Privacy Policy

Effective Date: July 2020

Introduction

You have arrived at a site that is owned and operated by Global University Systems on behalf of St. Matthew’s University(collectively, “ St. Matthew’s University” or “ we,” “ our ” or “ us”). This “ Privacy Policy” governs your use of www.stmatthews.edu (including, without limitation, both mobile and online versions of our site), and also applies to your use of interactive features, widgets, applications, content or downloads that we make available through the site and that post this Privacy Policy (collectively referred to herein as the “ Site”), regardless of how you access or use them, whether via personal computers, mobile devices or otherwise but does not apply to data we receive from third parties unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy Policy.

St. Matthew’s University is part of The Global University Systems B.V. group of companies which is made up of different legal entities, details of which can be found at: www.globaluniversitysystems.com.

Full name of data controller legal entity:  St. Matthew’s University School of Medicine

Email address: privacy@stmatthews.edu

Postal address: West Bay Rd, Seven Mile Beach, Grand Cayman, Cayman Islands

Telephone number: 345-945-3199

You have the right to make a complaint at any time to the Ombudsman, Cayman Islands the supervisory authority for data protection issues in the Cayman Islands (https://ombudsman.ky/about)

We would always prefer that you come to us to help address any concerns of a privacy nature before you go to the supervisory authority, so please contact us in the first instance.

Our statements under this Privacy Policy only cover information collected at the Site directly by us, and not by third parties that may interact with our Site. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Site (unless otherwise stated below) and does not govern the data practices of third parties that may interact with our Site.

To the extent we provide you notice on our Site of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.

This privacy notice supplements the other notices and does not replace them.

In addition, please review the Site’s Terms of Service, which governs your use of the Site. By using our Site, you consent to our Privacy Policy and Terms of Use and our collection, use and sharing of your information and data, and other activities, as described below.

Table of Contents

It is important that you read and understand the entire Privacy Policy before using the Site. To ease review, each section below contains a brief introductory summary and a link to the full explanation. Click on the headings and the “More” buttons to be taken to the full explanation. Any capitalized terms that appear in but are not otherwise defined in the introduction have the meanings given to them elsewhere in the Privacy Policy.

