General Data Protection Regulation - University Policies - University of Dallas

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Data Privacy Notice for Students in the E.U.

This Notice describes the practices of University of Dallas (“UD”) with respect to the collection, use, storage, and disclosure (“processing”) of Personal Information of students while at our Rome campus. This Notice applies to UD, with headquarters at 1845 East Northgate Drive, Irving, Texas 75062, including our affiliated colleges, schools and campuses (collectively “UD,” “us” or “our”). All students studying at our Rome campus (referred to below as “you” or “your”) should carefully read the provisions of this Privacy Notice.

“Personal Information,” as used in this Notice, means any information that can be used to identify you, whether directly or indirectly, including by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.

This general notice may be supplemented by additional notices at the point of any data collection. If you have specific questions about any of the data processing activities described in this or any other notice, please contact the DPO.

The Information We Process About You
We process the information we collect from you directly, including when you apply to study abroad, during our communications with you, when you sign up for classes or other services, when you take classes, when you apply for financial aid, and when you make use of UD equipment, facilities, and resources. This includes information about you created by our faculty and staff, like your grades, scores, records of attendance and participation, and recorded observations about you. It also includes information about your payments made to us for tuition and other expenses.

In some cases, we will require that certain information be provided in order for us to provide you with a service or take an action you request. We will indicate when such information is required, and failure to provide required information may result in our being unable to provide you with a service or take a requested action.

We use automated decision-making processes to process your data in certain contexts. For example, we may automatically evaluate your grades or test scores to determine your eligibility for enrollment in certain programs, receipt of certain honors, or to provide you with offers of academic support. Similarly, the information in your financial aid application may be used to generate a profile of your financial circumstances that is used to make decisions about your eligibility for scholarships, loans, and other financial assistance throughout your enrollment at UD. You can find out more about the logic we use in our automated decision-making processes by contacting the DPO.

In addition, we collect the following kinds of information about you from third parties:

- Information we collect from other students or UD staff: Other students may provide us with information about you, whether in the process of reporting an incident or complaint on campus or alerting us to an emergency situation involving you. This information can include your name, information about your behavior or activities, and other information about the situation being reported to us.

Information about your prior or concurrent educational history, which we collect from other educational institutions (or from our own records in the event of a re-enrollment or enrollment for a different degree).
Health, wellness, and insurance information about you that we receive from healthcare providers and/or insurance companies.
Any criminal convictions or offenses, which we collect from third parties who provide us with such information.

UD maintains video surveillance systems for the security of our premises. UD or our contracted service operator may process images and video of you in connection with the operation of these systems.

Purposes and Legal Basis for Processing Your Data

We process your Personal Information to operate UD and the programs you are enrolled in, to provide you with financial aid, and to provide you with additional related services (like housing, internet access, and health services). These uses include to:

manage university billing, collecting, refunding and cashiering functions,
provide desktop and software support services,
administer programs and make decisions about course offerings,
facilitate class diversity,
monitor trends within our student body and individual courses,
verify identity,
ensure that the university is prepared for emergencies,
enforce UD policies and applicable laws,
file required reports with applicable governmental authorities,
provide immigration and mobility services for you when you travel abroad to study, and
facilitate student directory and promotional activities.

We combine the data that we collect in order to provide these functions.

We have the following legal bases for processing the information you provide us or that we collect about you:

We have a legitimate interest in retaining and educating qualified students, complying with laws and regulations that govern our conduct in the countries where we operate, and administering UD and its programs in an efficient, ethical, and appropriate manner. We process all the information we collect from or about you to meet these purposes.
During the period of your enrollment, we may be required to process your Personal Information to complete a contract that you have entered into with us, including to be admitted to a program or receive financial aid, housing, or another service from us.
We may be required to process your Personal Information to comply with laws applicable in the European Union or its member states, such as immigration laws.

When we process your Sensitive Personal Information on the basis of your consent, you may withdraw that consent at any time by contacting the DPO. If you withdraw your consent, we may still be required to process your Sensitive Personal Information to comply with applicable law, but we will explain to you at the time your consent is withdrawn what processing activities will continue for legal compliance purposes.

Finally, we process your Personal Information for additional purposes that are compatible with those already described, including for the purposes of conducting scientific, statistical, or historical research or for the purpose of creating archives in the public interest. Where possible, we do not use identifiable information for these purposes, or we take steps, including making use of pseudonymous data, to limit the amount of Personal Information we use in our research or archives.

Recipients of Your Personal Information

Your Personal Information will be received and processed by UD employees and personnel, including third parties who provide services to UD in connection with the purposes of processing described above. For example, we may disclose your information to service providers who help us make travel arrangements, support our information technology systems, or provide services to our students. We share your Personal Information with our service providers only when they have agreed to process your Personal Information only to provide services to us and have agreed to protect your Personal Information from unauthorized use, access, or disclosure.

We also disclose your information to government authorities as required by laws that regulate immigration, tax, compliance reporting, national security, and criminal activity.

