For US residents not subject to GDPR, view our Privacy Notice.
This Privacy Notice describes how Emerson College of 120 Boylston Street, Boston, Massachusetts, USA 02116 (“we”, “us,” “Emerson”) collects and processes personal information about you in connection with Emerson’s fundraising efforts, alumni relations, and donor outreach (collectively “Institutional Advancement”); how we use, store, transfer and protect this personal information; and your rights in relation to this personal information.
This Privacy Notice applies to all personal information we collect or process about you in the context of Institutional Advancement. This Notice will inform you of:
- Personal information we collect and use;
- How we use your personal information and the basis on which we use it;
- Who has access to your personal information;
- How your personal information is protected and stored;
- International transfer of your data;
- How to exercise your rights;
- How to contact us; and
- Changes to the Privacy Notice
1. Personal information we collect and use
In connection with our Institutional Advancement efforts, Emerson collects and uses certain personal information about you. Personal information is information about you through which you can be identified (including where you can be identified by combining the information with other information).
Note that we may be required by law to collect certain personal information about you, or as a consequence of our contractual relationship with you. Failure to provide this personal information may prevent or delay the fulfilment of these obligations. We will inform you at the time your personal information is collected whether certain data is compulsory and the consequences of the failure to provide such personal information.
1.1 Personal information we collect directly from you
We collect some personal information directly from you. Personal information that is collected directly from you may include the following:
- Biographical information, such as your name, age, gender, date of birth, national origin, and current nationality;
- Contact information, such as your phone number, email address, and mailing address;
- Family information, such as marital status, name of spouse, names of parents, and associated contact information;
- Employment and education information, such as your occupation, job title, name of employer, work history, and level of education;
- Information about your interests and preferences;
- Financial information, such as your checking account or payment card information used for donations to Emerson; and
- Your communications with us, such as emails or inquiry forms you submit.
1.2 Personal information generated by us
In addition, the following categories of personal information about you may be generated by Emerson in the course of its relationship with you:
- Information about your involvement with Emerson College and other interests, such as your attendance at events, philanthropic interests, and volunteer efforts;
- Alumni records and academic information, if applicable, such as information about your major, transcript, degree, and date of graduation;
- Financial information, such as your history of donations; and
- Employment details, if you are or were employed by Emerson College.
1.3 Personal information we obtain from other sources
Emerson may also obtain personal information about you from third parties (e.g., companies that conduct wealth screening or other people that might know you and your philanthropic interests) or publicly available sources or databases (e.g., social media sites and online real estate portals). These types of personal information include:
- Financial information, such as wealth information and information about the value of your home; and
- Information about your philanthropic interests and preferences.
1.4 Sensitive information we collect and use
Some of the categories of personal information that we collect are considered special categories of personal data under European Union law, and these types of information are considered particularly sensitive. Specifically, we may process the following types of sensitive information:
- Information about your racial or ethnic origin;
- Information about your religious or philosophical beliefs;
- Information about your sexual orientation; and
- Health and medical information, such as information about disabilities and related accommodations and food allergies or other dietary restrictions, for purposes of event participation.
2. How we use your personal information and the basis on which we use it
Emerson uses your personal information in connection with our Institutional Advancement efforts, to:
- send you informational publications, such as Expression Magazine and newsletters from departments and clubs of interest to you. This processing is necessary to serve our legitimate interests in providing you information you request. Where required by law, we will obtain your consent before sending you electronic marketing communications;
- send you information about fundraising campaigns, events, and volunteer opportunities that may be of interest to you. We rely on your express consent for this processing, and where required by law, we will obtain your consent to receive electronic marketing communications before sending such communications;
- conduct surveys so that we can learn more about our alumni and other supporters. This processing is necessary to serve our legitimate interests in fundraising, alumni relations, and donor outreach;
- conduct wealth analysis and research to understand your philanthropic interests and your ability to give, in order to tailor our fundraising efforts. This processing is necessary to serve our legitimate interests in fundraising and donor outreach;
- carry out our contractual obligations to you and exercise our rights in this respect, where applicable (e.g. processing payment card information or issuing tax receipts for payments). Our basis for doing so is the performance of the agreement we have with you;
- provide any services or information you request from us, including networking opportunities and ongoing career services. This processing is necessary to serve our legitimate interest in fundraising, alumni relations, and donor outreach;
- keep our records accurate and up-to-date. This processing is necessary to comply with our legal obligations (such as obligations to document charitable giving for tax purposes) and to serve our legitimate interest in maintaining accurate records;
- research and statistical purposes. This processing is necessary to serve our legitimate interests in understanding alumni and donor interests and improving our fundraising and outreach efforts effectiveness;
- comply with legal obligations to which we are subject, including to respond to subpoenas, court orders, or other legal process; to cooperate with regulators and law enforcement as required by law; and to defend our rights or the rights of any third party in legal proceedings. This processing is necessary to comply with our legal obligations and to serve our legitimate interests in complying with the laws of all jurisdictions to which we are subject;
- publicly acknowledge gifts. We rely on your express consent for this processing;
- prevent or investigate fraud or other unlawful activity, and to protect the security of Emerson College’s property, website, and other systems. This processing is necessary to serve our legitimate interests in preventing unlawful activity and protecting Emerson’s property and interests;
- meet the obligations of private organizations with oversight over Emerson College, such as accreditation organizations. This processing is necessary to serve our legitimate interests in maintaining accreditation; and
- manage events and reunions. This processing is necessary to serve our legitimate interest in alumni relations.
