Effective Date: March 4, 2019
If you are a prospective student, an applicant for admission, a current student, or an alumnus at Saint Louis University (St. Louis or Madrid Campuses) (SLU) or an applicant for employment at SLU, we collect, store, use and disclose certain data about you.
SLU 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), we obtain from and about individuals interacting with SLU, its websites (the "Site"), products, and services. This Privacy Statement does not apply to SLU employees.
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 where applicable EU data protection laws apply, please see the "EU Section" below.
What Personal Data We Collect
As you interact with SLU 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 SLU 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 that provide or sell lists of potential students
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.
SLU 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 SLU 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 SLU St. Louis for students enrolling at SLU 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 SLU, including details of any degrees which you are awarded
- Any disabilities which you have disclosed to us (Only collected by SLU St. Louis for students enrolling at SLU St. Louis)
- Medical information, such as information held by the counseling service (Only collected by SLU St. Louis for students enrolling at SLU St. Louis)
- Financial information and scholarship details
- Information about your interests
- Information about your use of SLU 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 SLU 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, you enter into a contract with SLU 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./p>
With Whom We Share Your Personal Data
Your Personal Data may be shared between SLU entities (between the St. Louis and Madrid campuses) for all the purposes described above.
We may also provide some of our services through contractual arrangements with SLU service providers who process the 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 for the purposes of contacting you about attending our university or applying for employment with us.
We may also use or share your information in an anonymized or aggregate manner.
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 SLU, 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 SLU 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 whom SLU is sharing data, for 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.?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.?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.?However, you may refuse or delete cookies.?If you refuse or delete cookies, some of our website functionality may be impaired.? 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 firstname.lastname@example.org .
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 email@example.com
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 SLU, SLU 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
SLU 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.
SLU is a Data Controller for the purposes of the LOPD and the GDPR, and the Data Protection Officer on behalf of SLU can be contacted via:
- Phone: +34915545858
The address for correspondence in relation to EU data protection issues is:
- Saint Louis University - Madrid Campus, Avenida del Valle, 34 28003 Madrid Spain.
The address for correspondence in relation to U.S. data privacy issues is:
- Saint Louis University - Information Security Office, 3545 Lindell Blvd., Wool Center 3rd Floor, St. Louis, MO 63103.
For U.S. citizens, you may contact:
- For Student Information:?firstname.lastname@example.org
- For Employee Information:?HR@www.rcgktech.com
- For Alumni Information:?email@example.com
- For Donation Information:?firstname.lastname@example.org
- For Information regarding this website's security and privacy:?email@example.com (security and privacy)
Legal Basis for Processing Your Information
SLU, as a controller, will only 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 the personal information will depend on the personal information concerned and the specific context in which we collect it.
However, 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 enrolling as a SLU student, you understand that SLU will be collecting, storing, using and otherwise processing 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. We will also use your data for certain purposes after you cease to be student (alumni relations).
For questions or complaints regarding the LOPDGDD 3/2018 and the GDPR, the Information Commissioner can be contacted at:
- Post:?Agencia Espa?ola de Protección de Datos?
C/ Jorge Juan, 6
- Tel:?+34 901 100 099,? +34 91.266.35.17
- Information Commissioner's Office Website: http://www.rcgktech.com
Legal basis for processing your information
By commencing or enrolling as a SLU student, SLU 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 reasons?deemed necessary for the performance of your contractual agreement?with SLU. See GDPR Article 6(1)(b).
Processing of your personal data may also be?necessary for the pursuit of our legitimate interests or by a third party's legitimate interests?-but only when it will not cause a prejudicial effect on the rights and freedoms, or legitimate interests, of the student?See GDPR Article 6(1)(f).
Processing of your personal data is necessary?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).
SLU will obtain?consent?from you in order to assist with your pastoral and welfare needs (e.g. the counseling?service and services to students with disabilities).?See GDPR Article 6(1)(a).
Processing of Special Categories data is necessary for the?statistical and research purposes?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)
Your EU Privacy Rights
You have a number of rights under the Data Protection Legislation, LOPDGDD 3/2018 and the General Data Protection Regulation in respect to the information, which SLU holds about you, and how we can use that information. These include:
- The right to be informed about the data that we hold in relation to you and the purposes we intend to process that data for (see above).
- The right to prevent us from using your data for direct marketing purposes or for the purposes of scientific/historical research statistics.
- The right to prevent us from processing your data in a way that causes or is likely to cause you substantial damage or distress. However, we may refuse to accept such a notice in certain circumstances: for example, if doing so would prevent us from processing data that is necessary for our contract with you as a student.
- The right to restrict processing of your data under certain specified circumstances under the LOPDGDD and the GDPR.
- The right to require us to correct, erase or destroy inaccurate data.
- The right to have your data erased under additional specific circumstances under the GDPR.
- The right to get access to the data that we hold about you. To obtain a copy of this, for the LOPDGDD and GDPR, you may submit a subject access request to the DPO. For U.S. federal and state regulations you may contact SLU's Information Security Team.
- The right to data portability i.e. to use the data we hold on you for your own purposes.
- The right to not be subject to a decision when it is based on automated processing and that decision produces a legal effect or similarly significant effect on you as an individual.
You have the right to request access to copies of and rectification or erasure of personal data held by SLU and to object to processing. If we have asked for your consent in order to process your personal data, you can withdraw this consent in whole and part at any time. We will explain the consequences of doing so in any specific case if you contact us to withdraw consent.
The SLU Data Protection Officer on behalf of SLU 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:
- Saint Louis University - Madrid Campus, Avenida del Valle, 34 28003 Madrid Spain.
International Transfers of Your Personal Data
By providing personal data to SLU, your personal data may be transferred to the United States where SLU 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. Transfers from the European Economic Area ("EEA") to the United States will take place using the EU-U.S. and Swiss-U.S. Privacy Shield. Please contact firstname.lastname@example.org or DPOemail@example.com, if you want to receive further information or, where available, a copy of the relevant data transfer mechanism.
EU-U.S. and Swiss-U.S. Privacy Shield
SLU complies with the EU-U.S. and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States. SLU has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. The Federal Trade Commission has jurisdiction over SLU's compliance with the Privacy Shield. In the context of an onward transfer, SLU has the liability for the processing of Personal Data it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. To learn more about the Privacy Shield program, and to view our certification, please visit?https://www.privacyshield.gov/.
In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your Personal Data. European Union or Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact SLU firstname.lastname@example.org or DPOemail@example.com.
SLU has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If we have not resolved your complaint, you may contact or visit https://www.jamsadr.com/ for more information or to file a complaint. The services of JAMS are provided at no cost to you. Please note that if your complaint is not resolved through these channels, under limited circumstances, binding arbitration may be available. For additional information about the Privacy Shield arbitration process, please visit the?Privacy Shield website.
SLU?has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.