Transfers to Third Countries

UD is an international university headquartered in the United States, and we may transfer your Personal Information to the United States. UD has executed Standard Contractual Clauses, as approved by the European Commission. These clauses permit UD to transfer Personal Information from the EU to third countries, including the United States. If you would like to receive a copy of UD’s Standard Contractual Clauses, you can contact the DPO.

Data Retention

You can find more information about how long we retain Personal Information by consulting our Retention and Disposal Policy, available here: http://lcsgxgy.com/about/university-policies/_documents/approved-records-retention-policy_9-18.pdf. In some cases, we may be required by law to retain your information for a longer period.

Your Rights

You have the right to the following information regarding UD’s processing of your Personal Information:

the purposes of the processing,
the categories of Personal Information concerned,
the recipients or categories of recipients to whom the Personal Information have been or will be disclosed,
where possible, the envisaged period for which the Personal Information will be stored, or, if not possible, the criteria used to determine that period.

This Privacy Statement is intended to provide this information. Any questions about these details may be directed to the DPO.

You also have the following additional rights with respect to your Personal Information processed while a student at our Rome campus:

The right to request access to the Personal Information that UD has about you, as well as the right to request rectification of any data that is inaccurate or incomplete.
The right to request a copy of your Personal Information in electronic format so that you can transmit the data to third parties, or to request that UD directly transfer your Personal Information to one or more third parties.
The right to object to the processing of your Personal Information for marketing and other purposes.
The right to erasure of your Personal Information when it is no longer needed for the purposes for which you provided it, as well as the right to restriction of processing of your Personal Information to certain limited purposes where erasure is not possible.
The right to lodge a complaint with the Italian data protection authority:
- Garante per la protezione dei dati personali  
  Piazza di Monte Citorio, 121 00186 Roma  
  Tel. +39 06 69677 1  
  Fax +39 06 69677 785  
  e-mail: garante@garanteprivacy.it  
  Website: http://www.garanteprivacy.it/

Data Privacy Notice for University of Dallas Employees in the European Union

This Notice describes the practices of the University of Dallas (“UD”) with respect to the collection, use, storage, and disclosure (“processing”) of Personal Information of employees while at our Rome campus. This Notice applies to UD, with headquarters at 1845 East Northgate Drive, Irving, Texas 75062, including our affiliated colleges, schools, and campuses (collectively “UD,” “us” or “our”). All employees working at our Rome campus (referred to below as “you” or “your”) should carefully read the provisions of this Privacy Notice.

The Information We Process About You

We process the information we collect from you directly, either during our communications with you, when you apply for employment, when you sign up for employment benefits, or when you make use of UD equipment and systems, facilities, programs, resources, and UD services provided by third-party vendors. This includes information about your employment history with UD, your job performance, compensation and benefits, and your dependents and emergency contacts.

In some cases, we may require certain information from you to provide you with a service or benefit. Failure to provide that information may mean we cannot provide you with that service or benefit.

We use automated decision-making processes to process your data in certain contexts. For example, we may automatically evaluate information about your compensation and benefits to withhold taxes or determine your eligibility for employee benefits or other programs. You can find out more about the logic we use in our automated decision-making processes by contacting the DPO.

In addition, we collect the following kinds of information about you from third parties:

Information about your employment history and education: We collect information about your employment history and education during the application process or when taking an employment action – such as considering you for a promotion or a new position at UD. We collect this information from your previous employers and the education institutions you attended.
Information about your professional certifications: We collect information about any professional certifications you might have from third parties that provide or verify those certifications.
Information about your health: We may collect information about your health from your health care provider or another third party you direct us to in order to provide necessary accommodations.
Information we collect from other employees or students: Other employees or students may provide us with information about you, whether in the process of reporting an incident on campus, alerting us to an emergency situation involving you, or as part of the employment process. This information can include your name, information about your behavior or activities, and other information about the situation being reported to us.
Immigration information: The Italian government and consulate may provide us with government identification, immigration information, or other information in order to facilitate travel related to your employment at our Rome campus.

Purposes and Legal Basis for Processing Your Data

We process your Personal Information to administer and manage UD programs and services, administer, manage, and evaluate your employment with UD, communicate with you regarding your employment, and provide you with access to UD programs, services, and facilities. We also use data to make strategic decisions about UD programs or course offerings, administer those programs, file required reports with applicable governmental authorities, and engage in financial planning. We also use your data for purposes required by law, including complying with application retention requirements, and for the enforcement of UD policies and applicable laws.

We combine the data that we collect in order to provide these functions.

We have the following legal bases for processing the information you provide us or that we collect about you during your employment on our Rome campus:

We have a legitimate interest in hiring and retaining qualified employees, complying with laws and regulations that govern our conduct in the countries where we operate, and administering UD and its programs in an efficient, ethical, and appropriate manner. We process all the information we collect from or about you to meet these purposes.
We may be required to process your Personal Information to fulfill our obligations pursuant to a contract of employment or an agreement to receive certain other benefits.
We may also be required to process your Personal Information to comply with laws applicable in the European Union or its member states, such as immigration laws.