2.2 How we use sensitive information
- Information revealing an individual’s racial or ethnic origin, religious or philosophical beliefs, or sexual orientation. To the extent we process these types of sensitive information, such information is voluntarily disclosed for purposes of identifying affinity opportunities. We rely on express consent for such processing.
- Health and medical information. We process health and medical information to comply with obligations under social protection laws (e.g., to provide disability accommodations) or, where not required by law, in reliance on your express consent (e.g., to accommodate the dietary or other needs of our alumni and other supporters).
3. Who has access to your data
We may share your personal information with the following parties:
- Service providers. We may share your personal information with service providers and business partners who perform services for us. For example, we may engage service providers to process recurring gifts payments, send newsletters, maintain our systems of records, or partner with us for fundraising or other initiatives.
- Other Emerson College departments, alumni associations, clubs, and interest groups.
- Other Emerson alumni. We may share your personal information with other Emerson alumni, subject to your express consent.
- Law enforcement agencies, government bodies or other third parties. We may share your personal information with these parties where we believe this is necessary to comply with legal or regulatory obligations, or otherwise to protect our rights or the rights of any third party.
- Private organizations with oversight over Emerson College. We may share your personal information to the extent necessary to meet the obligations of private organizations with oversight over Emerson College, such as accreditation organizations.
Because we operate internationally, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide services). Please see the section on “International transfer of your data” below for more information.
4. How your personal information is protected and stored
We implement technical and organizational measures to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the ongoing integrity and confidentiality of personal information.
We will retain your personal information in accordance with our data retention policy, which sets out data retention periods required or permitted by applicable law.
5. International transfer of your data
Your personal information may be transferred to, stored, and processed in a country (such as the United States) that is not regarded as ensuring an adequate level of protection for personal information under the laws of your home country.
We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your personal information is adequately protected. For more information on the appropriate safeguards in place, please contact us alumni [at] emerson.edu (subject: Questions%20regarding%20GDPR%20Privacy%20Notice) or 617-824-8542.
6. How to exercise your rights
Where applicable under local law, you may have the following rights with respect to your personal information:
- To withdraw consent at any time, if we are processing your personal information on the basis of consent
- To access the information that Emerson College has about you
- To request that Emerson College rectify or erase your information
- To request that Emerson College restrict the way it uses your information
- To object to the way Emerson College uses your information, if we are processing your personal information on the basis of our legitimate interests
- To ask Emerson College to transfer your information to someone else
- To lodge a complaint with the appropriate data protection authority
If you wish to exercise these rights, or to notify us of a change in your details, or if you have any questions on the content of this Notice, please contact alumni [at] emerson.edu (subject: Questions%20regarding%20GDPR%20Privacy%20Notice) or 617-824-8542.
7. How to contact us
If you have questions or concerns regarding the way in which your personal information has been used, please contact alumni [at] emerson.edu (subject: Questions%20regarding%20GDPR%20Privacy%20Notice) or 617-824-8542.
Our representative in the European Union is Emerson College European Center – Kasteel Well, of Kasteellaan 20, 5855 AE Well, The Netherlands.
We are committed to working with you to obtain a fair resolution of any complaint or concern about your privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to make a complaint to the appropriate data protection authority.
8. Changes to the Privacy Notice
You may request a copy of this Privacy Notice from us using the contact details set out above. We may modify or update this Privacy Notice from time to time.
If we change this Privacy Notice, we will notify you of the changes. Where changes to this policy will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (for example, to object to the processing).
February 21, 2019