College of the 51С�Ƴ� Privacy Notice

The College of the 51С�Ƴ� (hereafter “College”) is committed to respecting the privacy of information and data that may be used to identify you (your “personal information”). This Privacy Notice describes our policies and practices regarding the most common ways we collect and use personal information.

Information We Collect and How We Use Your Personal Information

Applicants and Prospective Students

Personal Information We Collect

The College collects and uses personal information about applicants and other prospective students, including students interested in our summer program (referred to collectively as “applicants”). If you are or have been an applicant, we may collect and use the following types of personal information about you:

Information and supporting documentation that you provide in your application, including through third parties, such as The Common Application and The Coalition Application
Related application materials (e.g., recommendations, references, and test scores)
Information that you have permitted a third party, such as The College Board, to release (e.g., AP or PSAT scores, demographic information, academic information)
Contact information for prospective students that we receive from other institutions and from vendors who conduct advertising activities for us
Financial information, including financial information about your family members (e.g., information collected in connection with applications for financial aid, loans, and scholarships)
Survey responses (if you choose to respond to a survey sent by us or on our behalf)

How We Use Your Personal Information

Your personal information is used primarily to evaluate your application and related activities, such as evaluating requests for financial aid, communicating with you about your application, and other administrative functions related to the admissions and enrollment process. We may also use or disclose your personal information for the following purposes:

To consider requests for accommodations
For research and statistical purposes
To provide you with information about the College and events that you might be interested in attending
To send surveys for research purposes
For compliance with legal obligations, to respond to subpoenas, court orders, or other legal process, and to enforce our agreements
To prevent or investigate fraud or other unlawful activity, and to protect the security of the College's property, website, and other systems
To meet the obligations of private organizations with oversight over the College, such as accreditation organizations
To protect the health, safety, or rights of you, other students, faculty, staff, and visitors

How We Share Your Information

We may share your information with the following individuals and entities:

Individuals who assist in the application process, such as faculty and outside consultants
Other departments within College of the 51С�Ƴ�, in addition to the Admissions office, including the Office of Advancement
Your financial institutions and funders (e.g., as necessary for obtaining loans, scholarships, or other funding)
Other educational institutions (e.g., in order to send you information about jointly hosted informational events)
Vendors who provide services to the College
Governmental bodies as necessary for compliance with law, with law enforcement authorities when necessary, and other third parties to enforce our legal rights
Private organizations with oversight over the College, such as accreditation organizations

We do not share mobile phone numbers with third parties, affiliates, or partners, for marketing or promotional purposes. The College will not share text messaging originator opt-in data and consent with any third parties

Legal Basis for Processing (for personal information subject to the General Data Protection Regulation (“GDPR”))

With respect to personal information subject to the GDPR, we rely on the following lawful bases for processing:

Our legitimate interests, such as conducting our admissions activities
To provide you with services or perform on contractual obligations, such as processing your application for admission
For compliance with our legal obligations
With your consent, when applicable

Students, Faculty, and Staff

Personal Information We Collect

When you are a student at the College, or a member or prospective member of the faculty and staff, we maintain records containing your personal information. We may collect and use the following types of personal information about you, as applicable:

Your contact information and biographical data (e.g., name, address, date of birth, race, ethnicity)
Application materials and supporting documents (e.g., applications for admission or employment)
Copies of identification documents and other official documents (e.g. driver’s license, I-9 form, passport/visa information)
Employment and/or educational records (e.g., job history, job reviews, transcript information)
Academic work product and related information (e.g., research and course-related content)
Records about your other activities (e.g., involvement in clubs, disciplinary actions and similar incidents)
Financial information (e.g., payroll information, information related to tuition payments)
The College collects and maintains medical information as appropriate and necessary and subject to relevant laws. Student Health Services, Student Counseling Services, and Sports Medicine collect medical information for the purposes of providing treatment and determining enrollment and participation eligibility. Other offices, such as Disability Services, Human Resources, or Public Safety may request or maintain medical information for business purposes (not for treatment purposes).
Information about technology usage (e.g., IP addresses, software downloads, network and services use)

How We Use Your Personal Information

We use this information for the following purposes as applicable:

To provide educational, employment and/or related services (e.g., maintaining relevant records of your studies or employment, providing you with access to facilities and support services, such as counseling and IT services)
To administer the financial aspects of the relationship (e.g., payroll, collecting tuition, coordinating with lenders or other funders)
To enable your participation at events and in other opportunities (e.g., graduation, study abroad programs, internships)
To protect the educational integrity of the school (e.g. disciplinary actions)
To accommodate special needs (e.g., disability accommodations)
For research and statistical purposes related to our educational and/or other services
To provide basic contact information in student, faculty, and/or staff directories
For the general operations of the College and related administrative functions
For compliance with legal obligations, to respond to subpoenas, court orders, or other legal process, and to enforce our agreements
To prevent or investigate fraud or other unlawful activity, and to protect the security of the College’s property, website, and other systems
To meet the obligations of private organizations with oversight over the College, such as accreditation organizations
To protect the health, safety, or rights of you, other students, faculty, staff, and visitors