In the case of Sensitive Personal Information (which includes (i) information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; (ii) genetic and biometric data, and (iii) data concerning health, sex life, or sexual orientation, we process information either (i) because we have your consent to do so or (ii) because we are required to process the information to comply with applicable laws. When we process your Sensitive Personal Information on the basis of your consent, you may withdraw that consent at any time by contacting the DPO. If you withdraw your consent, we may still be required to process your Sensitive Personal Information to comply with applicable law, but we will explain to you at the time your consent is withdrawn what processing activities will continue for legal compliance purposes.

Recipients of Your Personal Information

Your Personal Information will be received and processed by UD employees, students, and personnel, including third parties who provide services to UD in connection with the purposes of processing described above, like payroll and benefits service providers, technology providers that support UD’s systems and infrastructure, and other vendors acting on our behalf. We only share your Personal Information with our service providers when they have agreed to process your Personal Information only to provide services to us and have agreed to protect your Personal Information from unauthorized use, access, or disclosure.

We may also disclose your contact information at UD in staff and faculty directories available to UD students, employees, and the general public. You may request that your information be removed from these directories.

We may provide your information to other universities or entities to facilitate joint activities, including travel, collaborative events, professional affiliations, and research.

We also disclose your information to government authorities as required by laws that regulate immigration, tax, compliance reporting, national security, and criminal activity.

Transfers to Third Countries

Data Retention

You can find more information about how long we retain personal data by consulting our Retention and Disposal Policy, available here: http://lcsgxgy.com/about/university-policies/_documents/approved-records-retention-policy_9-18.pdf. In some cases, we may be required by law to retain your information for a longer period.

Your Rights

You have the right to the following information regarding UD’s processing of your Personal Information:

the purposes of the processing,
the categories of Personal Information concerned,
the recipients or categories of recipients to whom the Personal Information have been or will be disclosed,
where possible, the envisaged period for which the Personal Information will be stored, or, if not possible, the criteria used to determine that period.
This Privacy Statement is intended to provide this information. Any questions about these details may be directed to the DPO.

You also have the following additional rights with respect to your Personal Information processed while you are employed on our Rome campus:

The right to request access to the Personal Information that UD has about you, as well as the right to request rectification of any data that is inaccurate or incomplete.
The right to request a copy of your Personal Information in electronic format so that you can transmit the data to third parties, or to request that UD directly transfer your Personal Information to one or more third parties.
The right to object to the processing of your Personal Information for marketing and other purposes.
The right to erasure of your Personal Information when it is no longer needed for the purposes for which you provided it, as well as the right to restriction of processing of your Personal Information to certain limited purposes where erasure is not possible.
The right to lodge a complaint with the Italian data protection authority:
- Garante per la protezione dei dati personali  
  Piazza di Monte Citorio, 121 00186 Roma  
  Tel. +39 06 69677 1  
  Fax +39 06 69677 785  
  e-mail: garante@garanteprivacy.it  
  Website: http://www.garanteprivacy.it/

Data Privacy Notice for University of Dallas Prospective Students and Their Families in the European Union

This Notice describes the practices of the University of Dallas (“UD”) with respect to the collection, use, storage, and disclosure (“processing”) of Personal Information covered by the European Union’s General Data Protection Regulation for purposes of recruiting and evaluating prospective students and processing applications for admission. This Notice applies to UD, with headquarters at 1845 East Northgate Drive, Irving, Texas 75062, as well as to its affiliated colleges, schools, and campuses (collectively “UD,” “us” or “our”) with respect to prospective students and their families located in the European Union, Iceland, Norway, Liechtenstein, and Switzerland. All such prospective students and their families (referred to below as “you” or “your”) should carefully read the provisions of this Privacy Notice.

The Information We Process About You

We process the information we collect from you directly, either during our communications with you about UD or as part of your application to UD, including applications for financial aid. In addition to submitting an application directly to us, you may submit an application through the Common Application or via other third party sites through which UD collects prospective student applications or financial aid information.

During the application process, we will indicate when certain information is required in order for UD to process your application. Failure to complete a required field may result in your application being denied or your ineligibility for financial aid.

We use automated decision making processes to screen applicants for financial aid according to predetermined criteria. For example, the information in your financial aid application may be used to generate a profile of your financial circumstances that is used to make decisions about your eligibility for scholarships, loans, and other financial assistance. You can find out more about the logic we use in our automated decision-making processes by contacting the DPO.

In addition, we collect the following kinds of information about you from third parties:

Your contact and demographic information, including publically available information, which we collect from third parties who provide us information about prospective students who may be interested in attending UD. We also collect this contact information from students about their parents and family members.
Any criminal convictions or offenses, which we collect from third parties who provide us with such information.
Specific personal background and health details, which we collect from third parties.
Information about your prior educational history, which we collect from other educational institutions (or from our own records in the event of a re-enrollment or enrollment for a different degree).

UD maintains video surveillance systems for the security of our premises. UD or our contracted service operator may process images and video of you in connection with the operation of these systems.