1. What Information Does the Site Collect?
   • We collect and receive certain information about you as you interact with our Site, explained further in this section.
   • Information You Provide to Us
     • We may collect certain Personal Information and Demographic Information that you provide to us when you interact with the Site. For example, we may collect this information through various forms and in various places on the Site, including when you submit your application to attend St. Matthew’s University, when you sign up to receive more information about St. Matthew’s University, or when you otherwise interact with the Site. More
   • Information Collected and Stored As You Access and Use the Site
     • Certain information may be collected from you automatically when you access and use the Site. For example, we and third parties may use Tracking Technologies to collect Usage Information based on your Device Identifier for a variety of purposes, including tracking, targeting, and advertising, which may include activities across time and third party locations. We do not look for or respond to do not track signals, but you may have certain other options regarding tracking and/or targeting. More
   • Information Third Parties Provide About You
     • We may obtain information about you from third parties. More
   • Interactions with Third-Party Services
     • If you interact with third-party services, those services may send us information about you and you or we may send them information about you. More
2. How Do We Use the Information Collected?
   • Use of Information By Us
     • We use your Personal Information, Demographic Information and Usage Information for a variety of purposes detailed in this section. More
   • Use of Information For Recruitment Purposes
     • If you apply for a job with us, we use the application information for considering you for a position. More
   • Interest-Based Advertising and Location-Based Services.
     • We may use your Personal Information, Demographic Information and Usage Information to target and understand advertisements as detailed in this section. More
   • Contact Us
     • If you contact us, we will not use your information for marketing purposes unless you opt-in. More
3. How and When Do We Share Information With Third Parties?
   • We may provide your information to third parties under various circumstances detailed in this section.These may include:
   • When You Request Information From or Provide Information to Third Parties
     • If you request information from third parties, request that we send information to third parties or interact with third-party services, content, ads or tools (including Facebook and other third party share functionality), we may share your information with such parties and/or they may collect your information directly. This may also include ordering or purchasing products from third parties through us where we indicate that the third party rather than St. Matthew’s University is the seller. More
   • Third Parties Providing Services on Our Behalf
     • Our vendors may collect your information on our behalf or we may share it with them so that they may provide services to us and you. Some may offer you choices regarding the collection and use of your information. More
   • To Protect the Rights of St. Matthew’s University and Others
     • There are a variety of administrative and legal reasons for which we may share some or all of your information. More
   • Affiliates and Business Transfer
     • We may share your information with our affiliates or in the event of a sale, merger or similar transaction. More
   • EEOC/Affirmative Action Reporting
     • Certain employment application, self-identifying information (e.g., race and gender) may be shared with the government and other third parties. More
   • Your California Privacy Rights
     • California Civil Code Section 1798 allows California residents to ask companies with whom they have an established business relationship to provide certain information about the companies’ sharing of personal information with third parties for direct marketing purposes. More
   • Your Connecticut Privacy Rights
     • We make good faith efforts to protect the security of Social Security numbers. More
   • Your European Privacy Rights
     • Certain European residents have certain data protection rights. More
4. What About Information I Disclose Publicly or to Others?
   • User-Generated Content and Public Information
     • Posting content in public areas makes it available to others. We may share and use your public information for any reason not otherwise prohibited by this Privacy Policy. More
   • Name and Likeness
     • You grant us the right to use your name and likeness in connection with your posting and activities. More
5. Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Site?
   • We may allow you to access third-party content on the Site, or to link to third-party applications and locations from the Site, but we are not responsible for your interaction with third-party content, apps, and locations. More
6. What About Ads?
   • We and third parties may send you targeted ads based on your location, information and/or behavior. This is in our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy). Some third parties allow you to exercise choices in relation to remarketing. More
7. How Do I Change My Information and Communications Preferences?
   • You may change certain account information and communications preferences as more fully detailed in this section. More
8. What About International Data Transfers?
   • We share your personal data within the GUS Group (https://www.globaluniversitysystems.com/our-institutions ) of which St. Matthew’s is a part of. This will involve international data transfers. More
9. What Should Parents Know About Children?
   • We do not intend to collect Personal Information from children. If you think we have, let us know. More
10. What About Security?
    • No data security is absolute, but we endeavor to take reasonable steps to secure data appropriately. More
11. What About Changes to the Privacy Policy?
    • We may change this Privacy Policy upon posting of a revised Privacy Policy. However, we will continue to treat your Personal Information under the terms of the privacy policy in effect when it was collected unless you otherwise consent. More
12. Student Educational Records
    • To learn more about our FERPA policy, click here.

The Full Detailed Privacy Policy

1. What Information Does the Site Collect?

(a) Information You Provide to Us

Personal data, or personal information, means any information about an individual from which that person can be identified. Anonymous data is therefore not treated as personal data. We have grouped together different kinds of personal data which we may collect, use, store and transfer as follows:

• Academic Data includes eligibility data including education and academic history, training records, qualifications, personal statements, CVs, personal achievements and references.
• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, , Unique Learner Number, nationality, residency status, disability declaration, criminal conviction declaration, third party student reference number where that third party shares your data with us, photographic images.
• Contact Data includes billing address, term-time and permanent residential address, country of residence, email address and telephone numbers
• Emergency Contact Data about next of kin names and contact details for use when there is an emergency that has involved you.
• Employment Data (if you are sponsored by your employer) includes employer details, start date, end dates, your job title, contact details at work (email address, telephone number and postal address).
• Financial Data includes student loan information, bank account and payment card details.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
• Profile Data includes any of your usernames and passwords, enquiries made by you, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Student Data includes your term time and home address, ID photo, subject of interest, chosen program your progress data and your results (coursework and exam, including mocks), other results from before final study years, exam scripts and transcripts, your attendance, lecturers’ and tutors’ feedback on you or your staff (if you are a corporate) (student references), communications with St. Matthew’s the extent of your use of any learning facilities / services by St. Matthew’s information relating to your use of the St. Matthew’s library resources (including materials checked out and overdue items), data about your membership of student groups, associations and any event attendances), information regarding mentor and mentee data, and your membership of any relevant alumni network, data around your taking part in events hosted by us or advertised by us, learner analytics and profiling data, any disciplinary data, student, course, or tutor- related complaints data and any claims involving you of any nature whatsoever, extenuating circumstances, appeals, additional information as required by professional/accreditation/awarding body
• Monitoring and Reporting Requirements Data includes destination of leavers of HE data and Student Data reported to third parties for regulatory purposes
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes your IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Usage Data includes URL data, web analytics data in relation to how you arrived at our sites, from where, what search items you looked for, which pages you visited on our sites, the duration of your visits and such other information about how you use our websites and the information provided on them, and how you use our products and services so as to assist us to improve our website offering to you.
• Visa Data for international students, including passport and previous visas data, bank statements or other financial information for satisfying ourselves that visa requirements are met.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Special Category Data

When you make an application on our website for a course or program we will ask whether you have any disabilities. You are not obliged to inform us but any information you do provide will assist us to assess how we will meet our statutory obligation in relation to your disability.

Criminal Offence Data

For the purposes of compliance with our Safeguarding Policy, we may ask for Background checks or seek criminal records information.  This type of data is regulated under The Cayman Islands Data Protection Law (“DPL”) and we ensure that we limit the use of any such data both in time and in scope and that we meet appropriate lawful grounds for processing such data.

For further information please contact us at privacy@stmatthews.edu

(b) Information Collected and Stored As You Access and Use the Site

In addition to any Personal Information or other information that you choose to submit to us via our Site, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Site (“ Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “ Device”) whenever you visit or interact with our Site. To the extent we associate Usage Information with your Personal Information we collect directly from you on the Site, we will treat it as Personal Information.

This Usage Information may include:

• your IP address, UDID or other unique identifier (“ Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Site, and our computers identify your Device by its Device Identifier;
• your Device functionality (including browser, operating system, hardware, mobile network information);
• the URL that referred you to our Site;
• the areas within our Site that you visit and your activities there, including remembering you and your preferences;
• your Device location;
• your Device characteristics; and
• certain other Device data, including the time of day, among other information.

We may use various methods and technologies to store or collect Usage Information if you have opted-in to tracking/advertising cookies (“ Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):

Cookies. A cookie is a data file placed on a Device when it is used to visit the Site. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage. Unlike Flash cookies, HTML5 cookies do not require a plug-in. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies. For information on disabling Flash cookies, go to Adobe’s web site www.adobe.com. Please be aware that if you disable or remove cookies, Flash cookies, or HTML5 cookies on your Device, some parts of our Site may not function properly, and that when you revisit our Site your ability to limit cookies is subject to your browser settings and limitations.

Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our Site’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Site, to monitor how users navigate the Site, to count how many emails that were sent were actually opened or to count how many particular articles or links were actually viewed.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.

Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.

ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.

Tracking Technologies Usage. We may use Tracking Technologies for a variety of purposes, including:

Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Site, including cookies required to prevent fraudulent activity, improve security or allow you to make use of shopping‑cart functionality.

Performance‑Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site.

Functionality‑Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Site, including identifying you when you sign‑in to our Site or keeping track of our specified preferences, including in terms of the presentation of content on our Site.

Targeting‑Related. We may use Tracking Technologies to deliver content, including ads, relevant to your interests on our Site and third‑party sites based on how you interact with our advertisements or content. This includes using Tracking Technologies to understand the usefulness to you of the advertisements and content that have been delivered to you. Further information on this, and your opt-out choices, is found in Section 6 below.

