Ä¢¹½ÊÓÆµios

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Privacy Policy

Purpose

Protecting your privacy and maintaining the accuracy of data Ä¢¹½ÊÓÆµios (Ä¢¹½ÊÓÆµios or the College) collects is of paramount importance and obligations the College takes very seriously. This policy applies to all Ä¢¹½ÊÓÆµios employees, students, contractors, volunteers, and visitors, and is balanced with Ä¢¹½ÊÓÆµios legal, policy and administrative duties in managing data.

This Privacy Policy applies to the information provided to Ä¢¹½ÊÓÆµios and which Ä¢¹½ÊÓÆµios maintains when you visit Ä¢¹½ÊÓÆµios main website,Ìýwww.menlo.edu,Ìý, other websites Ä¢¹½ÊÓÆµios controls, refers to or links to this policy, as well as other information maintained by the College in carrying out its mission. This policy also outlines how this information is processed or used, as well as the choices available to you regarding the use of information you provide to Ä¢¹½ÊÓÆµios which Ä¢¹½ÊÓÆµios maintains.

Definitions

For purposes of this policy, Personal Data is any information that can reasonably be used to identify you. [1]

Sensitive Personal Dataincludes special categories of Personal Data (e.g., racial or ethnic origin, citizenship, religious affiliation, genetic data, biometric data, data concerning health, and data concerning a person sex life or sexual orientation) for which applicable law provides enhanced protections.

Privacy Principles

  • Ä¢¹½ÊÓÆµios does not collect any more personal data than is necessary to provide services to the campus community;
  • Ä¢¹½ÊÓÆµios uses personal data for improving services provided to the campus community;
  • Ä¢¹½ÊÓÆµios uses your personal data for the purposes specified in this policy, unless agreed otherwise in writing;
  • Ä¢¹½ÊÓÆµios does not keep personal data if it is no longer needed; and
  • Other than as specified in this policy, Ä¢¹½ÊÓÆµios does not sell, rent, or share your personal data with third parties.

Your Rights

  • Right of Correction “Ä¢¹½ÊÓÆµios shall comply with requests to edit and update inaccurate Personal Data promptly
  • Right to Deletion “ Ä¢¹½ÊÓÆµios shall delete your Personal Data promptly if:
    • It is no longer necessary to retain Personal Data;
    • Consent, which formed the basis of Personal Data processing is withdrawn
    • An objection to the processing of Personal Data is submitted in writing and there are no overriding legitimate grounds for such processing;
    • The Personal Data was processed illegally; or
    • The Personal Data must be deleted in order for Ä¢¹½ÊÓÆµios to comply with its legal obligations.
  • Ä¢¹½ÊÓÆµios may decline requests for deletion if the processing of Personal Data is necessary to:
    • Comply with Ä¢¹½ÊÓÆµios legal obligations;
    • In connection with legal action;
    • To detect and monitor fraud; or
    • In performing a task in the public interest.

Collecting Data

Ä¢¹½ÊÓÆµios does not collect personally identifying information about you when you visit Ä¢¹½ÊÓÆµios site “unless you choose to provide such information to Ä¢¹½ÊÓÆµios Providing such information is strictly voluntary. This policy is your guide to how Ä¢¹½ÊÓÆµios will handle information it learns about you from your visit to this website.

  • Reading or Downloading “ Ä¢¹½ÊÓÆµios collects and stores only the following information about you: the name of the domain from which you access the Internet (for example, aol.com, gmail.com, yahoo.com, or www.menlo.edu if you are connecting from Ä¢¹½ÊÓÆµios domain, the date and time you access Ä¢¹½ÊÓÆµios site, and the Internet address of the Web site from which you linked to Ä¢¹½ÊÓÆµios site. Ä¢¹½ÊÓÆµios uses the information Ä¢¹½ÊÓÆµios collects to measure the number of visitors to the different sections of Ä¢¹½ÊÓÆµios site, and to help Ä¢¹½ÊÓÆµios make its site more useful to visitors.
  • Online Profile Updates and Donations “ If you complete the Profile update forms during orientation, and share your personally identifying information, this information will be used only to provide you with more targeted content. Ä¢¹½ÊÓÆµios may use your contact information to send further information about Ä¢¹½ÊÓÆµios or to contact you when necessary. You may always opt-out of receiving future mailing by contacting privacy@menlo.edu.
  • Sending Ä¢¹½ÊÓÆµios an Email “ You also may decide to send Ä¢¹½ÊÓÆµios personally identifying information, for example, in an electronic mail message containing a question or comment, or by filling out an internal form that provides this information to Ä¢¹½ÊÓÆµios. Ä¢¹½ÊÓÆµios uses this personally identifying information from email primarily to respond to your requests. Ä¢¹½ÊÓÆµios may forward your email to other employees who are better able to answer your questions. Ä¢¹½ÊÓÆµios may also use your email to contact you in the future about Ä¢¹½ÊÓÆµios programs that may be of interest.
  • Ä¢¹½ÊÓÆµios wants to be very clear: It will not obtain personally identifying information about you when you visit Ä¢¹½ÊÓÆµios site, unless you choose to provide such information to Ä¢¹½ÊÓÆµios. Providing such information is strictly voluntary. Except as might be required by law, Ä¢¹½ÊÓÆµios does not share any information it receives with any outside parties.

