transferred to a new university as a result of such transactions, in accordance with applicable laws; however, your Personal Data will continue to be protected by any pre-existing Privacy Statement of ΘνΓΓΙη, unless you agree otherwise.
Public Postings. You should also be aware that when you voluntarily disclose your Personal Data in any public areas on this Site or any other ΘνΓΓΙη digital media (e.g. a social media site), that Personal Data, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. Such activities are beyond our control. If you do not want your comments to be viewed by third parties, you are advised not to make any public submissions.
To receive a list of parties with which ΘνΓΓΙη shares data, as provided for under the LOPD and the GDPR, you may contact the Data Protection Officer:
- Phone: +34915545858
Cookies and Other Tracking Technologies
The Site also collects information, via cookies, web beacons, pixels, tags or other tracking technologies, such as your Internet Service Provider and IP address, the date and time you access the Site, the pages you have accessed, and the Internet address from which you accessed the Site. Some cookies exist only during a single session and some are persistent over multiple sessions over time.β―We use these technologies to remember user preferences, maximize the performance of our website and services, provide you with offers that may be of interest to you, measure the effectiveness of our email campaigns and to personalize online content.
Some browsers have incorporated Do Not Track ("DNT") preferences. Most of these features, when turned on, send signals to the website you are visiting that you do not wish to have information about your online searching and browsing activities collected and used.β―As there is not yet a common agreement about how to interpret DNT signals, we do not honor DNT signals from website browsers at this time.β―However, you may refuse or delete cookies.β―If you refuse or delete cookies, some of our website functionality may be impaired.β― Please refer to your browser's Help instructions to learn more about how to manage cookies and the use of other tracking technologies.
You can opt out of being further contacted by us by emailing us at email@example.com .
You may also opt-out of receiving marketing or promotional email messages from us by clicking on the "Unsubscribe" link contained at the bottom of each email.
For information about the Personal Data we process about you, please contact us firstname.lastname@example.org
Retention of Data
We will keep your Personal Data as reasonably necessary to fulfill the purposes for which Personal Data is collected as stated herein; for as long as is necessary for the performance of the contract between you and us, if any; and to comply with legal and statutory obligations, such as in tax, trade and corporate laws. Please note, however, that even after termination of your student relationship or employee applicant status with ΘνΓΓΙη, ΘνΓΓΙη may still need to retain your personal data to satisfy its obligations to keep certain records for a specific period of time under applicable law. When we no longer need your Personal Data for these purposes, we will destroy, delete or erase that Personal Data or convert it into an anonymous form.
Security of Data
ΘνΓΓΙη will take reasonable steps to protect your Personal Data in our possession from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
We do not use the Site to knowingly collect Personal Data from children under the age of thirteen (13), nor is this Site designed for or directed at children. By using the Site, you represent that you are age thirteen (13) or over. If you are a child under thirteen (13) years of age, you are not permitted to use the Site and should not send any Personal Data about yourself to us through the Site. If you believe that a child may have provided his or her Personal Data to us, please contact us using the contact information at the end of this Statement. In the event that we become aware that we have collected Personal Data from a child under the age of thirteen (13), we will dispose of that Personal Data immediately.
ΘνΓΓΙη is a Data Controller for the purposes of the LOPD and the GDPR, and the Data Protection Officer on behalf of ΘνΓΓΙη can be contacted via:
- Phone: +34915545858
The address for correspondence in relation to EU data protection issues is:
- ΘνΓΓΙη - Madrid Campus, Avenida del Valle, 34 28003 Madrid Spain.
The address for correspondence in relation to U.S. data privacy issues is:
- ΘνΓΓΙη - Information Security Office, 3545 Lindell Blvd., Wool Center 3rd Floor, St. Louis, MO 63103.
For U.S. citizens, you may contact:
- For Student Information:β―email@example.com
- For Employee Information:β―firstname.lastname@example.org
- For Alumni Information:β―email@example.com
- For Donation Information:β―firstname.lastname@example.org
- For Information regarding this website's security and privacy:β―email@example.com (security and privacy)
PART B: Additional Information Required Under the EU General Data Protection Regulation (GDPR)
Legal Basis for Processing Your Information
If you are a prospective student of, an applicant to, or a student or alumnus/alumna of ΘνΓΓΙηβs Madrid campus, ΘνΓΓΙη is the controller of your Personal Data. You may contact us as follows:
- ΘνΓΓΙη - Madrid Campus, Avenida del Valle, 34 28003 Madrid Spain
- ·‘³Ύ²ΉΎ±±τ:β― DPOfirstname.lastname@example.org
- Phone: +34915545858
ΘνΓΓΙη-Madrid will process your personal data fairly and lawfully in compliance with applicable laws, LOPDGDD 3/2018 (the Spanish Data Protection Law) and General Data Protection Regulation 2016/679 (the EU Data Protection Law). Our legal basis for collecting and using your Personal Data will depend on the categories of Personal Data concerned and the specific context in which we collect it.
We will normally process Personal Data about you as necessary to perform a student contract with you, where the processing is in our legitimate interests and not overridden by your rights, and when we have a legal obligation to do so. If we are processing your Personal Data based on consent, we will seek your consent separately at the time of collection.
By applying to or enrolling as a student of the ΘνΓΓΙη-Madrid Campus, you understand that ΘνΓΓΙη-Madrid will be collecting, storing, using and otherwise processing Personal Data about you for any purposes connected with your studies, your health and safety, to protect the vital interests of others, as required in compliance with a legal obligation, to perform tasks in the public interest, and for other legitimate reasons while you are a student. Unless you object, we may also use your data for certain purposes after you cease to be student (alumni relations).