(d) Interactions with Third-Party Services

The Site may include functionality that allows certain kinds of interactions between the Site and a third-party web site or application. For example, we may provide third-party sites’ interfaces or links on the Site to facilitate sending a communication from the Site and we may use third parties to facilitate emails, tweets or Facebook postings. These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy. St. Matthew’s University may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party tools on our Site.

(e) Information You Provide About a Third Party

You may send someone else a communication from the Site, such as sending an invitation to a friend. If so, the information you provide (names, email addresses, etc.) is used to facilitate the communication and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality on our Site, your contact information, name or user name and message may be included in the communication sent to your addressee(s). Some of these tools may be third-party tools subject to third-party privacy policies.

2. How Do We Use the Information Collected?

(a) Use of Information by Us.

We may use your Personal Information, Demographic Information or Usage Information that is subject to this Privacy Policy:

Purpose	Type of Data	Lawful Basis
To provide you with information or services	Contact data	Performance of a contract with you (in our anticipation of entering into such contract with you)
To process transactions that you have requested or agreed to receive	requested or agreed to receive Identity Data; Contact Data; Financial Data; Transaction Data	(a) Performance of a contract with you; (b) Necessary for our legitimate interests (to recover debts due to us)
To provide you with marketing materials or services on behalf of us or third parties	Contact Data	Consent
Cookie based remarketing services intended to deliver targeted marketing to you based on your internet searches	Contact Data	Legitimate interest
To determine your admissibility and to register you for your selected educational program	Identity Data; Contact Data; Financial Data; Academic data; Student data	Performance of a contract with you
If you are a student at St. Matthew’s, to allow you to gain access to course materials and other related content and services we make available to our students	Identity Data; Contact Data	Necessary for the student’s legitimate interests (to receive the benefit of the material or service)
To analyze academic and learning outcomes and preferences	Identity Data;  Student data	Necessary for our legitimate interests (to keep our records updated and to study how students use our products/services)
To provide you with information concerning arrangements and other options for the repayment of funds loaned to you for your education	Identity Data; Contact Data; Financial Data; Transaction Data	(a) Performance of a contract with you; (b) Necessary for the student’s legitimate interests (to receive the benefit of the information, payment or service)
To enable you to participate in a variety of the Site’s features such as to allow you to participate in a webinar about the university	Identity Data; Contact Data	Necessary for the student’s legitimate interests (to receive the benefit of the material or service)
To process your application and/or registration submitted through the Site, including verifying your information is active and valid	Identity Data; Contact Data; Academic data	Performance of a contract with you
To improve the Site or our services, to customize your experience on the Site, or to serve you specific content that is relevant to you	Identity Data; Contact Data; Technical Data; Profile Data; Usage Data; Profile Data	Legitimate interests (to define customer types for our products /services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To contact you with regard to your use of the Site and, in our discretion, changes to the Site and/or Site’s policies	Contact Data	Necessary to comply with a legal obligation
For internal business purposes	Identity Data; Contact Data; Technical Data; Profile Data; Usage Data; Profile Data	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

3. How and When Do We Share Information with Third Parties?

Internal Third Parties

Other companies in the GUS Group acting as joint controllers or processors and who are based throughout the world and provide shared services such as IT, legal services, system administration services and leadership reporting.

External Third Parties

We may share non-Personal Information, such as aggregated user statistics, with third parties. We may share your Device Identifiers with third parties along with data related to you and your activities. We do not share your Personal Information that we have collected directly from you on our Site with third parties for those third parties’ direct marketing purposes unless you have consented at the time you provide your Personal Information. If we de-identify data about you, it is not treated as Personal Information by us, and we may share it with others freely. In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy. St. Matthew’s University may disclose your information as follows:

(a) When You Request Information From or Provide Information to Third Parties. You may be presented with an option on our Site to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools apps or ads on our Site or link to them from our Site. This may include using third-party tools such as Facebook, Twitter, Pinterest or other third-party posting or content sharing tools and by so interacting you consent to such third party practices. It may also include ordering or purchasing products from third parties through us where we indicate that the third party rather than us is the seller. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.

