Privacy Policy

As used in this Privacy Policy, the following terms have the following meanings:

“We”, “us”, and “our” refer to St. George’s University.

“Business Associates” means third party service providers which St. George’s University may contract with to provide services on our behalf including those related to the Sites or for transactions occurring on the Sites including, but not limited to, Social Networking, hosting, web analytics, Online Behavioral Advertising, lead generation, academic, business, career, or financial services.

“Educational Partners” means St. George’s University and their subsidiaries and affiliates.

“Unrelated Entities” means third parties that are not Educational Partners and who are not providing services as Business Associates

“Affiliates” means companies related by common ownership or control.

“Nonaffiliates” means companies not related by common ownership or control.

“Information” means any Information collected and includes:  “Personal Information”, “Web Analytical Information” or any other Information collected from you through our Sites.

“Personal Information” means Information that may be used, alone or in combination, to identify a specific individual and includes Financial Information.

“Personal Data” is the UK / EU GDPR definition of data in scope for related protections. It means data that can and may be used, alone or in combination with other available data, to identify a specific living individual. It does not include financial data.

“Online Behavioral Advertising” means the collection of data from a particular computer or device regarding web viewing behaviors over time and across web sites for the purpose of using such data to predict user preferences or interests to deliver advertising to that computer or device based on the preferences or interests inferred from such Web viewing behaviors.

“Site” or “Sites” means websites operated by or exclusively on behalf of St. George’s University, regardless of domain name or IP address.

“Social Network” means various Internet communication technologies provided on sites that facilitate conversation and interaction between people online and includes, but is not limited to, blogs, discussion forums, wikis, chat sessions, news groups, etc.

“Web Analytical Information” means internet-generated Information we collect when you visit our Sites.  This Information may be linked with Personal Information.  When linked with other Information identifying you personally, either alone or in combination with other Information, then such Information also will be considered Personal Information.

Purpose of Processing	Categories of Personal Information	Legal Basis (UK / EU GDPR)
As part of the graduate and undergraduate admissions process, we collect applicant Personal Information to evaluate applications. We also may obtain Personal Information from third parties, such as other schools, references, family members, and education partners (e.g., The Common Application, the Medical Common Application etc.) as part of an application package.	Name, address, contact details, race/ethnicity, demographic information, educational history, reference letters, and other relevant information as part of the application package.	Legitimate Interest: Personal Information collected through the graduate or undergraduate application is necessary to evaluate candidates for admissions and for our internal statistical and analytics purposes. Consent: Processing of Sensitive Personal Information for purposes stated above
To evaluate and determine whether financial aid opportunities are available to an applicant	Name, address, contact details, demographic information, salary history, tax forms and other relevant information to evaluate financial aid eligibility and opportunities.	Legitimate Interest: Personal Information collected through the financial aid application is necessary to evaluate whether the applicant is eligible to receive financial aid and for our internal statistical and analytics purposes. Consent: Processing of Sensitive Personal Information for purposes stated above
To support course registration	Name, Unique ID, contact information	Legitimate Interest: Personal Information collected for matriculated students, staff, faculty and members of the public, as appropriate for the course, to register in courses or classes
To process requests for housing and dining services	Name, Unique ID, contact information	Legitimate Interest: Personal Information collected to facilitate housing requests and for available meal plans
To provide online/hybrid training, online/hybrid academic courses, and other online/hybrid educational programs	Name, unique ID, contact information, demographic information, platform usage and interaction, student-provided data and content	Legitimate Interest: To facilitate provision, administration, instruction, and quality improvement of platform use, courses, learning, and teaching/instruction to matriculated students, staff, faculty, and members of the public, as appropriate for the course
To enroll interested individuals in research opportunities	Name, contact information	Legitimate Interest: Upon request from the individual, inform registrants about research opportunities
To enroll in wellness programs	Name, Unique ID	Legitimate Interest: For eligible individuals interested in participating in a variety of wellness programs, courses, activities, facilitate enrollment and communications about the programs Contract: If there is a contract for participation in wellness programs, Personal Information is processed pursuant to that contract
To process employment applications	Name, Unique ID (if available), demographic information, resumes	Legitimate Interest: For individuals interested in employment opportunities, processing applications
To process visa applications	Name, demographic information, financial information, passport number	Legal Requirements
To request and receive donations, and assess donor and prospective donor giving activities	Name, contact information, demographic and biographic information, affiliation to SGU, giving history, payment information	Legitimate Interest: To collect and process donations/gifts and donor and prospective donor information
To receive brochures or other information	Name, contact information	Legitimate Interest: To send brochures or other requested information
To purchase tickets to events	Name, Unique ID (if available), contact information	Contract: To process ticket payment for a variety of events
For event registration	Name, Unique ID (if available), contact information	Legitimate Interest: To process registration for sports, cultural, educational, and other university events
To purchase parking passes and permits	Name, Unique ID, contact information	Contract: To facilitate payments for parking passes and permits
To submit requests for services (e.g., IT, help desk etc.)	Name, Unique ID, contact information	Legitimate Interest: To process service requests from students, staff, and faculty Contract: If there is a contract that governs your use of such services, Personal Information is processed pursuant to that contract
Website account registration	Name, contact information, alumni status	Legitimate Interest: For websites that require registration for access, to facilitate the registration
Travel sites	Name, Unique ID, contact information, passport number, loyalty membership information, emergency contacts	Legitimate Interest: To facilitate travel arrangements and coordination for students and affiliated travellers through SGU programmes Contract: If there is a contract that governs your use of travel sites, Personal Information is processed pursuant to that contract
Marketing	Name, Unique ID (if available), contact information, IP address, device ID	Consent: To share information about additional educational opportunities programmes and services relevant to SGU and improve related services, marketing, and analytics