How We Share Your Personal Information

We may share your personal information with the following:

Faculty and staff at the College in order to fulfill their responsibilities
Your lenders, funders, and/or other sponsors
Providers of any external program, such as study abroad programs, internships, and other collaborations
Your host institution and host family (in connection with study abroad or faculty or student exchange programs)
Student clubs and related organizations
Individuals or entities inquiring about your attendance or employment history
Vendors who provide services to the College
Governmental bodies as necessary for compliance with law, with law enforcement authorities when necessary, and other third parties to enforce our legal rights
Private organizations with oversight over the College, such as accreditation organizations

Legal Basis for Processing (for personal information subject to the GDPR)

With respect to personal information subject to the GDPR, we rely on the following lawful bases for processing:

Our legitimate interests, such as fulfilling our educational mission
To provide you with services or perform on contractual obligations, such as providing you with educational services or managing your employment relationship
For compliance with our legal obligations
With your consent, when applicable

Alumni and Other Supporters

Personal Information We Collect

The College holds personal information related to its alumni and other supporters (such as donors, prospective donors, volunteers, and family members of students). If you are an alumni or other supporter, we may collect and use the following types of personal information about you:

Academic information (e.g., major, transcript, degree)
Biographical information (e.g., name, date of birth, ethnicity, religious affiliation)
Contact information (e.g., email address, phone number)
Your activities at the College (e.g., club memberships)
Your involvement with the College and other interests (e.g., attendance at events, philanthropic interests)
Family information (e.g., marital status, name of spouse)
Health information (e.g., disability, food allergies)
Financial information (e.g., history of donations, wealth information)
Employment information

We collect data about alumni and other supporters from various sources, including directly from the individual (for example, by filling out a form on our website). We also retain information from your student records if you studied here. We also collect information from publicly available sources, such as social media, and from third parties, such as companies that conduct wealth screening or other people that might know you and your philanthropic interests.

How We Use Your Personal Information

Your personal information is used for the following purposes:

Sending you informational publications (e.g., 51С�Ƴ� Magazine, newsletters from departments and clubs you may have interest in)
Conducting surveys so that we can learn more about our alumni and other supporters
Providing services (e.g., networking, ongoing career services)
Sending you information about fundraising campaigns, events, and volunteer opportunities that may be of interest to you
Conducting wealth analysis and research to understand your philanthropic interests and ability to give in order to ensure that our fundraising efforts are tailored to your interests
For administrative purposes (e.g., processing donations and issuing a tax receipt, managing events, such as reunions)
For research and statistical purposes
To publicly acknowledge gifts (with consent of the donor)
For compliance with legal obligations, to respond to subpoenas, court orders, or other legal process, and to enforce our agreements
To prevent or investigate fraud or other unlawful activity, and to protect the security of the College’s property, website, and other systems
To meet the obligations of private organizations with oversight over the College, such as accreditation organizations
To protect the health, safety, or rights of you, other students, faculty, staff, and visitors

How We Share Your Personal Information

We share your personal information with the following:

College departments, clubs, and interest groups
College volunteers, 51С�Ƴ� Alumni Association, specific alumni clubs and organizations and similar affiliates
Other individuals or entities with a legitimate interest in your personal information, such as scholarship supporters
Vendors who provide services to the College
Governmental bodies as necessary for compliance with law, with law enforcement authorities when necessary, and other third parties to enforce our legal rights
Private organizations with oversight over the College, such as accreditation organizations.

Legal Basis for Processing (for personal information subject to the GDPR)

With respect to personal information subject to the GDPR, we rely on the following lawful bases for processing:

Our legitimate interests, such as maintaining alumni relationships and conducting fundraising activities
To provide you with services or perform on contractual obligations, such as providing certain alumnae services
For compliance with our legal obligations
With your consent, when applicable

Website Visitors

( and other associated 51С�Ƴ� web properties, including all at holycross.edu)

Personal Information We Collect

The College of the 51С�Ƴ� website (defined as the collection of all web pages, multimedia content, documents published to .holycross.edu) is the College’s public information and communications system and serves as the digital embodiment of the College for all audiences including students, employees, alumni, families, future employees, prospective students, and friends. If you visit this site to view or download information, or submit information to us, we or our third-party vendors may automatically collect the following types of personal information:

the name of the domain from which you access the Internet
your approximate geographic region from which you access the Internet
the date and time of your visit
the page(s) you visit, and engagement with them
your computing platform (browser, operating system, etc.)