(b) Third Parties Providing Services on Our Behalf . We may use third-party vendors to perform certain services on behalf of us or the Site, such as hosting the Site, designing and/or operating the Site’s features, tracking the Site’s activities and analytics, and enabling us to send you special offers or perform other administrative services. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you. We are not responsible for those third party technologies or activities arising out of them. However, some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available at the end of this Privacy Policy. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.

(c) To Protect the Rights of St. Matthew’s University and Others . To the fullest extent permitted by applicable law, we may also disclose your information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of St. Matthew’s or third parties (including through the enforcement of this Policy, our Terms of Service, and other applicable agreements and policies); or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders). To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all without notice to you.

(d) Affiliates and Business Transfer . We may share your information, including your Device Identifiers and Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates (“Affiliates”). We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Site or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.

(e) EEOC / Affirmative Action Reporting . In conjunction with U.S. laws and regulations enforced by the Equal Employment Opportunity Commission (“ EEOC”), the Office of Federal Contract Compliance Programs (“OFCCP”) and similar state and local regulatory agencies, we may ask you to provide us with self-identifying information (such as veteran status, gender and ethnicity). Providing such self-identifying information is voluntary, but if you do provide us with such information, we may submit that information, to the EEOC, the OFCCP and similar state and local regulatory agencies or otherwise use or disclose it for business-related purposes, including, without limitation, responding to information requests, fulfilling regulatory reporting requirements and defending against employment related complaints.

(f) Your California Privacy Rights .Under California law, California residents who have an established business relationship with St. Matthew’s or one of its Affiliates may choose to opt out of St. Matthew’s disclosure of personal information about them to third parties for direct marketing purposes. Unless noted at the time of collection, our policy is not to disclose personal information collected online to a third party for direct marketing purposes without your approval. If you choose to opt-out at any time after granting approval, write to St. Matthew’s University at 11486 Corporate Blvd, Suite 120 Orlando, FL 32817, United States; by email: privacy@stmatthews.edu.

(g) Your Connecticut Privacy Rights . Connecticut law requires any person or entity that collects Social Security numbers from Connecticut residents in the course of business to create a privacy protection policy and to publish or display it publicly. It is our policy to protect the confidentiality of Social Security numbers in our possession from misuse and improper disclosure by maintaining and enforcing policies and physical and electronic safeguards against misuse and improper disclosure. Unlawful disclosure of Social Security numbers is prohibited, and access to them is limited to personnel who need access to such information in order to perform their job functions.

(h) Your United Kingdom/European Privacy Rights.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are explained below:

• Request access to your personal data.
  • You have the right to access your personal data (known as an “access request”). This enables you to receive a copy of the personal data we hold about you and check that we are lawfully processing it.
  • To make a request: If you wish to make a request for access to your information, please contact us at St. Matthew’s University, 11486 Corporate Blvd, Suite 120 Orlando, FL 32817, United States or by email at privacy@stmatthews.edu.
  • What we may need from you: We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response to provide you with your information promptly

• Request correction of your personal data
  • This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data
  • This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data
  • You may raise an objection to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing your personal data
  • You may request to restrict our processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data
  • You may exercise your right to transfer your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Right to withdraw consent
  • This applies only where we rely on your consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
  • In certain circumstances, you can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also contact us at privacy@stmatthews.edu. if you wish to exercise your rights.
  • You have the right to make a complaint at any time to the Information Commissioner’s Office ICO, the supervisory authority for data protection issues in the UK. More information here:  https://ico.org.uk/
  • We would always prefer that you come to us to help address any concerns of a privacy nature before you go to the supervisory authority, so please contact us in the first instance.

