Information that you give us
The types of information we collect concerning individuals includes:
- a) academic, alumni, donor, educational, employment-related and application information as further described below;
- b) business and personal contact information (such as name, postal and email addresses, and telephone number); and
- c) other information you provide to us (such as information provided by registering for email alerts or filling in forms).
In connection with an application on our admissions pages, you may provide Personal Data with the following types of information: login credentials; information regarding yourself, your contact details, place of birth, country of citizenship, work authorization status, education history, employment history and professional designations; and other information about your background and qualifications. In addition, we may be provided information about you when we contact the individuals you have listed as your reference contacts.
Alumni and Donors
In connection with our alumni and donor relationships we collect and process various types of Personal Data about alumni, donors and prospective donors from a number of sources, including data you provide to us. Examples of us collecting your Personal Data may include instances when you update your alumni or donor profile, engage with us on social media, complete a donation form or register to attend SASEF events. If you were a scholar, some of your Personal Data may be transferred from your student record into our alumni databases. We may also collect Personal Data from publicly available sources or third-party sources that support our operations. The Personal Data collected by us, or on our behalf, is collected for the primary purpose of providing you opportunities to engage with SASEF, the Schwarzman College, alumni, donors, prospective donors and students through interactions, events and your gifts or donations.
Employees and Job Applicants
In connection with our recruitment operations we may collect your Personal Data when you apply to work for SASEF. Further Personal Data collection occurs at hiring and throughout your relationship with us. The Personal Data collected by us, or on our behalf, are collected for the primary purpose of providing employment or enabling authorised persons to utilise our services and facilities. In addition, where legally permissible, you may provide information regarding your gender, race/ethnicity, and your veteran and disability status. SASEF will not consider either this information or your choice to decline to provide it in evaluating your qualifications. This information will be used only for Equal Employment Opportunity reporting and other legal and compliance purposes.
In connection with electronic interactions you have with us or our service providers (including by email, phone or other forms of electronic communication), we may record and monitor details of those interactions, including their content, to the extent permitted or required by applicable law.
We may also collect some information from other sources, including:
- a) if we have a business relationship with the organization that you represent, your colleagues or other business contacts may give us information about you such as your contact details or details of your role in the relationship; and
- b) information from third party data providers or publicly available sources for anti-money laundering, background checking and similar purposes, and to protect our organization and comply with our legal and regulatory obligations.
We may use third-party web analytics services on our Sites, such as those of Google Analytics. These service providers help us analyse how visitors use the Sites. The information obtained for this purpose (including your IP address and other information collected by automated means) may be disclosed to or collected directly by these service providers. To learn about opting out of Google Analytics, please click here.
The providers of third-party plugins and widgets on our Sites, such as embedded videos and social media sharing tools, may use automated means to collect information regarding your use of the Sites and your interactions with the plugins and widgets. This information is subject to the privacy policies or notices of the providers of the plugins and widgets.
We may use, disclose or otherwise handle the information described in this Privacy Notice for the following purposes to:
- operate, evaluate, develop, promote, and improve our organization;
- create and manage your account;
- comply with and enforce applicable legal requirements, relevant industry standards and our policies;
- protect against, identify and prevent fraud, money-laundering, breach of confidence, cyber attack, theft of proprietary materials, financial or business crimes, and other unlawful activity;
- in some cases, in order to operate, administer and improve the user’s experience of the Sites;
- send you (or produce) promotional materials, newsletters and other communications, including in visual and audio form (such as videos, podcasts and online seminars);
- communicate with you about, and administer your participation in, special events, programs, promotions, offers, surveys and market research;
- respond to your inquiries;
- manage your employment application, assess your qualifications and manage your employment with us;
- verify your information; and
- provide employment or enable authorised persons to utilise our services and facilities;
- run the application and evaluation cycles for the Schwarzman Scholars Program;
- provide online education courses and programs, and, if applicable, evaluate qualification for online education certificates or credit;
- allow you to engage with SASEF, the Schwarzman College, alumni, donors, prospective donors and students through interactions, events and your gifts or donations; and
- connect with, maintain records or our communications and follow up on opportunities with our alumni, donors, prospective donors and students.
In addition, we use information collected through cookies, web beacons, web server logs and other automated means for purposes such as (i) customizing our users’ visits to our Sites, (ii) delivering content tailored to our users’ interests and the manner in which our users browse our Sites, and (iii) managing our Sites and other aspects of our organization.
We also may use the information in other ways for which we provide specific notice at the time of collection.
We will only process your Personal Data as necessary so that we can pursue the purposes described above. Where we process your Personal Data for our legitimate interests as an organization or those of a third party, we do so only where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest in pursuing those purposes.
When we collect Personal Data from you, unless indicated otherwise, you should assume that, if we ask you for information, we need it for our organizational or compliance purposes. In limited circumstances, we are required to collect Personal Data to comply with a legal obligation and/or might ask you to provide information which is purely voluntary; in either case, this will be indicated to you. In other circumstances we may seek to collect Personal Data for which we need to obtain your express and informed consent. This may be the case when the Personal Data contains information about you which is particularly sensitive – such as information relating to race or ethnic origin, religious or philosophical beliefs, trade union membership, political opinions, genetic or biometric data, health, and sexual orientation. Please note that in such cases we will only process your Personal Data with your express and informed consent, which you may withdraw at any time by contacting us.