Your Rights Under The GDPR
Applicants to, or students or alumni of, ΘνΓΓΙη-Madrid may exercise the following rights regarding your Personal Data as applicable under the GDPR or LOPDGDD 3/2018:
- Right of Access: This entitles you to receive a copy of the Personal Data we hold about you and check that we are lawfully processing it.
- Right to Rectify: This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Right to Delete: You may ask us to delete or remove Personal Data where there is no good reason for us continuing to process it, you withdraw your consent, we are unlawfully holding your Personal Data or we should erase your Personal Data to comply with applicable EU law. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Right to Object: This applies where we are relying on a legitimate interest (or those of a third party) as a legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal data for direct marketing purposes.
- Right to Restrict: You may ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or stop us deleting personal data, which you need for a legal claim.
- Right to Portability: This enables you to have us transfer the Personal Data you have provided us to another party.
- Right to Withdraw Consent: Where consent is the basis for processing your Personal Data, you may withdraw your consent at any time by notifying us of your decision to do so.
We do not engage in any form of automated decision making or profiling.
You can exercise your rights at any time by contacting us at DPOemail@example.com and providing sufficient information for us to identify you and your Personal Data. In some cases, we may have lawful grounds to reject your request depending on the legal basis for collecting your Personal Data. We will investigate any request you make without undue delay and in any event within one month of receipt of your request (except in the case of complex or voluminous requests, in which case an extension of up to two additional months may be necessary). We will inform you of the need and reasons for any extensions that may be required.
We will do our best to satisfy your request, but if you are not satisfied with our response, you have the right, under the LOPDGDD 3/2018 and the GDPR, to submit a complaint to the Spanish Supervisory Authority responsible for data protection which can be contacted at:
- Post:β―Agencia EspaΓ±ola de ProtecciΓ³n de Datosβ―
- C/ Jorge Juan, 6
- C/ Jorge Juan, 6
- Tel:β―+34 901 100 099,β― +34 91.266.35.17
- Information Commissioner's Office Website:
The ΘνΓΓΙη Data Protection Officer on behalf of ΘνΓΓΙη can be contacted (regarding questions or to exercise your rights) via:
- Phone: +34915545858
The address for correspondence in relation to EU data protection issues/rights is:
- ΘνΓΓΙη - Madrid Campus, Avenida del Valle, 34 28003 Madrid Spain.
Legal basis for processing your information
- By commencing or enrolling as a ΘνΓΓΙη student, ΘνΓΓΙη will be required to collect, store, use and otherwise process information about you for any purposes connected with teaching, support, research, administration, your safety and for other reasonsβ―deemed necessary for the performance of your contractual agreementβ―with ΘνΓΓΙη. See GDPR Article 6(1)(b).
- Processing of your personal data may also beβ―necessary for the pursuit of our legitimate interests or by a third party's legitimate interestsβ―-but only when it will not cause a prejudicial effect on the rights and freedoms, or legitimate interests, of the studentβ―See GDPR Article 6(1)(f).
- Processing of your personal data is necessaryβ―for the performance of a task carried out in the public interest (see GDPR Article 6(1)(e) and LOPDGDD Article 8(2)) and for statistical and research purposes (see GDPR Article 89).
- ΘνΓΓΙη will obtainβ―consentβ―from you in order to assist with your pastoral and welfare needs (e.g. the counselingβ―service and services to students with disabilities).β―See GDPR Article 6(1)(a).
- Processing of Special Categories data is necessary for theβ―statistical and research purposesβ―in accordance with article 89 (1) based on the duties in the Equality LOPDGDD 3/2018 (see GDPR Article 9(2)(j) and LOPDGDD Article 9).
International Transfers of Your Personal Data
By providing personal data to ΘνΓΓΙη, your personal data may be transferred to the United States where ΘνΓΓΙη is headquartered. If you are not a resident of the United States, your country's laws governing data collection and use may differ from those in the United States. For example, the data protection laws of the United States have not been found by the European Commission to provide the same level of protection as EU data protection law.
ΘνΓΓΙηβs Madrid campus collaborates closely with ΘνΓΓΙηβs St. Louis, Missouri campus and may transfer Personal Data about you to ΘνΓΓΙη in the United States for a variety of reasons relevant to your relationship with ΘνΓΓΙη, such as for purposes of evaluating your application, management of academic records, processing your transfer from the Madrid campus to the St. Louis campus, employee information for purposes of allowing access to systems and alumni event planning. ΘνΓΓΙη-Madrid also transfers Personal Data about its applicants, students and alumni to ΘνΓΓΙη St. Louis, Missouri as a data processor for electronic storage purposes. ΘνΓΓΙη-Madrid has put in place the relevant EU Commission-approved Standard Contractual Clauses with ΘνΓΓΙη St. Louis in accordance with the requirements of the GDP.
If you are transferring data directly to ΘνΓΓΙη in the United States from the EU, including for reasons such as to apply for employment, to apply for education, for materials on ΘνΓΓΙη programs. etc., please only send the personal information necessary to facilitate the applicable process. By sending this information directly to the United States you are acknowledging that it will be processed in the United States and authorizing it to be used to facilitate the applicable process.
Transfers to Unaffiliated Third Parties
Third-party entities, primarily vendors, are sometimes located outside the EU. Unless the recipients are located in countries recognized as adequate by the European Commission (or certified under schemes such as the EU-US Privacy Shield Framework), we put in place data transfer agreements based on the applicable European Commission-approved Standard Contractual Clauses or rely on other available data transfer mechanisms (Binding Corporate Rules, approved Certifications, or Codes of Conduct) to protect the transferred personal data. In exceptional cases, we may rely on statutory derogations for international data transfers.