4. What About Information I Disclose Publicly or to Others?

(a) User-Generated Content and Public Information. The Site may permit you to submit ideas, photographs, user profiles, writings, music, video, audio recordings, computer graphics, pictures, data, questions, comments, suggestions or other content, including Personal Information (collectively, “User Content”), such as on blogs and message boards. We or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to you. Others may have access to this User Content and may have the ability to share it with third parties. Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content. Please note that St. Matthew’s does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on the Site or what others do with information you share with them on the Site. We are not responsible for the accuracy, use or misuse of any User Content that you disclose or receive from third parties through the Site.

(b) Name and Likeness. We may also publish your name, voice, likeness and other Personal Information that is part of your User Content, and we may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities. For full terms and conditions regarding User Content you submit to the Site, please review our Terms of Service.

5. Do Third-Party Content, Links to Third-Party Sites, and/or Third-Party Apps Appear on the Site?

The Site may contain content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Site are served to you. In addition, when you are on the Site you may be directed to other sites that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their sites and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. For example, if you “click” on a link, the “click” may take you off the Site onto a different site. These other sites may associate their Tracking Technologies with you, independently collect data about you, including Personal Information, and may or may not have their own published privacy policies.

Third-party applications may also be available via the Site. The owners of these applications (“Third-Party Owners”) may collect Personal Information and other data from you and may have their own policies and practices. We are not responsible for how Third-Party Owners or their applications collect or use your information and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. These Third-Party Owners may have their own terms of service, privacy policies or other policies and ask you to agree to the same. We are not responsible for these third-party privacy policies or the practices of Third-Party Owners. Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications. We also encourage you to note when you leave our Site and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.

6. What About Ads?

Data about your activities online is being collected on our Site for use in providing advertising tailored to your individual interests. We may use third parties such as network advertisers and ad exchanges to serve advertisements across the Internet and may use third party analytics service providers to evaluate and provide us and/or third parties with information about the use of these ads on third party sites and viewing of ads and of our content. Network advertisers are third parties that display advertisements, which may be based on your visits to the Site. Third parties may offer you a choice as to whether or not to have your information collected for that purpose. This section of the Privacy Policy provides details and explains how to exercise that choice.

The Site’s third-party ad network and exchange providers, the advertisers, the sponsors and/or traffic measurement services may themselves set and access their own cookies (including Flash cookies), web beacons and other Tracking Technologies on your Device and track certain behavioral Usage Information regarding users of your Device via a Device Identifier. These third-party Tracking Technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you. You acknowledge and agree that associated technology may access and use your Device and may set or change settings on your Device in connection with the associated operations. Note that any images (or any other parts of content) served by third parties in association with third-party ads or other content may serve as web beacons, which enable third parties to carry out the previously described activities.

Third-party Tracking Technologies are not controlled by us, even if they use our technology to help store or collect data. Statements regarding our practices do not apply to the methods for collecting information used by these third-party advertisers and others or the use of the information that such third parties collect. We do however work with third parties to make efforts to have you provided with the information on their practices and any available opportunity to exercise choice. The relevant third party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices. We make no representations regarding the policies or practices of third-party advertisers or advertising networks or exchanges or related third parties.

However, some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available at the end of this Privacy Policy.

While we may use a variety of companies to serve advertisements, you may wish to visit http://www.networkadvertising.org/optout_nonppii.asp, which provides information regarding this practice by Network Advertising Initiative (“NAI”) members, and your choices regarding having this information used by these companies, including the “opt-out” procedures of NAI members. Opting out of one or more NAI members only means that those NAI members no longer will be allowed under their own rules to deliver targeted content and/or ads to you, which will affect this and other sites, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different Device or change web browsers, your NAI opt-out may not, or may no longer, be effective. Additional information is available on the NAI’s web site accessible by the above link. You may also be able to opt-out of receiving third-party behavioral ads on certain sites by visiting the Digital Advertising Alliance (“DAA”) web site at http://www.aboutads.info/choices/#completed. Similar limitations may apply to the DAA opt-out. We are not responsible for effectiveness of or compliance with any third-parties’ opt-out options.