Each time you visit one of our Sites, Web Analytical Information is automatically gathered.  In general, this Information does not identify you personally.  Examples of Web Analytical Information include, but are not limited to:

• IP address
• Collection Date
• Publisher Name
• Connection Speed
• Day of Week or Time of Day (hour)
• Language settings
• Country, State, Designated Market Area (DMA), City (relating to IP address, if available)
• Domain (.com, .net, .mil, .org, .edu, etc.)

This information may be linked with Personal Information to accomplish the purposes described in this Privacy Policy.

We operate or may process information in multiple jurisdictions and some Educational Partners and Business Associates may be located outside of the jurisdiction in which you reside.

In such cases, your Personal Information may be collected, used, disclosed, stored, and processed in these other jurisdictions for the purposes described in this Privacy Policy.

The data protection and other laws of the United States and other countries might differ from your jurisdiction.  Where jurisdiction-specific requirements apply these have been taken into account when designing data protection and associated security controls.

Categories of third parties used for data processing include:

• Document Scanning and Storage
• Student Relationship Management
• IT Service Providers
• Student Recruitment and Application Validation
• Marketing agencies

These third parties support SGU to provide the data processing purposes described in the section above.

No mobile information will be sold or shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be sold or shared with any third parties/affiliates.

Californian Residents
These rights are applicable if you are resident in California

• Right to know
  The right to know about the personal information a business collects about you and how it is used and shared;
• Right to delete
  The right to delete personal information collected from you (with some exceptions);
• Right to opt out
  The right to opt-out of the sale of your personal information;
  SGU do not sell your information, so there is no requirement to provide a ‘Do Not Sell’ button to support you to exercise this right at present.
• Right to non-discrimination
  The right to non-discrimination for exercising your CCPA rights.

EU and UK Residents
These rights are applicable to data subjects resident in the European Union or UK

• Right of access
  You may request details of your Personal Information that we hold. We will confirm whether we are processing your Personal Information and we will disclose supplementary information including the categories of Personal Information, the sources from which it originated, the purpose and legal basis for the processing, the expected retention period, and the safeguards regarding Personal Information transfers to non-EEA countries, subject to the limitations set out in applicable statutes, regulations and other laws.
• Right of correction
  We will comply with your request to edit and update incorrect Personal Data promptly.
• Right to be forgotten
  At your request, we will delete your Personal Information promptly if:
  • it is no longer necessary to retain your Personal Data;
  • you withdraw the consent which formed the basis of your Personal Data processing;
  • you object to the processing of your Personal Data and there are no overriding legitimate grounds for such processing;
  • the Personal Data was processed illegally; or
  • the Personal Data must be deleted for us to comply with our legal obligations.
  • We will inform any third parties we might have shared your Personal Data with of your deletion request.
  • We will decline your request for deletion if processing of your Personal Data is necessary:
  • to comply with our legal obligations;
  • in pursuit of a legal action;
  • to detect and monitor fraud; or
  • for the performance of a task in the public interest.
• Right to restrict processing of your Personal Data
  At your request, we will limit the processing of your Personal Data if:
  • you dispute the accuracy of your Personal Data;
  • your Personal Data was processed unlawfully and you request a limitation on processing, rather than the deletion of your Personal Data;
  • we no longer need to process your Personal Data, but you require your Personal Data in connection with a legal claim; or
  • you object to the processing pending verification as to whether an overriding legitimate ground for such processing exists.
• Right to notice related to correction, deletion, and limitation on processing
  In so far as it is practicable, we will notify you of any correction, deletion, and/or limitation on processing of your Personal Data.
• Right to data portability
  At your request, we will provide you free of charge with your Personal Data in a structured, commonly used and machine readable format, if:
  • you provided us with Personal Data;
  • the processing of your Personal Data is based on your consent or required for the performance of a contract;
  • or the processing is carried out by automated means.
• Right to object
  Where we process your Personal Data based upon our legitimate interest then you have the right to object to this processing.
• Right not to be subject to decisions based solely on automated processing
  You will not be subject to decisions with a legal or similarly significant effect (including profiling) that are based solely on the automated processing of your Personal Data, unless you have given us your explicit consent or where they are necessary for a contract with us.
• Right to withdraw consent
  You have the right to withdraw any consent you may have previously given us at any time. If you withdraw your consent, this will not affect the lawfulness of our collecting, using and sharing of your Personal Data up to the point in time that you withdraw your consent. Even if you withdraw your consent, we may still use your information that has been fully anonymized and does not personally identify you.
• Right to complain to a supervisory authority
  If you are not satisfied with our response, you have the right to complain to or seek advice from a supervisory authority and/or bring a claim against us in any court of competent jurisdiction.