If you are a former applicant, student, donor, alumni, employee, worker, contractor or member of SASEF, we will continue to process your Personal Data for a reasonable period following the end of your employment or engagement for our legitimate business and / or our legal compliance purposes and / or for the establishment or defence of a legal claim. Further, in some instances, we may process your data to perform our obligations under the contract between us (e.g. to pay you your final salary payment after your termination date). We only carry out such processing where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interests in pursuing those purposes. Your data will be retained and deleted in accordance with our retention policies and procedures (as discussed further below).
We and third parties acting on our behalf (such as Facebook, Twitter. Google and LinkedIn) may collect information about your online activities over time and across third-party websites to provide you with advertising about products and services tailored to your interests. Where required by applicable law, we will obtain your consent for the processing of your Personal Data for direct marketing purposes.
You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to users by considering demographic data, users’ inferred interests and browsing context. These networks track users’ online activities over time by collecting information through automated means (such as by cookies, web server logs, web beacons and other similar technologies). The networks use this information to show ads that may be tailored to individuals’ interests, to track users’ browsers or devices across multiple websites or apps, and to build a profile of users’ online browsing activities. The information our ad networks may collect includes data about users’ visits to websites and apps that participate in the relevant ad networks, such as the pages or ads viewed and the actions taken on the websites or apps. This data collection takes place both on the Sites and on third-party websites and apps that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts.
The Sites are not designed to respond to “do not track” signals received from browsers. To learn how to opt out of ad network interest-based advertising, please visit www.aboutads.info/choices, http://www.networkadvertising.org/choices/ or http://www.youronlinechoices.eu/.
We do not disclose Personal Data we obtain about you through the Sites or other channels covered by this Online Privacy Notice, except as described in this Online Privacy Notice. We may share your Personal Data with our authorized third parties including Tsinghua University (which must accept you into the university if you wish to become a scholar). Depending on the nature of our relationship with you, we also share Personal Data with service providers who perform services on our behalf, including our professional advisors. We do not authorize these persons to use or disclose the information except as necessary for the purposes for which it is provided or to comply with legal requirements.
We also may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities, regulators and/or other government entities and/or other competent authorities based on a lawful disclosure request, or (iii) when we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.
In addition, we may share anonymous / aggregated information with third parties, such as service providers, in order to facilitate our operations.
Information collected through third-party plug-ins and widgets on the Sites (such as information relating to your use of a social media sharing tool) is collected directly by the providers of the plug-ins and widgets. This information is subject to the privacy policies of the providers of the plug-ins and widgets, and SASEF is not responsible for those providers’ information practices.
We may transfer the Personal Data we collect about you to recipients in countries other than the country in which the information originally was collected. Where you are based in the UK (after it has left the EU), the EU, or another country which imposes data transfer restrictions outside of its territory, this includes transfers outside of the UK and the European Economic Area (“EEA“) or that geographical area, including to those countries in which our service providers and business partners operate. Those countries may not have the same data protection laws as the country in which you initially provided the information. Where we transfer Personal Data to countries outside of the UK, the EEA, or other territories subject to data transfer restrictions, we will ensure that our arrangements with them are governed by data transfer agreements or safeguards, designed to ensure that your Personal Data is protected as required under applicable data protection law (including, where appropriate, under an agreement on terms approved for this purpose by the European Commission or by obtaining your consent).
We intend to keep your Personal Data accurate and up-to-date. We will delete the information that we hold about you when we no longer need it. We retain your Personal Data for as long as it is required by us for our legitimate purposes, to perform our contractual obligations, or where longer, such longer period as is required or permitted by law or regulatory obligations which apply to us.
We will retain your information in line with our retention policies and, in any event, for no longer than is necessary given the purpose for which it was collected, after which it will be deleted or anonymized.
Note that we may retain some limited information about you (even when we know that you have left the organization that you represent) so that we can maintain a continuous relationship with you if and when we are in contact with you again.
We offer you certain choices in connection with the Personal Data we collect from you. To update your preferences or submit a request, please contact us as indicated in the “How to Contact Us” section of this Privacy Notice. To the extent provided by the law of your jurisdiction or otherwise applicable to our processing of your information, you may request access to the Personal Data we maintain about you or request that we correct, amend, delete or block the information by contacting us as indicated below. Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your Personal Data, and we will apply your preferences going forward. You can also lodge a complaint about our processing of your Personal Data with the body regulating data protection in your country.
These rights may include:
Rights of access, correction and deletion. You may have a right of access to the Personal Data that we hold about you, and to some related information, including the purpose for processing the Personal Data, the recipients of that Personal Data to the extent it has been transferred internationally, and, where the Personal Data has not been collated directly from you, the source. You may also have the right to require any inaccurate Personal Data to be corrected or deleted.
Right to object, and portability. You can object to our use of your Personal Data for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your Personal Data (and require them to be deleted) in some other circumstances. In some circumstances, you may also have a “data portability” right to require us to transfer your personal data to you or a third party.
If you wish to exercise any of these rights, please Contact us as set out below.
Complaints. You can also lodge a complaint about our processing of your Personal Data with the body regulating data protection in your country.
We maintain administrative, technical and physical safeguards designed to protect Personal Data we obtain through the Sites against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Our Sites may provide links to other websites for your convenience and information. These websites may operate independently from us. Linked websites may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked websites are not owned or controlled by us, we are not responsible for their content, any use of the websites, or the privacy practices of the websites.
This Online Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our Personal Data practices. We will post the updated version on the Sites and indicate at the top of the Notice when it was most recently updated. Please check for any updates regularly.
If you have any questions or comments about this Online Privacy Notice, or if you would like us to update information we have about you or your preferences, please email us at firstname.lastname@example.org. You also may write to:
Stephen A. Schwarzman Education Foundation
641 Lexington Avenue, 23rd Floor | New York, NY 10022
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