Purposes and Legal Basis for Processing Your Data

We process your Personal Information to recruit prospective students, evaluate applications for admission to UD, evaluate your eligibility for financial aid, communicate with you about UD and your application, and, if you are admitted to UD, to award you financial aid and to enroll you in UD programs if you choose to attend. We also use this data to:

administer programs and make decisions about course offerings,
file required reports with applicable governmental authorities,
facilitate class diversity,
administer our programs and provide appropriately tailored services, including student health services, financial aid, and research and reporting activities,
monitor trends within incoming classes,
report application and admission statistics to appropriate publications,
plan course offerings,
verify identity,
ensure that the university is prepared for emergencies, and
enforce UD policies and applicable laws.

We combine the data that we collect in order to provide these functions.

We have the following legal basis for processing the information you provide us in your application or that we collect about you during the application process:

We have a legitimate interest in recruiting and admitting qualified applicants, complying with laws and regulations that govern our conduct in the countries where we operate, and administering UD and its programs in an efficient, ethical, and appropriate manner. We process all the information we collect from or about you to meet these purposes..
Once you have accepted an offer of admission from us, we may also be required to process your Personal Information to complete a contract that you have entered into with us, including to be admitted to a program, or receive financial aid, housing, or another service from us.

You can obtain additional information about the processing we do to comply with applicable laws by contacting the DPO.

In the case of Sensitive Personal Information (which includes (i) information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; (ii) genetic and biometric data, and (iii) data concerning health, sex life, or sexual orientation), we process information because we have your consent to do so. When we process your Sensitive Personal Information on the basis of your consent, you may withdraw that consent at any time by contacting the DPO. If you withdraw your consent, we may still be required to process your Sensitive Personal Information to comply with applicable law, but we will explain to you at the time your consent is withdrawn what processing activities will continue for legal compliance purposes.

Recipients of Your Personal Information

Your Personal Information will be received and processed by UD employees and personnel, including third parties who provide services to UD in connection with the purposes of processing described above, including third-parties that provide us with technical support for the application process, and provide us with application collection services. We share your Personal Information with our service providers only when they have agreed to process your Personal Information only to provide services to us and have agreed to protect your Personal Information from unauthorized use, access, or disclosure. We provide Personal Information to research partners, printers and mailing houses, college board members, and the Texas Higher Education Coordinating Board.

We also disclose your information to government authorities as required by laws that regulate immigration, tax, compliance reporting, national security, and criminal activity.

Transfers to Third Countries

Data Retention

Your Rights

You have the right to the following information regarding UD’s processing of your Personal Information:

the purposes of the processing,
the categories of Personal Information concerned,
the recipients or categories of recipients to whom the Personal Information have been or will be disclosed,
where possible, the envisaged period for which the Personal Information will be stored, or, if not possible, the criteria used to determine that period.

This Privacy Statement is intended to provide this information. Any questions about these details may be directed to the DPO.

You also have the following additional rights with respect to your Personal Information:

The right to request access to the Personal Information that UD has about you, as well as the right to request rectification of any data that is inaccurate or incomplete.
The right to request a copy of your Personal Information in electronic format so that you can transmit the data to third parties, or to request that UD directly transfer your Personal Information to one or more third parties.
The right to object to the processing of your Personal Information for marketing and other purposes.
The right to erasure of your Personal Information when it is no longer needed for the purposes for which you provided it, as well as the right to restriction of processing of your Personal Information to certain limited purposes where erasure is not possible.
The right to lodge a complaint with the Italian supervisory authority or the supervisory authority for the country where you live or work or where you believe that your rights have been violated:
- Garante per la protezione dei dati personali
  Piazza di Monte Citorio, 121 00186 Roma
  Tel. +39 06 69677 1
  Fax +39 06 69677 785
  e-mail: garante@garanteprivacy.it
  Website: http://www.garanteprivacy.it/

A full list of supervisory authority contacts for E.U. countries is available here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

Data Privacy Notice for University of Dallas Prospective Employees in the European Union

This Notice describes the practices of the University of Dallas (“UD”) with respect to the collection, use, storage, and disclosure (“processing”) of Personal Information covered by the European Union’s General Data Protection Regulation for purposes of recruiting and evaluating prospective employees and processing applications for employment. This Notice applies to UD, with headquarters at 1845 East Northgate Drive, Irving, Texas 75062, as well as to its affiliated colleges, schools, and campuses (collectively “UD,” “us” or “our”) solely with respect to prospective employees of UD’s Rome Campus. All such prospective employees (referred to below as “you” or “your”) should carefully read the provisions of this Privacy Notice.

The Information We Process About You

We process the information we collect from you directly, either during our communications with you about UD or as part of your application for employment at UD.

In addition, we collect the following kinds of information about you from third parties:

Your contact and demographic information, including publically available information, which we collect from third parties who provide us information about prospective employees who may be interested in working at UD.
Any criminal convictions or offenses, information about your credit, and other information about your previous employment and education, which we collect as part of a background check process (where permitted by applicable law) from government records, credit reporting companies, your previous employers, and other academic institutions.