Our website is not targeted at minors. Minors are defined for the purpose of this Privacy Notice as children under 16. However, the age of digital consent (the age when children are legally viewed as capable of making their own choices about sharing personal data) varies between countries. In many EU states the age of digital consent is 13.

We recommend that no minor shares personal data with SGU without getting permission from a parent or guardian unless the age of digital consent in their country of residence permits them to do so.

We keep your Personal Data for as long as needed to fulfill the particular purpose for which it was collected. We may also retain your records if legally required or to fulfill a legitimate interest.

If you wish to contact us in connection with the exercise of your rights listed above, or in connection to anything else in this policy, please email us at compliance@sgu.edu.  We will respond to your written request without unreasonable delay and in accordance with any deadlines imposed by law. Unless we notify you at the time of your request, we will not charge you any fee in connection with the exercise of your rights.

Our online advertisements and Sites take part in Online Behavioral Advertising.  Some of these ads are targeted to your interests and preferences based on your browsing history, which is stored in a cookie on your computer.  Your browsing history on the Sites may be tracked in these cookies even if ads are not being displayed.

Internet Technologies Used
Cookies, web beacons, and other relevant internet technologies are used on our Sites to allow us to accomplish the uses set out above as well as to deliver Sites messaging and to keep track of your Information.

• What are cookies?
  Cookies save a file to an Internet user’s computer and store a limited amount of information.  For example, some cookies help us remember your computer and streamline the login process, some are used to authenticate you as a user on our systems, and some cookies help us deliver advertising that is more customized to your needs on our Web site and the Web sites of our partners.

  A cookie can either be stored in your computer’s memory temporarily and automatically deleted when you close your Web browser (a “session” cookie) or placed on your hard drive (a “persistent” cookie) by a Web server.  A persistent cookie is not deleted when the browser is closed and will stay in one of your browser’s subfolders until you delete it manually or your browser deletes it based on an expiration period setting contained within the persistent cookie’s programming.

  In addition to the general browser cookies, we may use Local Shared Objects (sometimes referred to as “Flash cookies” that are built for use with the Adobe® Flash® Player), for authentication purposes, to personalize and to enhance Web site presentation and functionality.  Unlike traditional cookies, Flash cookies cannot be managed through your browser controls and are not saved in your browser’s temporary Internet files.  Flash cookies remain in your Flash Player folder until they are removed, as described below.

  St. George’s University also uses Web Beacons (also known as clear gifs or pixel tags), which are images that we incorporate onto our Web site to analyze advertising campaigns and the general usage patterns of Web site visitors.

How does St. George’s University use these technologies?

• Browser Cookies
  Browser cookies are used by St. George’s University and its partners for targeted marketing activities and Web site analytics. Browser cookies are placed on sgu.edu by us as well as third-parties.  The information that we collect and share (e.g., IP Address of your computer and pages viewed) does not contain customer or consumer names, addresses, telephone numbers, or email addresses. This information helps our company refine and improve our Web site content and presentation, deliver relevant advertising regarding St. George’s University on other Web sites you visit and optimize our placement in search engine results.
• Flash Cookies
  Flash cookies may be used by St. George’s University for limited purposes, such as authentication, as well as distinguishing customers from visitors to our Web site.
• Web Beacons
  St. George’s University uses Web Beacons to help manage online advertising and site traffic analysis.  These image files are provided by third parties for external ad management, search marketing tracking, affiliate marketing, and sgu.edu site analytics.  In all such instances, the Web Beacon is programmed to collect your computer’s IP Address and certain other limited information when you are on our Web site.  We do not collect your name, e-mail address, or telephone numbers using this technology.  For example, with online advertising campaigns, Web Beacons enable third parties to recognize a cookie on your Web browser, which in turn enables us to learn which advertisements bring unique users to sgu.edu from other locations on the Web.

