The purpose of this Privacy Policy is to outline how CUW collects, uses, transfers, and discloses Personal Information that it collects through our website (https://windsor.campbellsville.edu), other CUW sites, including TigerNet our online portal, as well as through our mobile applications, via email, Live Chat over the phone, via printed forms and in person (collectively, the “Sites ”). Some information is collected automatically through various web and Internet technologies including social networking tools used by the University. 

The University has developed policies and procedures consistent with the Personal Information Protection and other relevant privacy laws. 

By choosing to continue to use the Sites and providing us with your Personal Information, you expressly consent to our collection, use and disclosure of Your Personal Information in accordance with this Privacy Policy. If you do not understand the nature, purpose and consequences of CUW collecting, using, and disclosing your Personal Information, please do not use the Site or provide us with any Personal Information, and contact us at the contact information set forth below so that we can address your questions or concerns.

Scope

This Policy applies to all visitors, students, alumni, faculty, and staff who use the University Sites. This policy pertains to all information collected by or submitted to official University Sites, including any and all domains owned and managed by the University, which are classified and identified as the official web pages of University schools, departments, and other divisions and entities.

Definitions

• Collection: the act of gathering, acquiring, recording, or obtaining Personal Information from any source, including third parties, by any means.
• Consent: voluntary agreement to the collection, use and disclosure of Personal Information for defined purposes. Consent can be either express or implied. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of CUW. Implied consent is consent that can reasonably be inferred from the circumstances or from an individual’s action or inaction.
• Disclosure: making Personal Information available to a third party for that party’s own use.
• Personal Information: means information, recorded in any form, that identifies an individual or that could be used to identify an individual, but does not include aggregated or depersonalized information that cannot be associated with an individual.
• Transfer: making Personal Information available to a third party for processing, storage or otherwise, solely to be used on behalf of CUW.
• Use: the treatment, handling, and management of Personal Information by and within CUW.

Accountability

CUW is responsible for Personal Information under our possession and control. We have a designated a Privacy Officer to be responsible for our compliance with this Privacy Policy and applicable privacy legislation.  CUW will make known, upon request, the title and contact information of the person or persons designated to oversee CUW’s compliance with this Privacy Policy.

CUW is responsible for Personal Information in its possession or custody, including information that has been transferred to a third party for processing. CUW shall use contractual or other means to provide a comparable level of protection while the information is being processed by a third party.

CUW shall implement policies and practices to give effect to these principles, including:

1. 1. implementing procedures to protect Personal Information;
   2. implementing an internal process to receive and respond to complaints and inquiries relating to this Privacy Policy; and
   3. training staff and communicating to staff information about the organization’s policies and practices.

What Information Do We Collect?

Personal Information

CUW collects Personal Information that you provide us voluntarily online or offline when you respond to an advertisement, a survey or request information, register for classes, apply for financial aid, order education or other products and services, or set up a site profile.  This includes, but is not limited to:

• Inquiry and Application Forms: information that you choose to complete, which may include your name, email address, phone number, and content of the e-mail, are used in order to provide you with information about the University.
• Financial and Payment Information: this includes banking and payment information to pay tuition and financial information related to financial aid.
• Admissions and Registration Information: this includes application forms, reference letters and grades, and courses and programs you register for.
• Login Site and Services: various websites and web services of CUW require users to log in and gain access to information and tools reserved for students, faculty, and staff.  Creation of a login account requires you to provide your student or faculty/staff ID number.
• Web Engagement Data: your engagement data (e.g., analytical info, referral data, form data, etc.) may be used to personalize our communications with you.

Non-Personal Information

Non-Personal Information (“NPI”) means information that is aggregated, anonymized or otherwise cannot be linked with any individual.  The University collects limited, non-personal identifying information your browser makes available when visiting websites. We may aggregate this non-identifying information for reporting purposes to access the effectiveness of our websites without disclosing specific information that would link to any individual. This includes:

• The Internet Protocol (IP) address and name of the Internet domain you used to access the Internet; The URL of the website from which you linked directly to the CUW Site;
• The date and time you accessed the CUW Site;
• The pages you visited, including the information requested through your browser, the response from your browser, the size of the page you received in response to the request, and the marketing email or web page that referred you to the page you visited; and
• The web browser and operating system you used to access the CUW Site.

In some instances, our websites use cookies that uniquely identify your browser so that we may provide content most relevant to your needs.  A cookie allows the University Sites to customize what you see in relation to the way you entered the website and content that you most recently viewed (i.e. if you logged into your student account, the website may be personalized for student viewing in subsequent visits). 

How Do We Use Your Personal Information?