Data Subject Rights

You have certain rights with respect to your Personal Data. Ä¢¹½ÊÓÆµios takes reasonable steps to ensure your Personal Data is relied upon for its intended use, is accurate, complete, and up to date. If you wish to contact us directly about accessing, correcting, updating, or deleting your personal data, or altering your Personal Data, you may do so at any time by contactingprivacy@menlo.edu. Ä¢¹½ÊÓÆµios shall consider your request in accordance with applicable laws.

You may also object to processing of your Personal data, ask to restrict processing or your Personal Data, or request portability of your Personal Data by contactingprivacy@menlo.edu.

Similarly, if Ä¢¹½ÊÓÆµios has collected and processed your Personal Data with your consent, you may withdraw your consent at any time by contactingprivacy@menlo.edu. Withdrawing your consent will not affect the lawfulness of any processed conducted prior to your withdrawal, nor will it affect the processor of your Personal Data conducted in reliable on lawful processing notwithstanding the absence of consent.

Privacy Requests and Authentication

Ä¢¹½ÊÓÆµios responds to all requests received from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Ä¢¹½ÊÓÆµios may ask you to verify your identity in order to help Ä¢¹½ÊÓÆµios respond efficiently to your request. Ä¢¹½ÊÓÆµios will only use Personal Data provided in an opt-out request to review and comply with the request.

Non-Discrimination and Non-Retaliation

Ä¢¹½ÊÓÆµios shall not discriminate or retaliate against anyone for exercising their rights under this policy.

Use of Cookies on Ä¢¹½ÊÓÆµios.edu

Ä¢¹½ÊÓÆµios uses cookies and tracking technologies on its website to improve functionality and analyze visitor behavior. Cookies may have unique identifiers and reside, among other places, in your device, in emails Ä¢¹½ÊÓÆµios sends to you and on Ä¢¹½ÊÓÆµios website.

Ä¢¹½ÊÓÆµios uses cookies to collect and use data such as IP addresses, visited pages, and browser details. These cookies enable features such as login and more convenient access to the MyÄ¢¹½ÊÓÆµios portal. Cookies are usually only set in response to actions taken by users which amount to a request for services, such as setting your privacy preferences, logging-in, or filling-in forms. Users can manage their browser settings to limit the use of cookies, but disabling cookies entirely may negatively affect certain site functions.

Ä¢¹½ÊÓÆµios website uses cookies during on-line sessions for certain legitimate business interests, which may include delivering content specific to your interests, collecting the domain name of the service which you are visiting, and providing Ä¢¹½ÊÓÆµios with information about the site performance. Cookies also allow Ä¢¹½ÊÓÆµios to avoid showing the same ad or other message repeatedly. Cookies enable Ä¢¹½ÊÓÆµios to relate your use of the site to information that you have specifically and knowingly provided to Ä¢¹½ÊÓÆµios website. Ä¢¹½ÊÓÆµios does not store or share cookies externally, nor does it allow second-party or third-party cookies to be placed on Ä¢¹½ÊÓÆµios.edu.

You may control and/or delete cookies as you wish For details, including how to prevent your browser from accepting cookies or how to disable cookies, seeor contactprivacy@menlo.edu.

Legal and Regulatory Compliance

Ä¢¹½ÊÓÆµios complies with the Family Educational Rights and Privacy Act (), which prohibits educational institutions from releasing most education records without student consent.

Citizens of the European Economic Area (EEA) have additional rights regarding the use of and access to their own personal data, under the provisions of the European Union General Data Protection Regulation (), and California residents have additional rights when dealing with larger, profit-making entities in this state, under the California Consumer Privacy Act (). Because Ä¢¹½ÊÓÆµios is neither located in the EEA nor is it a profit-making enterprise, Ä¢¹½ÊÓÆµios is not legally required to conform to either of these policies, but Ä¢¹½ÊÓÆµios nevertheless pledges to do its best to respect them.

Requests for Information

Ä¢¹½ÊÓÆµios shall comply with all reasonable requests for information, subject to legal obligations and legitimate interests. Any request for student information should be forwarded toregistrar@menlo.edu. Ä¢¹½ÊÓÆµios will not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If Ä¢¹½ÊÓÆµios determines that the request warrants a fee, it will tell you why that decision was made and provide you with a cost estimate before completing your request.

If you have questions about FERPA, GDPR, or CCPA, or if you wish to contact Ä¢¹½ÊÓÆµios in connection with the exercise of your own privacy rights, please contactprivacy@menlo.edu. Ä¢¹½ÊÓÆµios cannot respond to your request or provide you with Personal Data if it cannot verify your identity or authority to make and request and confirm the Personal Data relates to you. Requests made through your password protected account sufficiently verified when the request relates to Personal Data associated with that particular account shall be processed. Ä¢¹½ÊÓÆµios will only use Personal Data provided in a verifiable consumer request to verify the requestor identity or authority to make the request.

