European Union (EU) Privacy Disclosures
The following EU (European Union) privacy disclosures (the “Disclosures”) provide information about the collection, use, processing and sharing of data about individuals located in the European Union.
In these Disclosures:
- “GDPR” means the European Union’s General Data Protection Regulation;
- “Personal Data” means information that relates to an individual who is directly or indirectly identified or identifiable; and
- “EU Processing Activities” means the collection, use, processing or sharing of Personal Data when those activities are within the scope of the GDPR.
These Disclosures apply only to the use of Personal Data in EU Processing Activities. Further, these Disclosures apply only to the Suffolk University Boston, Suffolk University Madrid. In these Disclosures the words “we” or “our” refer to each. In some cases, Suffolk University may provide other information about its EU Processing Activities in its own supplemental or separate disclosures.
These Disclosures apply to EU Processing Activities by any means, including hardcopy (such as paper applications or forms) and electronic means (such as websites and mobile applications).
How We Collect and Use Personal Data
We collect several categories of Personal Data in circumstances that may involve EU Processing Activities, including data you provide, data collected automatically (potentially including location data), and data we obtain from third party sources.
We use the Personal Data that we collect to carry on various institutional and educational activities. We rely on a number of legal bases to lawfully process your Personal Data.
The ways in which we collect and use your data vary depending on the relationship between you and us, as well as the Suffolk University entity with which you interact may involve EU Processing Activities. Please note that, depending on the situation, some of the processing of Personal Data we do in the various circumstances described below may not fall within the scope of the GDPR.
We also use your data to provide you additional services which may under certain circumstances be based on your consent, may be necessary to fulfill our contractual commitments to you, may be necessary for legal compliance, or are necessary to serve our legitimate interest in the following operations:
- Conducting our operations and administering our educational offerings;
- The normal relationship between the two legal entities, Suffolk Boston and Suffolk Madrid;
- Administering fellowships, grants and other programs in support of individual study and research projects;
- Contacting you to respond to your requests or inquiries;
- Providing you with newsletters, articles, service alerts or announcements, event invitations, and other information that we believe may be of interest to you;
- Requesting gifts and donations;
- At your request, processing and fulfilling transactions for merchandise or other Suffolk products;
- Alerting you about a safety or security announcement;
- Conducting research, surveys and similar inquiries to help us understand trends and needs of our applicants, students and others using our websites or other services;
- Meeting the requirements of our accreditors;
- Disclosing directory information;
- Performing marketing, promotions and advertising, either directly or through third-parties. These activities may include interest-based advertising, targeted advertising and online behavioral advertising in order to increase the likelihood that the content would be of interest to you;
- Preventing, investigating, taking action regarding or providing notice of fraud, unlawful or criminal activity, other misconduct, security or technical issues, or unauthorized access to or use of Personal Data, our website or data systems; or
- Responding to subpoenas, court orders, or other legal process; enforcing our agreements; protecting the health, safety, rights or property of you, us or others; and meeting legal obligations.
Using and Sharing of Personal Data
We rely on several legitimate interests in using and sharing your Personal Data. These interests include:
- Providing, improving and customizing our educational offerings;
- Administration of our operations;
- Promoting the success of our current and former students;
- Furthering research and understanding in fields of academic study;
- Maintaining an ongoing relationship with alumni, donors and prospective donors, and helping to connect them with others;
- Requesting gifts or donations;
- Offering attendance to events and opportunities to volunteer;
- Conducting admissions research;
- Understanding how our online platforms are being used;
- Exploring ways to develop and grow our operations;
- Ensuring the safety and security of our students, faculty, fellows, employees and others;
- Enhancing protection against fraud, spam, harassment, intellectual property infringement, crime and security risks; and
- Meeting our obligations and enforcing our legal rights.
Legal Process, Safety and Terms Enforcement
We may disclose your Personal Data to legal or government regulatory authorities as required by applicable law. We also disclose your Personal Data to third parties as required by applicable law in connection with claims, disputes or litigation, when otherwise required by applicable law, or if we determine its disclosure is necessary to protect the health, safety, rights or property of you, us or others, or to enforce our legal rights or contractual commitments that you have made.
International Data Transfers
Suffolk University may transfer your Personal Data between Suffolk University Boston and Suffolk University Madrid and/or to the third parties as discussed above in order to provide an adequate service of higher education to our students or complementary activities. We may transfer your Personal Data outside the EU relying on appropriate or suitable safeguards or specific derogations recognized under data protection laws, including the GDPR.
We will provide you upon your reasonable, good faith request with information about whether we hold any of your Personal Data as part of our EU Processing Activities, to the extent required by and in accordance with applicable law. In certain cases, you may also have a right, with respect to your Personal Data collected and used in the EU Processing Activities, to:
- correct or update any of your Personal Data that is inaccurate
- to restrict or limit the ways in which we use your Personal Data;
- to object to the processing of your Personal Data;
- to request the deletion of your Personal Data; and
- to obtain a copy of your Personal Data in an easily accessible format.
To submit a request, please send an email message to EUDataSubjectRequest@suffolk.edu. Because we want to protect your data and avoid taking action regarding your Personal Data at the direction of someone other than you, we will ask you for information verifying your identity. We will respond to your request within a reasonable timeframe.
You also have the right to withdraw your consent to our processing of your Personal Data as part of the EU Processing Activities, where our processing is solely based on your consent, subject to certain limitations at law. In some cases, you can do this by discontinuing use of the services involved in the EU Processing Activities. This would include by closing all of your online accounts with us and contacting us at EUDataSubjectRequest@suffolk.edu to request that your Personal Data be deleted. If you withdraw your consent to the use or sharing of your Personal Data for the purposes set out in these Disclosures or the other Suffolk privacy statements that link to or expressly adopt these Disclosures, you may not have access to all (or any) of the related services, and we might not be able to provide you all (or any) of the services. Please note that, in certain cases, we may continue to process your Personal Data after you have withdrawn consent and requested that we delete your Personal Data, if we have a legal basis to do so. For example, we may retain certain data if we need to do so to comply with an independent legal obligation, if we still need the data for the lawful purposes for which we obtained the data, or if it is necessary to do so to pursue our legitimate interest in keeping our services and operations safe and secure.
If you have any complaints regarding our privacy practices, you have the right to make a complaint with your national data protection authority (i.e., supervisory authority).
User Generated Content
Some of our services involved in EU Processing Activities may enable users to submit their own content. Unless otherwise indicated, please remember that any Personal Data you submit or post as user-generated content could become public information. You should exercise caution when deciding to disclose your personal, financial or other information in such submissions or posts. We cannot prevent others from using that information in a manner that may violate these Disclosures, the law or your personal privacy and safety. We are not responsible for the results of such postings.
Updates to the Disclosures
We may update these Disclosures from time to time without prior notice by posting revised Disclosures to this site. You can determine when these Disclosures were last revised by checking the Last Updated date in these Disclosures.
If you have any questions, comments, requests or concerns about these Disclosures or other privacy-related matters, you may contact us in the following ways:
Attention: EU Data Privacy
8 Ashburton Place, Boston, MA 02108 USA
The website www.suffolk.edu belongs to Suffolk University Boston, 8 Ashburton Place, Boston, MA 02108-2770 USA including microsite www.suffolk.edu/Madrid for Suffolk University Madrid, Calle de la Viña, 3, 28003 Spain
The users of www.suffolk.edu may contact Suffolk University Boston in writing sent to the address stated above, or through any of the following means:
Telephone: (+1) 617-573-8000
Effective Date: May 25, 2018
Last Updated: January 9, 2020