7. How Do I Change My Information and Communications Preferences?

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. The Site may allow you to review, correct or update Personal Information you have provided through the Site’s registration forms or otherwise, and you may provide registration updates and changes by contacting us by e-mail: privacy@stmatthews.edu. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). With respect to our mobile and other applications (i.e., when we are the application publisher), you can prospectively stop all collection of information by the application by uninstalling the application. You may use the standard uninstall process as may be available as part of your applicable Device or potentially via the appropriate application or app marketplace. Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. When you edit your Personal Information or change your preferences on the Site, information that you remove may persist internally for St. Matthew’s administrative purposes. You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails. This will not affect subsequent subscriptions and if your opt-in is limited to certain types of emails the opt-in will be so limited. Please note that we reserve the right to send you certain communications relating to your account or use of our Site, such as administrative and Site announcements and these transactional account messages may be unaffected if you have not opted-in to receiving our marketing communications. If you have any questions about the Privacy Policy or practices described in it, you should contact us in the following ways: Postal Mail: St. Matthew’s University, 11486 Corporate Blvd, Suite 120 Orlando, FL 32817, United States; by email: privacy@stmatthews.edu.

8. What About International Data Transfers?

We share your personal data within the GUS Group of which St. Matthew’s University is a part of. This will involve transferring your data outside of the Caribbean.

Whenever we transfer your personal data internationally, we ensure an adequate degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries by following the guidelines set by Ombudsman, Cayman Islands (https://ombudsman.ky/data-protection) proposed transfer, after having been informed of the possible risks of such transfers for you due to the absence of an adequacy decision and appropriate safeguards.
• The transfer is necessary for the performance of a contract between you and us as the data controller or for the implementation of pre-contractual measures taken at your request.
• The transfer is necessary for the conclusion or performance of a contract concluded in your interests between us as the data controller and another natural or legal person.
• The transfer is necessary for important reasons of public interest.
• The transfer is necessary for the establishment, exercise or defence of legal claims.
• The transfer is necessary in order to protect your vital interests or the vital interests of other persons, where you are physically or legally incapable of giving consent.

Please contact our privacy team if you want further information on the specific mechanism used by us when transferring your personal data.

9. What Should Parents Know About Children?

We understand the importance of protecting children’s privacy in the interactive world. We are a general audience Site and do not use the Site to knowingly collect personal information from children under the age of 13 that requires parental notice and consent under the GDPR and the Children’s Online Privacy Protection Act (“ COPPA”) without such parental consent. If you are a child under 13 years of age, you are not permitted to use the Site and should not send any information about yourself to us through the Site.

In the event that we become aware that we have collected personal information from any child, we will dispose of that information in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of 13 has provided us with personal information without required consent, please contact us at privacy@stmatthews.edu.

10. What About Security?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. What About Changes to the Privacy Policy?

We reserve the right to change this Privacy Policy at any time. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of our Site indicates your consent to the privacy policy posted at the time of use.

However, we will not use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent.

To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

12. Student Educational Records

If you become a student, your educational records are subject to the U.S. federal Family Educational Rights and Privacy Act (“ FERPA ”), state laws and St. Matthew’s University’s policies.

Students have the right to limit access to FERPA-defined directory Information about them. To obtain a copy of St. Matthew’s University’s FERPA policy, click here. If you have questions about our FERPA policy, you may also contact us at ferpa@stmatthews.edu.

The following third parties that collect information from you on the Site have given us notice that you may obtain information on their policies and practices, and in some instances opt-out of certain of their activities, as follows:

Party	Service	For More Information	Use of Tracking Technologies	Privacy Choices
Google	Analytics	Click here	Yes	Click here
Google	Adwords	Click here	Yes	Click here
Facebook	Ads Manager	Click here	Yes	Click here
Yahoo	Yahoo Advertising	Click here	Yes	Click here
Bing	Bing Ads	Click here	Yes	Click here

INFORMATION ABOUT OUR USE OF COOKIES

SMUSOVM website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site.

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device.

Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.

