Alumni and Friends Privacy Notice

Effective Date: July 1, 2021

We at Webster University (“Webster,” “we,” “our,” “us”) understand that privacy is important to you and we are committed to protecting the privacy and security of your Personal Data.

This Alumni and Friends Privacy Notice contains important information regarding Webster’s privacy practices and the choices we offer to our valued alumni and friends with respect to their personal data. It is important that you read this Privacy Notice, together with any other privacy notices we may provide for specific circumstances when we are collecting or processing information about you.

This privacy notice contains important information regarding our privacy practices and the choices we offer you with regard to your rights and our obligations over the processing of your personal data and we encourage you to revisit this notice from time to time to stay informed of changes.

This privacy notice is effective from July 1, 2021. We may update this policy at any time.

If you have any questions regarding this Privacy Notice or any of our related privacy policies, please do not hesitate to contact your campus Privacy Manager or the Office of Privacy by phone or email using the contact details provided at the end of this document.

General Alumni and Friends Privacy Notice Information

This Privacy Notice applies to our collection, use, and retention (“processing”) of personal data, including any information transferred outside of the EEA or Switzerland, or which identifies, or can be used by us or on our behalf to identify, an individual.

At Webster, we may collect personal data from or about you in a number of ways, for example:

  • From the information you voluntarily provide to us: when you are graduating from one of our programs as you complete graduation-related processes and procedures, elect to receive electronic communications, sign up for an alumni event, make inquiries, raise concerns, or share what is going on in your life, make a donation to the University, or otherwise communicate with us by telephone, email, or via our website.
  • From the information you voluntarily provide to our relationship partners.
  • From the information we receive from other third-party entities who may provide us with reference information where you have granted them permission to do so.
  • From publicly available sources of information.

Webster University is a data controller for the information we process about you. Our partners may also process your personal data through the collaboration initiatives we operate as joint controllers. This means that we (and they) independently determine the purposes and manner in which your personal data is processed. We are not responsible for the privacy practices of non-partner third party organizations, nor can we endorse or take any responsibility for all of the privacy practices or policies of our relationship partners. We encourage you to exercise care when sharing your information and review the privacy practices of organizations before sharing your personal data.

We may combine the personal data you provide to us with information available from external sources to gain updated contact information or to gain a better understanding of our alumni and friends to improve our advancement objectives.

We may collect the following types of personal data about you:

  • Your name and contact information, such as your address, email address, and telephone numbers to identify you in our database, to communicate with you for marketing, promotional and fundraising purposes. To invite you to events and reunions and to provide you with the services, Webster news and information you have requested.
  • Ensuring we know how you prefer to be contacted.
  • Promoting the benefits and services available to alumni and friends.
  • To fundraise and for alumni purposes.
  • Your date of birth, degree subject, the dates your degree started and completed with final class of degree may be transferred from your student record.
  • Financial and tax information necessary to process philanthropic and research funding donations and contributions.
  • Keeping a record of your relationship with Webster.
  • Information relating to scholarships and bursaries where relevant to you.
  • Family or personal circumstances such as employment position, career advancement and dietary/mobility requirements (when you register for an event).
  • Options that you have selected to be of interest to you (e.g. whether you wish to volunteer, donate, or other support you wish to provide) Including:
    • Where you provided us with articles and testimonials for publication or where we have written them for you and you have approved them.
    • Asking you to provide support in a non-financial capacity (e.g. offering professional training placements, careers advice and help with student recruitment.

We may process your personal data because it is necessary for the legitimate interests of Webster:

  • In performance of our duties in carrying out our mission, vision, and values, our strategic plan and our Policies and Community Expectations.
  • To monitor and evaluate the performance and effectiveness of the University.
  • To maintain and improve the academic, corporate, financial, and human resource management of the University.
  • To promote equality and diversity throughout the University.
  • To seek advice on our legal rights and obligations and to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other students or faculty, visitors to the University, or anyone else who could be harmed by such activities.
  • To manage our accounts and records.