Purposes and Legal Basis for Processing Your Data

We process your Personal Information to recruit prospective employees, evaluate applications for employment at UD, evaluate your eligibility for employment, communicate with you about UD and your application, and, if you are offered a position at UD, to manage your acceptance of our offer of employment and begin the process of onboarding you as a new employee. We also use data to make strategic decisions about UD programs or course offerings, administer those programs, file required reports with applicable governmental authorities, and engage in financial planning. We also use your data for purposes required by law, including complying with application retention requirements, and for the enforcement of UD policies and applicable laws.

We combine the data that we collect in order to provide these functions.

We have the following legal basis for processing the information you provide us in your application or that we collect about you during the application process.

We have a legitimate interest in recruiting and hiring qualified applicants, complying with Italian laws and regulations, and administering UD and its programs in an efficient, ethical, and appropriate manner. We process all the information we collect from or about you to meet these purposes.
Once you have accepted an offer of employment from us, we may also be required to process your Personal Information to complete a contract that you have entered into with us, including a contract of employment or an agreement to receive certain other benefits.
We may also be required to process your Personal Information to comply with laws applicable in the European Union or its member states, such as tax laws.

In the case of Sensitive Personal Information (which includes (i) information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; (ii) genetic and biometric data, and (iii) data concerning health, sex life, or sexual orientation), we process information either (i) because we have your consent to do so or (ii) because we are required to process the information to comply with applicable laws. When we process your Sensitive Personal Information on the basis of your consent, you may withdraw that consent at any time by contacting the DPO. If you withdraw your consent, we may still be required to process your Sensitive Personal Information to comply with applicable law, but we will explain to you at the time your consent is withdrawn what processing activities will continue for legal compliance purposes.

Finally, we process your Personal Information for purposes compatible with those already described, including for the purposes of conducting scientific, statistical, or historical research or for the purpose of creating archives in the public interest. Where possible, we do not use identifiable information for these purposes, or we take steps, including making use of pseudonymous data, to limit the amount of Personal Information we use in our research or archives.

Recipients of Your Personal Information

Your Personal Information will be received and processed by UD employees and personnel, including third parties who provide services to UD in connection with the purposes of processing described above, including background-check providers, service providers that support our application software and other programs, and service providers that support our human resources and hiring functions. We share your Personal Information with our service providers only when they have agreed to process your Personal Information only to provide services to us and have agreed to protect your Personal Information from unauthorized use, access, or disclosure. We provide Personal Information to printers and mailing houses, professional organizations, and third party organizations who assist in verifying your credentials.

We also disclose your information to government authorities as required by laws that regulate immigration, tax, national security, and criminal activity.

Transfers to Third Countries

Data Retention

You can find more information about how long we retain personal data by consulting our Retention and Disposal Policy, available here: http://lcsgxgy.com/about/university-policies/_documents/approved-records-retention-policy_9-18.pdf. We may be required by law to retain your information for a longer period.

Your Rights

You have the right to the following information regarding UD’s processing of your Personal Information:

the purposes of the processing,
the categories of Personal Information concerned,
the recipients or categories of recipients to whom the Personal Information have been or will be disclosed,
where possible, the envisaged period for which the Personal Information will be stored, or, if not possible, the criteria used to determine that period.

This Privacy Statement is intended to provide this information. Any questions about these details may be directed to the DPO.

You also have the following additional rights with respect to your Personal Information:

The right to request access to the Personal Information that UD has about you, as well as the right to request rectification of any data that is inaccurate or incomplete.
The right to request a copy of your Personal Information in electronic format so that you can transmit the data to third parties, or to request that UD directly transfer your Personal Information to one or more third parties.
The right to object to the processing of your Personal Information for marketing and other purposes.
The right to erasure of your Personal Information when it is no longer needed for the purposes for which you provided it, as well as the right to restriction of processing of your Personal Information to certain limited purposes where erasure is not possible.
The right to lodge a complaint with the Italian data protection authority or the supervisory authority for the country where you live or work or where you believe that your rights have been violated:
- Garante per la protezione dei dati personali  
  Piazza di Monte Citorio, 121 00186 Roma  
  Tel. +39 06 69677 1
   Fax +39 06 69677 785  
  e-mail: garante@garanteprivacy.it
   Website: http://www.garanteprivacy.it/

A full list of supervisory authority contacts for E.U. countries is available here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

Data Privacy Notice for University of Dallas Vendors in the European Union

This Notice describes the practices of the University of Dallas (“UD”) with respect to the collection, use, storage, and disclosure (“processing”) of Personal Information covered by the European Union’s General Data Protection Regulation for purposes of evaluating prospective vendors and managing our vendor relationships. This Notice applies to UD, with headquarters at 1845 East Northgate Drive, Irving, Texas 75062, including our affiliated colleges, schools, and campuses (collectively “UD,” “us” or “our”) with respect to processing of personal information of vendors in the context of UD’s Rome Campus. All such vendors or prospective vendors (referred to below as “you” or “your”) should carefully read the provisions of this Privacy Notice.

The Information We Process About You

We process the information we collect from you directly, either during our communications with you about UD, as part of the vendor selection and contracting process, or as part of your response to our request for information about your goods or services.

Throughout our relationship with you, certain information may be required in order for us to fulfill the terms of our contract with you or take an action you request. Failure to provide required information may result in the termination of your relationship with UD or inability to take an action you request.

