PRIVACY NOTICE FOR ADVANCEMENT
I. Purpose of this Notice
Princeton University ("Princeton" or the "University") respects and protects the privacy of alumni, donors' and affiliates' personal data. This notice explains how Princeton, through Advancement (Office of Alumni Affairs and Office of Development), may collect and use your personal data for engagement and development activities.
Personal data is information that Princeton holds about you and which identifies you. This includes information such as contact information, and is further detailed below.
II. Princeton's Commitment to Alumni, Donors & Affiliates
When you choose to attend Princeton, you agree that we can process your personal data for administrative and educational purposes. Such purposes include processing your personal data, at the appropriate time, for alumni and development activities as well. The University regards its alumni engagement efforts, including its outreach to alumni and the services it provides to alumni, as an important and integral part of the University's long-term commitment to its students. Similarly, when you donate to or are otherwise affiliated with Princeton, you agree that we can process your personal data in connection with your donation or affiliation and future University activities.
III. Where Do We Get Your Personal Data?
The University's Advancement Office obtains and updates personal data regarding alumni, donors and affiliates from various sources, including the following:
From you, when you:
- provided information to the University as a student (if applicable)
- provide information through one of our websites or through the act of donating or volunteering
- provide information in response to University outreach (e.g. response cards, surveys, Gift Aid forms, etc.)
- have discussions with University representatives
- register to attend and/or attended a University-related event
From third-party sources:
- Certain public available information may be provided by third-party sources that assist us with pursuing our purposes described below, including: affiliated and related University organizations; media; public records; directories; social networks; and market research sources.
IV. Categories of Personal Information We May Hold
The information about you that we may maintain includes:
- name (including former name)
- degrees and years earned
- details of your Princeton experience (e.g., residential college, student activities)
- contact information (e.g., address, telephone, email)
- date of birth
- employment and business details, including: positions, professional memberships and qualifications, and other notable achievements
- interests and group memberships
- select information about your wealth
- family details and relationships with other University constituents
- events you have been invited to and whether or not you have responded or attended
- volunteer and giving activity
- a history of communications with you (e.g., emails sent by the University may record whether the email has been opened and whether any links have been clicked on)
- information you have shared with us or affiliated organizations
- photographs and other media from Princeton and affiliated events
As with most websites, certain actions you take will be recorded as cookies by the University's websites. Please see the University's website privacy notice for more information.
V. What Do We Do With Your Personal Information?
We may use your information to help us maintain an engaged alumni community and for fundraising purposes. For example:
- to verify an account and provide a personalized online experience
- to process a gift
- to support your volunteer activities
- to support University initiatives through philanthropic efforts
VI. Who Can See Your Information?
Your personal data is held securely within the University. Access is limited on a need-to-know basis, and staff receive training on data protection, including compliance and confidentiality. Certain personal information is also shared with contracted vendors for discrete University business purposes (e.g., mail houses, event venues, market research firms). We do not sell or share your personal data with third parties for commercial purposes. Note that all students and alumni have access to TigerNet, the University's alumni online community, which includes select alumni information. Note also that volunteers may have access to select personal information as necessary for the volunteers to support the University's engagement and fundraising efforts.
We may, from time to time, communicate with you by email, mail, telephone, or other methods, to pursue the purposes mentioned above. In particular, we regularly communicate with alumni, donors, and affiliates regarding fundraising and volunteer activities.
If you have opted not to receive communications from us, we will comply. In particular, you can request to have your contact information amended by contacting the Alumni Records Office, at email@example.com or through self-service via TigerNet.
We view being a member of the University and part of the alumni community as a lifelong relationship. In general, the University may retain University alumni, donor and affiliate personal information in perpetuity or until the individual asks us to remove it from our records.
If you decide that you no longer wish to receive communications from Princeton, please understand that we still need to retain certain personal information for our records (e.g., to show that you don't want us to contact you or for audit and compliance purposes).
For additional information about Princeton's record retention practices, please see Princeton's "University-wide Records Management Principles" ( https://records.princeton.edu/policies-procedures ).
For Our Alumni, Donors & Affiliates Who Reside in the EU
This addendum is pursuant to the European Union's ("EU's") General Data Protection Regulation ("GDPR"). The GDPR may apply to the processing of personal information that you provide Princeton while you are in the EU, but it does not apply to information that you provide while you are in the US (for example, on campus).
I. What Constitutes "Personal Data"
Your "personal data" includes, for example, your contact information. It may also include "special categories" of data under the GDPR. Such "special categories" include information about your racial or ethnic origin, sexual orientation, religious beliefs or other beliefs, physical or mental health, or information concerning any criminal offenses or criminal proceedings.
These "special categories" of data would only be collected if (i) you have directly provided the data yourself (with your consent), for example during one-to-one conversations with our representatives or collected for event management purposes, e.g., for assessing access requirements arising from a disability, or (ii) it has been obtained from public sources.
II. Our Legal Basis for Processing Your Personal Data Under GDPR
We may use your personal data with your consent. In addition, Princeton has made a commitment to its students, as lifetime members of the University community, to provide services and activities for alumni, and we may use your information to fulfill that commitment.
By supporting University alumni and undertaking other development activities, the University is acting in the public interest. In particular, alumni engagement and fundraising supports the University's charitable educational mission and the benefits to society that flow as a result.
Also, the University's activities with respect to its constituents are necessary to further the legitimate interests of the University. Legitimate interests of the University include supporting educational activities and ongoing development of the University and members of its community.
III. Your Rights Under GDPR With Regards to Your Personal Data
Subject to certain limitations and conditions, you have the following rights with respect to the processing of your personal data:
- Right of access: You have the right to request access to the personal data that we hold about you.
- Right of rectification: You have the right to correct personal data that we hold about you that is inaccurate or incomplete.
- Right to erasure: In certain circumstances, you have the right to request that the personal data we hold about you be erased from our records.
- Right to restriction of processing: In certain circumstances, you have the right to restrict certain processing of your personal data.
- Right of portability: You have the right to request that personal data we hold about you be transferred to another organization.
- Right to object: You have the right to object to certain types of processing of your personal data, such as direct marketing (to the extent applicable).
- Right to judicial review: In the event that we refuse a request under rights of access, we will provide you with a reason. Individuals in the EU have the right to complain as outlined in "Further Information and Guidance" section below.
IV. Sharing Your Information Outside the EU
If we collect your information while you are in the EU, we may need to share your personal data outside the EU (for example, by transmitting it to Princeton NJ, USA).
The European Commission provides a list of countries which, according to the Commission, have adequate data protection rules. The list can be found here: http://ec.europa.eu/justice/data-protection/international- transfers/adequacy/index_en.html .
If the country that we are sending your information to is not on the list, or is not a country within the EEA (which means the European Union, Liechtenstein, Norway and Iceland), then it might not have the same level of protection for personal data as the EU provides.
Upon request, we will provide you with additional information about the data security safeguards which Princeton has in place outside of this privacy notice. In particular, if you have any questions about the safeguards that are in place, please contact Princeton's Information Security Office at firstname.lastname@example.org .
V. Further Information and Guidance
Please contact us should you have any questions or concerns at GDPR@princeton.edu . Specifically, as noted above, you can request to have your contact information amended or to discontinue receiving communications from us by contacting the Alumni Records Office, at email@example.com , or through self-service via TigerNet.
If you believe that we have not acted properly when using your personal information, you can file a complaint with the appropriate supervisory authority in the EU:(http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.html )