We also may process your personal data where it is necessary for compliance with our legal and regulatory obligations. In this respect, we may use your personal data for the following:

  • To meet our compliance, regulatory, and reporting obligations, such as compliance with anti-money laundering laws and accreditation requirements and public safety.
  • For the prevention and detection of crime.
  • To assist with investigations (including criminal investigations) carried out by law enforcement bodies and other competent authorities. We also may process your personal data where It is necessary to protect your or another person’s vital interests.

We rely on your explicit consent to use your personal data for marketing activities.

For the purposes referred to in this Privacy Notice and relying on the bases for processing as set out above, we may share your personal data with our relationship partners where it is necessary to do so in order to participate in certain advancement initiatives. We will not share your personal data with certain third parties if you ask us not to, but this may impact your ability to participate. Please refer to the "Your Rights with Respect to Your Personal Data" section below for more information.

Sometimes a law, court order, or other judicial or administrative process requires us to provide your personal data to a government authority or third party to a private lawsuit.

We do not sell your personal data or share it for any other purposes.

Some of the personal data we process about you will be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) and Switzerland. This happens, for example, where it is processed by Webster staff operating outside of the EEA or Switzerland or for one of our vendors who help us to operate perform our operational activities. Where personal data is shared or accessible by a Webster vendor, those organizations are subject to stringent due diligence evaluations and contractual restrictions on how they use and protect your rights and your data.

In these circumstances, your personal data will only be transferred on one of the following bases:

  • Where it is lawful and necessary in conducting our duties in carrying out our mission, vision, and values, accomplishing our strategic plan, and fulfilling our policies and community expectations.
  • Where you have provided explicit consent for the transfer.
  • Where the transfer is occasional and necessary in relation to a contract or a legal claim.
  • Where the transfer is made on the basis of an adequacy decision.
  • Where the transfer is subject to one or more appropriate safeguards for international transfers prescribed by applicable law.
  • Where the transfer is necessary for the execution of a contract with you or in order to take steps at your request prior to entering into a contract.

Please tell us promptly about any changes to the personal data you have voluntarily provided to us by contacting Webster University's Office of Advancement and/or the Office of Privacy. For contact details please see below.

This is particularly important with respect to your contact details.

We will retain your personal information for as long as needed to meet the uses described in “The Bases for Processing Your Information” in compliance with legal document retention obligations. Even where you have exercised one of the rights listed below with respect to your personal information, we will have the right to retain your personal information for compliance with a legal obligation, for the performance of a task carried out in the public interest, for archiving purposes in the public interest, for scientific or historical research purposes, for statistical purposes, or for the establishment, exercise, or defense of legal claims.

The personal data of alumni and friends are held in our database. We ensure that there are appropriate organizational and technical security controls in place to protect your personal details both when they are stored and when you update them. For example, our online forms are securely stored and our network is protected and routinely monitored.

We undertake regular reviews of who has access to the information that we hold to ensure it is only accessible by appropriately trained staff, all of whom have a contractual responsibility to maintain confidentiality.

Where the EU General Data Protection Regulations (GDPR) applies to the processing of your personal data, you have the following rights:

  • To be informed about the processing (the intention of this Privacy Notice).
  • To obtain access to the personal data that we hold about you.
  • To object on grounds relating to your particular situation to our processing activities where you feel they have a disproportionate impact on your interests, rights, and freedoms.
  • If you believe that your personal data that we possess is, or has become, incorrect or is incomplete, you may request to review, revise, correct, or update any of the personal data we may have about you free of charge.
  • To restrict the processing activities related to your personal data (and, where our processing is based on your consent, to withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal).
  • To have your personal data erased, except where we have a legal obligation to retain it.
  • To have personal data, which you have voluntarily provided to us, produced in a structured, commonly used, and machine-readable format, including for the purpose of transmitting it to another party.
  • To require us not to send you marketing communication.
  • Californian consumers may also have a right to opt out of the sale (or disclosure for other monetary gain or value) of your personal data. Webster does not sell your personal data but may disclose it to outside parties, including but not limited to our partners and vendors. If the CCPA applies to you and you would like to exercise this right, please contact the Office of Privacy.