In addition, we collect the following kinds of information about you from third parties:

Your contact, demographic information, references, and other publicly available information, which we collect from third parties who provide us information about prospective vendors who may be interested in working with UD.
Any criminal convictions or offenses, Specially Designated National status, information about your credit, and other information about your previous employment and education, which we collect as part of a background check process (where permitted by applicable law) from government records, credit reporting companies, your previous employers, and other academic institutions.

Purposes and Legal Basis for Processing Your Data

We process your Personal Information to recruit prospective vendors, evaluate vendors interested in working with UD, communicate with you about UD and your contract status with us, and, if we decide to work with you, to manage the procurement process, onboard you as a new vendor, and manage your business dealings with UD. We also use data about you to make strategic decisions about UD programs, administer those programs, file required reports with applicable governmental authorities, and engage in financial planning. We also use your data for purposes required by law, including complying with application retention requirements, and for the enforcement of UD policies and applicable laws.

We combine the data that we collect in order to provide these functions.

We have the following legal basis for processing the information you provide us in your application or that we collect about you during the application process.

We have a legitimate interest in recruiting and retaining qualified vendors, complying with laws and regulations that govern our conduct in the countries where we operate, and administering UD and its programs in an efficient, ethical, and appropriate manner. We process all the information we collect from or about you to meet these purposes.
We may also be required to process your Personal Information to complete a contract that you have entered into with us, including to provide you with contracted-for payments, fulfill our contractual obligations to you, or to ensure your compliance with contractual obligations.
We may also be required to process your Personal Information to comply with applicable Italian laws, such as tax laws.

In the case of Sensitive Personal Information (which includes (i) information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; (ii) genetic and biometric data, and (iii) data concerning health, sex life, or sexual orientation), we process information either (i) because we have your consent to do so or (ii) because we are required to process the information to comply with applicable laws. When we process your Sensitive Personal Information on the basis of your consent, you may withdraw that consent at any time by contacting the DPO. If you withdraw your consent, we may still be required to process your Sensitive Personal Information to comply with applicable law, but we will explain to you at the time your consent is withdrawn what processing activities will continue for legal compliance purposes.

Recipients of Your Personal Information

Your Personal Information will be received and processed by UD employees and personnel, including third parties who provide services to UD in connection with the purposes of processing described above. We share your Personal Information with our service providers only when they have agreed to process your Personal Information only to provide services to us and have agreed to protect your Personal Information from unauthorized use, access, or disclosure. You may contact the DPO to learn more about the categories of service providers to whom your data is disclosed.

We also disclose your information to government authorities as required by laws the regulate immigration, tax, national security, and criminal activity.

Transfers to Third Countries

Data Retention

Your Rights

You have the right to the following information regarding UD’s processing of your Personal Information:

the purposes of the processing,
the categories of Personal Information concerned,
the recipients or categories of recipients to whom the Personal Information have been or will be disclosed,
where possible, the envisaged period for which the Personal Information will be stored, or, if not possible, the criteria used to determine that period.

This Privacy Statement is intended to provide this information. Any questions about these details may be directed to the DPO.

You also have the following additional rights with respect to your Personal Information:

The right to request access to the Personal Information that UD has about you, as well as the right to request rectification of any data that is inaccurate or incomplete.
The right to request a copy of your Personal Information in electronic format so that you can transmit the data to third parties, or to request that UD directly transfer your Personal Information to one or more third parties.
The right to object to the processing of your Personal Information for marketing and other purposes.
The right to erasure of your Personal Information when it is no longer needed for the purposes for which you provided it, as well as the right to restriction of processing of your Personal Information to certain limited purposes where erasure is not possible.
The right to lodge a complaint with the Italian supervisory authority or the supervisory authority for the country where you live or work or where you believe that your rights have been violated:
- Garante per la protezione dei dati personali  
  Piazza di Monte Citorio, 121 00186 Roma  
  Tel. +39 06 69677 1  
  Fax +39 06 69677 785  
  e-mail: garante@garanteprivacy.it  
  Website: http://www.garanteprivacy.it/

A full list of supervisory authority contacts for E.U. countries is available here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

Data Privacy Notice for Alumni and Other Friends of University of Dallas In the European Union

This Notice describes the practices of the University of Dallas (“UD”) with respect to the collection, use, storage, and disclosure (“processing”) of Personal Information covered by the European Union’s General Data Protection Regulation about alumni and other friends of UD. This Notice applies to UD, with headquarters at 1845 East Northgate Drive, Irving, Texas 75062, including our affiliated colleges, schools, and campuses (collectively “UD,” “us” or “our”). All alumni and other friends of UD in the E.U. (referred to below as “you” or “your”) should carefully read the provisions of this Privacy Notice.

The Information We Process About You

Alumni and other friends of UD are important sources of financial support for UD and its activities around the world. Friends of UD include former employees, faculty, family of students and faculty, other donors to UD and their families, potential donors and their families, and others who have expressed an interest in supporting UD or in participating or engaging in University-sponsored activities.