Cookie List
A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts. More specifically, we use cookies and other tracking technologies for the following purposes:

Targeting Cookies
These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

Performance Cookies
These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

Strictly Necessary Cookies
These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Functional Cookies
These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

Browser Cookies
You can change your cookie settings by reviewing your internet browser’s cookie options. The links below to popular browsers may help you understand your cookie options better. Typically, such information can be found under the browser’s ‘Help’, ‘Preferences’ or ‘Options’ menus.

• Cookie settings in Chrome
• Cookie settings in Firefox
• Cookie settings in Internet Explorer
• Cookie settings in Safari – iOS
• Cookie settings in Safari – macOS

Interest-Based Advertisements
Some of our Sites engage in online interest-based advertising to enhance your experience and show you advertisements that might interest you. Like many organizations, we and our advertising partners display tailored interest-based advertising using information you make available to us when you interact with our Sites.  Interest-based ads, also sometimes referred to as personalized or targeted ads, are displayed to you based on information from activities such as searching on our Sites or visiting websites that contain our content or ads. We do this using a variety of digital marketing networks and ad exchanges, and we use a range of advertising technologies like web beacons, pixels, ad tags, cookies, and mobile identifiers.

To learn more about interest-based ads or to opt-out of receiving third-party interest based ads, please visit http://optout.aboutads.info or www.youronlinechoices.eu. Please note that if you opt out of interest-based advertising, you will still see advertisements – they will just not be tailored to your interests.  Also note that deleting browser cookies can remove the cookie preferences you have made, so you may need to opt-out again in the future.

Blocking Cookies
Should you choose to decline or block cookies by adjusting your browser settings, including cookies essential to the Sites.  Please note that all or parts of our Sites may not be functional or accessible to you. Our Sites will issue cookies as soon you visit the Sites, unless your browser cookie settings are adjusted to prevent such an occurrence. Please review the information provided in this cookie policy on adjusting cookie settings for the browser of your choice.

Google Analytics
We use Google Analytics to help operate our Sites more efficiently, to gather demographic information, and to monitor the level of activity of our Sites. For information on how Google uses data from sites that share information with Google, see https://www.google.com/policies/privacy/partners/ (or other relevant URL that Google may provide from time to time). You can prevent the use of Google Analytics relating to your use of our Sites by downloading and installing the browser plugin available at this link: https://tools.google.com/dlpage/gaoptout?hl=en.

Site Hosting and Links from Our Sites to Other Websites
Some of our Sites may contain links to websites hosted by Educational Partners, Unrelated Entities, and Business Associates operating websites on their own behalf or on behalf of multiple entities.  Some of these websites may collect your Personal Information and may apply their own policies on how your Personal Information is used.  In addition, some of our Sites may have Additional Policies that apply to the use of Personal Information collected on that Site.  Please make sure to read the policies of any websites you visit on the internet carefully.  Please be aware that we are not responsible for the privacy practices or the content of any websites that are not operated by or exclusively for us, and the collection, use, and disclosure of Information about you will be subject to the policies applicable on those websites.

We will take commercially reasonable measures to secure and store your Information to protect against the loss, misuse, and alteration of the Information under our control. Unfortunately, no data transmission over the internet can ever be guaranteed to be completely secure. If you feel that the security of any data that we hold about you has been compromised, please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section above.

St. George’s University may update this Privacy Policy or revise it from time to time. We make every reasonable attempt to ensure that all the information on the Site is accurate and up to date. Nevertheless, we make no representations or warranties, whether express or implied, as to the accuracy, reliability or completeness of the information, text, graphics, links or other items contained in the Site or in any site linked to or from the Site. St. George’s University reserves the right to change the programs, policies and services described in this Site at any time without notice, and we will not be liable for any special or consequential damages that result from the use of, or inability to use, the materials in this Site. We urge you to review this Privacy Policy frequently to obtain the current version. Your continued provision of Personal Information or use of our services following any changes to this Privacy Policy constitutes your acceptance of such changes.