How to control cookies

You can find more information about cookies and how to disable them at allaboutcookies.org and youronlinechoices.eu.

Disabling cookies may result in some features on our websites, and some of our online services, not functioning correctly or as intended. Cookies will typically expire automatically after 2 years, though you can choose to delete your cookies at any point manually or disable cookies on your computer.

Cookies used on SMUSOVM domain and sub domains

In accordance with ICC UK Cookie guide, we use the following cookies: 

Strictly necessary cookies

These cookies are essential in order for you to move around the website and use its features. Usage examples are accessing secure areas of a site and adding items to a shopping basket. Essentially, they enable services you have specifically asked for.

Performance cookies

These cookies collect information about how visitors use a website, for instance, which pages a visitor goes to most often. They do not identify a visitor and are only used to improve how a website works. Analytics cookies fall into this category. Essentially, they collect anonymous information on the pages visited.

Functionality cookies

These cookies remember choices made by a user to personalise a site, such as area you are in or language. Essentially, they remember choices you have made to improve your experience.

Targeting or advertising cookies

These cookies are used to deliver ads more relevant to the users. Essentially, they collect information on your browsing habits to make advertising relevant to you and your interests.

The table below explains the cookies we use and why.

Strictly Necessary

Cookie	Name	Purpose	More Information
	visitor_id	The visitor cookie includes a unique visitor ID
	pi_opt_in	Tracks opt in or out of Pardot cookies
	visitor_id-hash	This cookie is a security measure
Google Optimizer	_gaexp	These cookies collect information about how visitors interact with the pages on the website. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form.  The information obtained does not identify anyone.	Click here for an overview of cookie usage at Google

Functionality

Cookie	Name	Purpose	More Information
	lpv	This LPV cookie is set to keep Pardot from tracking multiple page views on a single asset over a 30-minute session.
	pardot	A session cookie named pardot is set in your browser when you access a form, landing page, or page with Pardot tracking code. The cookie denotes an active session and isn’t used for tracking
Transversal Video player	__distillery	This cookie is used by Transversal video player to remember where you are in a video so that if playback is interrupted (for example, by losing your internet connection) then you can get right back to where you left off.	https://www.transversal.com/company/legal/cookies-and-privacy-policy
Pixel (Third Party)	E	Keeps track of special fonts for internal analysis, does not register any visitor data

Performance

Cookie	Name	Purpose	More Information
Google Analytics	_dc_gtm_ ; _gid ; _ga	These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited	Click here for an overview of privacy at Google
Google Optimizer	_gaexp	These cookies collect information about how visitors interact with the pages on the website. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form.  The information obtained does not identify anyone.	Click here for an overview of cookie usage at Google
In -house cookies	showed-cookie-popup ; load-once	Speeds up loading of page. Cookie pop up only loads once for recurring visitors

Advertising/Targeting

Cookie	Name	Purpose	More Information
Google Services	_gcl_au	Used by Google AdSense for experimenting with advertisement efficiency across websites using their services.	https://policies.google.com/privacy
Facebook	_fbp	This cookie is used to collect information on how users from facebook interact with our website	https://www.facebook.com/policy.php
Youtube.com (Third Party)	YSC ; VISITOR_INFO1_LIVE ; GPS ; PREF	Registers a unique ID to keep statistics of what videos from YouTube the user has seen. Tries to estimate the users’ bandwidth on pages with integrated YouTube videos. Registers a unique ID on mobile devices to enable tracking based on geographical GPS location. Registers a unique ID that is used by Google to keep statistics of how the visitor uses YouTube videos across different websites.	https://policies.google.com/privacy?hl=en
Veinteractive.com  (Third Party)	__ssid	Allows us to email customers who abandon a transaction on our website to ask if they need any assistance from our supporter services team.	https://www.ve.com/privacy-policy

Unclassified

Cookie	Name	Purpose	More Information
intelligencebank.com	gaconnectorId	Unclassified	https://www.intelligencebank.com/privacy