Please note that the above individual rights are not absolute, and we may be entitled to refuse requests where certain exceptions apply. If you have given your consent and you wish to withdraw it, please contact Webster University's Office of Advancement and/or the Office of Privacy. For contact details please see below.

Please note that where our processing of your personal data relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our services to you and/or it may affect the provision of those services.

If you have any questions or concerns about your rights regarding your personal data, please contact Webster University's Office of Privacy. For contact details please see below.

You may also use the contact details provided below to initiate a request to exercise your rights to access, reject, correct, restrict, or erase your personal data, or where you may initiate a request for transfer of your personal data or change your marketing preferences.

Webster University is committed to answering your questions, resolving complaints about your privacy and our processing of your personal data. If you have an inquiry or complaint regarding this Privacy Notice, you should first contact privacy@webster.edu. In the event that a resolution cannot be reached, you may also contact your local data protection authority which may investigate your complaint further.

Austria
Österreichisch Datenschutzbehördede
Wickenburggasse 8
1080 Vienna
Austria / Europe

The Netherlands
Autoritei Persoonsgegevensns
Postbus 93374
250AJAJ DEHAAGAG

Switzerland
Office of the Federal Data Protection and Information Commissioner
Feldeggweg 1
CH - 300Bernene

Greece
Data Protection Authority Offices
Kifissias 1-3,
115 23 Athens,
Greece

This Privacy Notice is not directed to children under the age of eighteen (18), and we do not intentionally seek, nor do we knowingly process, personal data from children or minors as defined by the Children’s Online Privacy Protection Act (COPPA) and equivalent legislation to protect children’s data in any jurisdiction in which we operate, without the consent of a parent or legal guardian.

Webster reserves the right, at our sole discretion, to change, modify, add, remove, or otherwise revise portions of our policies and this Privacy Notice at any time, consistent with the requirements of applicable law. When we do, we will post the revision(s) on our website. If we change the Privacy Notice in a material way, we will provide appropriate notice to you. The “Effective Date” at the top of this Privacy Notice reflects the date of the most recent revisions.

If you have questions about our University Privacy Statement, this Privacy Notice, our privacy practices, or any other aspect of your privacy and the security of your Personal Information, please contact your Privacy Manager or our Office of Privacy by phone or email using the contact details provided below.

Webster University Office of Privacy — Director of Privacy Governance and Programs, International Campuses
Edna Schick-Bodrič
Palais Wenkheim Praterstr. 23, 1020 Vienna, Austria
Tel. +43 12 699 293 4334
edna.schick-bodric@webster.ac.at / privacy@webster.edu
 
Webster University Office of Privacy — Data Privacy Operations Manager, International Campuses
Ellie Despotaki
Ipitou Str. No 9, Athens 105 57, Greece
Tel. +30 211 990 5302
despotakie@webster.edu / privacy@webster.edu
Webster Vienna Private University — Privacy Manager
Allison Snowden
Palais Wenkheim Praterstr. 23, 1020 Vienna, Austria
Tel. +43 1 269 9293 4324
allison.snowden@webster.ac.at
Webster Geneva Campus — Privacy Manager
Mr. Michel Pollak
15, Route de Collex, 1293 Bellevue, Switzerland
Tel. +41 22 959 80 03
michelpollak74@webster.edu
Webster University Leiden — Privacy Manager
Chris (Mac) McDonnell
Boommarkt 1, 2311 EA Leiden, The Netherlands
Tel. +31 71 516 8000 x4526
mcdonnell16@webster.edu
Webster University Athens — Privacy Manager
Angelos Kostopoulos
9 Ipitou St., Athens 105 57, Greece
Tel. +30 211 990 5302
privacy@webster.edu
Webster University Georgia — Privacy Manager
Gaga Gvenetadze
82 I. Chavchavadze Avenue, Tbilisi 0612, Georgia
Tel. +995 598 389 037
gagagvenetadze@webster.edu
Webster University Tashkent — Privacy Manager
Oydin Sabirova
13 Alisher Navoiy Str., Tashkent 100011, Uzbekistan
Tel. +99871 241 3300
oydinsabirova09@webster.edu