Some of this information may be collected through the use of cookies, which are text files that are placed on your hard disk by a web server, or similar technologies, such as web beacons. Some of these cookies are managed by third parties that we do not control, such as Google Analytics. You have the ability to accept or decline cookies by changing your browser settings. If you choose to decline cookies, some features on this website may not work properly.

If you use our website to complete forms, use our applications, or submit information to us (such as through form registrations, requesting information or making a donation), we will collect the information that you provide to us, as well as related information such as your login ID.

How We Use Your Personal Information

The data collected with cookies and similar technologies are used in the aggregate for purposes of analyzing site traffic, managing the site, and providing accountability regarding the usefulness of our work.

If you provide us with information (such as through registration pages), we will use that information for the purposes described on the form or registration pages.

We may also use your personal information for the following purposes:

For compliance with legal obligations, to respond to subpoenas, court orders, or other legal process, and to enforce our agreements
To prevent or investigate fraud or other unlawful activity, and to protect the security of College property, website, and other systems.
To meet the obligations of private organizations with oversight over the College, such as accreditation organizations
To protect the health, safety, or rights of you, other students, faculty, staff, and visitors
We may also share your email address and/or your browsing behavior with third-parties for use in targeted advertising campaigns.

How We Share Your Personal Information

Personal information collected automatically on this website is not disclosed to third parties unless the third party is an institutionally authorized provider of services to the College. Information collected through website forms is used as specified on the form or as otherwise described in this notice.

This web site contains links to many sites that are beyond our control. The College is not responsible for the privacy practices or content of these other sites. Users of these services are subject to the privacy policies established by the third-party provider.

Legal Basis for Processing (for personal information subject to the GDPR)

With respect to personal information subject to the GDPR, we rely on the following lawful bases for processing:

Our legitimate interests, such as monitoring our website usage
To provide you with services or perform on contractual obligations, such as managing our relationships with our suppliers and alumnae
For compliance with our legal obligations
With your consent, when applicable

Transfer of Information to the United States

The College of the 51С�Ƴ� is located in the United States. Information we collect from you will be processed by the College in the United States. The College may also transfer your personal information to third parties, including our vendors, as described in this notice that may be located outside of the European Economic Area (“EEA”).

The United States has not sought nor received a finding of “adequacy” from the EEA, which means that the data protection laws in the United States may not offer you the same protections as in the country in which you are residing when the personal information is collected. With respect to transfers outside the EEA, the College generally relies on derogations for specific situations. In some circumstances, the College may enter into standard contractual clauses governing the import or export of personal information, or rely on your consent. In all cases, the College endeavors to apply suitable safeguards to protect the privacy and security of your personal information, particularly sensitive data, and to use it in a manner that is consistent with this Privacy Notice.

Retention of Data

The College retains personal information about students and alumni indefinitely for the purpose of alumni relationships, academic record-keeping, and archiving purposes. Other personal information will be retained in accordance with applicable College data retention policies or for audit or system integrity purposes.

Communications from College of the 51С�Ƴ�

The College of the 51С�Ƴ� and the 51С�Ƴ� Alumni Association periodically send marketing communications to alumni, supporters, and other members of the College community, such as newsletters, event invitations, and fundraising information. If you would like to request that College or the 51С�Ƴ� Alumni Association limit or stop these marketing communications with you, please contact us at privacy@holycross.edu . If you request to be removed from our mailing lists, we will retain your contact information to ensure that we do not continue to contact you for these purposes. If applicable, we will also continue to process your personal information for other purposes consistent with this Privacy Notice.

Individual Rights

If you are located in the EEA, you may have the following legal rights under applicable law with respect to the personal information processed by the College:

To withdraw consent at any time, if we are processing your personal information on the basis of consent
To access the information that the College has about you
To request that the College rectify or erase your information
To request that the College restrict the way it uses your information
To object to the way the College uses your information
To ask the College to transfer your information to someone else
To lodge a complaint with a data protection authority in the EEA
The College’s ability or obligation to comply with your requests may be limited by applicable law.

To request to exercise one of these rights, please contact us at privacy@holycross.edu.l

Changes to this Privacy Notice

The College reserves the right to amend this Privacy Notice at any time, for any reason, without notice to you. Any changes will be published here and you should check our website to access our current Privacy Notice. This Privacy Notice was last updated on November 1, 2018.

Contact Information

The controller of the personal information described in this Privacy Notice is:

The College of the 51С�Ƴ�
One College Street
Worcester, MA 01610
Email: privacy@holycross.edu

The College’s legal representative in the EEA is:

[To be determined]

Questions, concerns, requests, or complaints regarding this Privacy Notice and the processing of personal information by the College should be directed to privacy@holycross.edu.

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