We process the information we collect from you directly, including during our communications with you; during your enrollment, employment, participation in student or alumni activities or programs, or other association with UD; when you attend one of our events, and when you request services from UD.

In some cases, we will require that certain information be provided in order for UD to provide you with a service or take an action that you request. We will indicate when such information is required and failure to provide required or mandatory information may result in our being unable to provide you with a service or take an action you request.

We use automated decision-making processes to process your data in certain contexts. For example, we may automatically evaluate your history of giving to UD and create a profile of your giving activities, which we will use to make decisions about how to contact you about supporting UD. You can find out more about the logic we use in our automated decision-making processes by contacting the DPO.

In addition, we collect the following kinds of information about you from third parties:

Information we collect from other UD personnel or students: We may collect information about you from other persons affiliated with UD. For example, we collect contact information for our students’ parents and family members from our students.
Information we receive about you from journals, research publications, professional organizations, or other platforms through which you publish or present academic content.
Information from publically available sources, like your public social media profiles (e.g., LinkedIn), and public directories that include your professional and contact information.
Demographic Information: We may share information we have about you with third-party service providers who use other information they have about you to provide us with demographic information.
Information about your prior or concurrent educational history, which we collect from other educational institutions (or retrieve from our own records).

Purposes and Legal Basis for Processing Your Data

We process your Personal Information to operate UD and its programs, to provide you with alumni support and related services (like job placement, email, reunion planning, and transcripts), and to contact you to offer you services and request financial support for the University. We also use this data to:

file required reports with applicable governmental authorities,
administer our programs and provide appropriately tailored services,
monitor trends within our fundraising activities,
verify your identity,
ensure that the university is prepared for emergencies,
enforce UD policies and applicable laws,
manage university billing, collecting, refunding and cashiering functions,
facilitate internal research,
coordinate events such as conferences and professional development, and
facilitate alumni directories and other promotional activities.

We combine the data that we collect in order to provide these functions.

We have the following legal basis for processing the information you provide us or that we collect about you:

We have a legitimate interest in supporting our alumni and other friends of UD, complying with laws and regulations that govern our conduct in the countries where we operate, raising funds to support UD’s mission and programs, and administering UD and its programs in an efficient, ethical, and appropriate manner. We process all the information we collect from or about you to meet these purposes.
We may also be required to process your Personal Information to complete a contract that you have entered into with us, including to receive a service or collect pledged funds.
We may also be required to process your Personal Information to comply with laws applicable in the European Union or its member states, such as tax laws.

In the case of Sensitive Personal Information (which includes (i) information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; (ii) genetic and biometric data, and (iii) data concerning health, sex life, or sexual orientation), we process information either (i) because we have your consent to do so or (ii) because we are required to process the information to comply with applicable laws. When we process your Sensitive Personal Information on the basis of your consent, you may withdraw that consent at any time by contacting the DPO. If you withdraw your consent, we may still be required to process your Sensitive Personal Information to comply with applicable law, but we will explain to you at the time your consent is withdrawn what processing activities will continue for legal compliance purposes.

Recipients of Your Personal Information

Your Personal Information will be received and processed by UD employees and personnel (including our volunteers), including third parties who provide services to UD in connection with the purposes of processing described above. For example, we may disclose your information to service providers who provide campus security, support our information technology systems, or coordinate and provide alumni or public events and services. We share your Personal Information with our service providers only when they have agreed to process your Personal Information only to provide services to us and have agreed to protect your Personal Information from unauthorized use, access, or disclosure.

We also disclose your information to government authorities as required by laws that regulate immigration, tax, national security, and criminal activity.

Transfers to Third Countries

Data Retention

Your Rights

You have the right to the following information regarding UD’s processing of your Personal Information:

the purposes of the processing,
the categories of Personal Information concerned,
the recipients or categories of recipients to whom the Personal Information have been or will be disclosed,
where possible, the envisaged period for which the Personal Information will be stored, or, if not possible, the criteria used to determine that period.

This Privacy Statement is intended to provide this information. Any questions about these details may be directed to the DPO.

You also have the following additional rights with respect to your Personal Information:

The right to request access to the Personal Information that UD has about you, as well as the right to request rectification of any data that is inaccurate or incomplete.
The right to request a copy of your Personal Information in electronic format so that you can transmit the data to third parties, or to request that UD directly transfer your Personal Information to one or more third parties.
The right to object to the processing of your Personal Information for marketing and other purposes.
The right to erasure of your Personal Information when it is no longer needed for the purposes for which you provided it, as well as the right to restriction of processing of your Personal Information to certain limited purposes where erasure is not possible.
The right to lodge a complaint with the Italian supervisory authority or the supervisory authority in the country where you live or work or where you believe that your rights have been violated:
- Garante per la protezione dei dati personali
   Piazza di Monte Citorio, 121 00186 Roma  
  Tel. +39 06 69677 1  
  Fax +39 06 69677 785  
  e-mail: garante@garanteprivacy.it  
  Website: http://www.garanteprivacy.it/

A full list of supervisory authority contacts for E.U. countries is available here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

Data Privacy Notice for Visitors to University of Dallas in the European Union

This Notice describes the practices of University of Dallas (“UD”) with respect to the collection, use, storage, and disclosure (“processing”) of Personal Information covered by the European Union’s General Data Protection Regulation about visitors to UD’s Rome Campus. This Notice applies to UD, with headquarters at 1845 East Northgate Drive, Irving, Texas 75062, as well as to its affiliated colleges, schools, and campuses (collectively “UD,” “us” or “our”). All visitors to UD’s Rome Campus (referred to below as “you” or “your”) should carefully read the provisions of this Privacy Notice.