Please note that, in certain circumstances, Ä¢¹½ÊÓÆµios may not be able to delete your Personal Data without also deleting your user account. Ä¢¹½ÊÓÆµios may be required to retain some of your Personal Data after you have requested deletion, to satisfy its legal or contractual obligations. Ä¢¹½ÊÓÆµios may also be required by applicable laws to retain some of your Personal data to satisfy its business needs.

Ä¢¹½ÊÓÆµios shall respond to your written request without unreasonable delay and in accordance with any deadlines imposed by law. Unless Ä¢¹½ÊÓÆµios notifies you at the time of your request, it will not charge you any fee in connection with the exercise of your rights.

Right to Appeal

If you have any concerns about the policy or the way in which Ä¢¹½ÊÓÆµios processes your Personal Data, please contactprivacy@menlo.edu.

Policy Changes

Ä¢¹½ÊÓÆµios intends this policy to be a general statement and may be subject to more specific privacy notices that pertain to personal information related to specific departments or functions at Ä¢¹½ÊÓÆµios. Likewise, Ä¢¹½ÊÓÆµios reserves the right, at our discretion, to change, modify or remove portions of this policy at any time. Please check this policy periodically for changes.

Examples of the Types of Information that may be Collected

Ä¢¹½ÊÓÆµios uses email and web links to respond to questions or comments directly. Occasionally, our website includes links to external resources for convenience. These external sites are not controlled or endorsed by Ä¢¹½ÊÓÆµios and may have their own privacy policies or none at all. When you access or use Ä¢¹½ÊÓÆµios sites, it may collect and process the following information from you.

Purpose of ProcessingCategories of Personal DataLegal Basis
As part of the undergraduate and graduate admissions process, Ä¢¹½ÊÓÆµios collects applicant Personal Data to evaluate applications.

Ä¢¹½ÊÓÆµios also may obtain Personal Data from third parties, such as other schools, references, family members, and education partners (e.g. FAFSA) as part of the application package
Name, address, contact details, race/ethnicity, demographic information, educational history, testing history, and other relevant information as part of the application processNecessary to evaluate candidates for admission and for internal statistical and analytics purposes

Consent: Processing of Sensitive Personal Data for purposes stated above
To evaluate and determine whether financial aid opportunities are available to an applicantName, address, contact details, demographic information, salary history, tax forms, and other relevant information to evaluate financial aid eligibility and opportunities
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 data for purposes state above
To enroll in wellness programsName, ID
To identify eligible individual interested in participating in a variety of wellness programs, courses, activities, facilitate enrollment and communications about the programs

Contract: Waiver or contract for participation includes personal data in order to process
To process employment applicationsName, ID, demographic information, resumesFor individuals interested in employment opportunities and in order to process applications
To process visa applicationsName, demographic information, financial information, passport number, USCIS informationUS Government legal requirements
To support course registrationName, ID, contact informationNecessary for students, staff, faculty and administration as appropriate for the courses or classes
To process requests for housing and dining servicesName, ID, contact informationFacilitates housing requests and meal plans
To provide online/hybrid training, academic courses and educational programs when necessaryName, ID, contact information, demographic information, platform usage and interaction, student provided data and contentFacilitates provision, administration, instruction, and quality improvement of platform use, courses, learning, and teaching/instruction to students, staff, faculty members, as appropriate for the courses and classes
To enroll interested individuals in research opportunitiesName, contact information
Upon request from students and faculty, information informs candidates about research opportunities
To process student worker assignmentsName, contact information
Upon request from students, faculty, administration and third party vendors, information informs candidates about opportunities
To submit requests for services (e.g., IT, helpdesk, helpline, Safety & Security)Name, ID, contact informationTo process service requests from students, staff and faculty; to gather metrics regarding use of services

Contract: If a contract governs use of the services, personal data is processed pursuant to that contract
Website account informationName, contact information, relationship to collegeFor websites that require registration for access, to facilitate the registration
Travel sitesName, ID, contact information, passport number, emergency contactsTo facilitate travel arrangements and coordination for students, faculty and staff through college programs

Contract: If there is a contract governing use of travel sites, personal data is processed pursuant to that contract
To request and receive donations, and assess donor and prospective donor giving activitiesName, contact information, demographic and biographic information, education records, employment information, affiliation with the college, giving history, payment informationTo college and process donations/gifts anddonor and prospective donor information
To receive brochures or other informationName, contact information
To send brochures or other requested information
To purchase tickets to campus eventsName, ID, contact information
To process ticket payment for a variety of events
For campus event registrationName, ID, contact information
To process registration for sports, cultural, educational and other university events
To purchase parking passes and permitsName, ID, contact information
Contract: to facilitate payments for parking passes and permits

[1] Personal Data does not include:

¢ Publicly available information from government records;
¢ Lawfully obtained, truthful information that is a matter of public concern;
¢ Deidentified or aggregated consumer information or information specifically excluded from the scope of applicable data protection laws such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Family Education Rights and Privacy Act (FERPA); and
¢ Clinical trial data or other biomedical research study or Personal Data covered by certain sector-specific privacy laws including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), and the Drivers Privacy Protection Act of 1994.

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