This general notice may be supplemented by additional notices at the point of any data collection. This notice is intended for casual visitors who have no formal relationship with UD. If the nature of your relationship with UD changes, a different data privacy notice may apply and will be provided to you. If you have specific questions about any of the data processing activities described in this or any other notice, please contact the DPO.

The Information We Process About You

We process the information we collect from you directly, including during our communications with you, to confirm your identity when you access a UD service or facility, when you RSVP for or attend one of our events, and when you request services from UD.

UD maintains video surveillance systems for the security of our premises. UD or our contracted service operator may process images and video of you in connection with the operation of these systems.

In some cases, we will require that certain information be provided in order for UD to provide you with a requested service or take an action you request. We will indicate when such information is required and failure to provide required or mandatory information may result in our being unable to provide you with a service or take an action you request.

We use automated decision-making processes to process your data in certain contexts. For example, we may automatically check your name against a list of those not permitted entrance to UD facilities.

In addition, we collect the following kinds of information about you from third parties:

Information from UD personnel or students: We may receive information about you from UD personnel or students, including your name, contact information, relationship to UD personnel or students, and the reason for your visit.
Information we receive about you from journals, research publications, professional organizations, or other platforms through which you publish or present academic content.
Information from publically available sources, like your public social media profiles (e.g., LinkedIn), and public directories that include your professional and contact information.
Information from UD affiliates or partners for the purpose of providing you access to a UD program or service.

Purposes and Legal Basis for Processing Your Data

We process your Personal Information to operate UD and its programs, to provide you with access to our facilities, to provide you with the services you request, and to manage our events.

We combine the data that we collect in order to provide these functions.

We have the following legal basis for processing the information you provide us or that we collect about you.

We have a legitimate interest in ensuring the safety of UD students, faculty, and personnel, complying with laws and regulations that govern our conduct in the countries where we operate, and administering UD and its programs in an efficient, ethical, and appropriate manner. We process all the information we collect from or about you to meet these purposes.
We may also be required to process your Personal Information to complete a contract that you have entered into with us, including a contract to make use of an UD facility for an event or to receive a service from UD.
We may also be required to process your Personal Information to comply with laws applicable in the European Union or its member states, such as immigration laws.

In the case of Sensitive Personal Information (which includes (i) information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; (ii) genetic and biometric data, and (iii) data concerning health, sex life, or sexual orientation), we process information either (i) because we have your consent to do so or (ii) because we are required to process the information to comply with applicable laws. When we process your Sensitive Personal Information on the basis of your consent, you may withdraw that consent at any time by contacting the DPO. If you withdraw your consent, we may still be required to process your Sensitive Personal Information to comply with applicable law, but we will explain to you at the time your consent is withdrawn what processing activities will continue for legal compliance purposes.

Recipients of Your Personal Information

Your Personal Information will be received and processed by UD employees and personnel, including third parties who provide services to UD in connection with the purposes of processing described above. For example, we may disclose your information to service providers who provide campus security, support our information technology systems, or coordinate and provide public events and services. We share your Personal Information with our service providers only when they have agreed to process your Personal Information only to provide services to us and have agreed to protect your Personal Information from unauthorized use, access, or disclosure.

We also disclose your information to government authorities as required by laws that regulate immigration, tax, national security, and criminal activity.

Transfers to Third Countries

Data Retention

Your Rights

You have the right to the following information regarding UD’s processing of your Personal Information:

the purposes of the processing,
the categories of Personal Information concerned,
the recipients or categories of recipients to whom the Personal Information have been or will be disclosed,
where possible, the envisaged period for which the Personal Information will be stored, or, if not possible, the criteria used to determine that period.
This Privacy Statement is intended to provide this information. Any questions about these details may be directed to the DPO.

You also have the following additional rights with respect to your Personal Information:

The right to request access to the Personal Information that UD has about you, as well as the right to request rectification of any data that is inaccurate or incomplete.
The right to request a copy of your Personal Information in electronic format so that you can transmit the data to third parties, or to request that UD directly transfer your Personal Information to one or more third parties.
The right to object to the processing of your Personal Information for marketing and other purposes.
The right to erasure of your Personal Information when it is no longer needed for the purposes for which you provided it, as well as the right to restriction of processing of your Personal Information to certain limited purposes where erasure is not possible.
The right to lodge a complaint with the Italian data protection authority:
- Garante per la protezione dei dati personali  
  Piazza di Monte Citorio, 121 00186 Roma  
  Tel. +39 06 69677 1  
  Fax +39 06 69677 785
   e-mail: garante@garanteprivacy.it  
  Website: http://www.garanteprivacy.it/

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