CUW will only use the Personal Information that we collect for the purpose for which it was collected.  We use your Personal Information for the following purposes:

1. Manage and improve the user experience and preferences associated with the CUW Site and CUW communications;
2. For administrative uses, including determining eligibility for scholarships and student aid;
3. For the purposes of student progression and graduation with respect to CUW programs;
4. Track how often people gain access to or read CUW content;
5. Foster further communications and manage your subscription(s) to CUW publications;
6. Optimize advertisement, which may include embedding cookies or
7. Invite and/or register you (upon request) to events that may be of interest to you;
8. Personalize your online interactions with CUW;
9. Fulfill your online requests for goods or services;
10. For fundraising programs and initiatives;
11. Conduct online research, education, training, or surveys;
12. Identify anomalies in web traffic in order to help protect personal and CUW institutional information;
13. Exercise CUW’s legal rights, defend against legal claims, or respond to subpoenas, court orders, or other legal processes;
14. To comply with applicable laws; and
15. For any other reasonable purposes for which you may have provided your express consent or in which your consent can be reasonably implied. 

How Long Will We Retain Your Personal Information?

CUW will retain your Personal Information for as long as need it to fulfill the purposes for which it was collected and to comply with our legal obligations.

Consent

CUW respects your privacy and, unless otherwise required by law, we will not collect, use, or disclose your Personal Information without your prior consent. Your Personal Information will only be used for the purposes for which it was collected or in accordance with applicable laws. From time to time, we may wish to use Personal Information for new or additional purposes, in which case we will obtain your consent for such new purpose(s).

You may expressly give your consent in writing, verbally or through any electronic means.  In certain circumstances, your consent may be implied by your actions. For example, submitting a Request Info form is implied consent for a CUW enrollment counsel to contact you and provide you with information about the University.  The form of consent sought by CUW may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, CUW shall consider the sensitivity of the Personal Information and the reasonable expectations of the individual.  CUW will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.

In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected, but before use (for example, when CUW wants to use information for a purpose other than those identified above).

Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the purposes identified in this Privacy Policy at any time by contacting us at the contact information set forth below. If you refuse or withdraw your consent, you acknowledge that we may not be able to provide you or continue to provide you with certain services or information which may be of value to you.

Limiting Collection

When collecting Personal Information, CUW will limit the collection of Personal Information to that which is necessary to fulfill the purposes identified in this Privacy Policy. CUW will be open and transparent about the information that is being collected by communicating the purpose of collection.

Do We Disclose or Transfer Your Personal Information to Others?

CUW will maintain the strict confidentiality of all Personal Information collected and will not sell, transfer or otherwise disclose any of your Personal Information to any third party without your knowledge and consent except for purposes outlined in this Privacy Policy.

We may share your Personal Information with third party service providers and suppliers to facilitate the Sites or the services CUW provides. For example, we may share Personal Information from inquiry forms to our third-party recruiters.  We may also share your Personal Information with other Campbellsville University campuses. 

Only CUW’s, our affiliates’ and our service provider’s employees with a business need to know, or whose duties reasonably so require, are granted access to Personal Information that we are accountable for. All such employees will be required as a condition of employment to contractually respect the confidentiality of your Personal Information.

CUW may be required to disclose Personal Information such as Ontario Education Numbers, student characteristics and educational outcomes to the Ministry of Colleges and Universities. The ministry collects this data for purposes such as planning, allocating and administering public funding to colleges, universities and other postsecondary educational and training institutions and to conduct research and analysis, including longitudinal studies, and statistical activities conducted by or on behalf of the ministry for purposes that relate to postsecondary education and training.

How Do We Protect Your Personal Information?

CUW protects your Personal Information by security safeguards appropriate to the sensitivity of the information.  CUW Sites have standard security measures in place to protect against the loss, misuse, or alteration of the information under our control. For example, we utilize standard SSL encryption when accepting your credit card information during the online ordering process, as well as whenever we ask you to log in to any of the University’s online student and faculty services. 

Service Providers in Other Countries 

As noted above, we may use service providers and other third parties (“Third Parties”) to perform services on our behalf. These Third Parties may store, process, and transfer Personal Information on servers located outside of Canada in jurisdictions whose data protection laws may differ from those of Canada, such as the United States of America. As a result, Personal Information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to the laws in those jurisdictions. For example, information may be shared in response to valid demands or requests from government authorities, courts, and law enforcement officials in those countries. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require our Third Parties to maintain protections on Personal Information that are equivalent to those that apply in Canada.

How May I Access and Modify My Personal Information or Make a Complaint?

If you have questions or concerns about Personal Information collected by us or would like assistance accessing that information and/or would like to confirm its accuracy, you should contact CU organizational area to which you provided your information. If your privacy related questions or concerns are not addressed after contacting CU organizational area to which you provided data, then you may also contact: dataprivacy@campbellsville.edu.  

You may request to update and change your Personal Information in our control at the contact information set forth above.  We shall endeavor to correct or complete any Personal Information which you advise us is inaccurate or incomplete.  Where appropriate, the amended information shall be transmitted to third parties having access to such information.

Internet Technologies Used

Cookies, web beacons, and other relevant Internet technologies may be used in our emails and on our sites to allow us to accomplish the uses set out above as well as to deliver sites messaging and to keep track of your information. These small pieces of program code reside in your computer and browser and can be removed. If you desire to remove such technologies you may do so, but this may render our sites unusable to you. You can opt out of cookies or other Internet technologies used by disabling these features in your browser program. Please note that this deletion of certain opt out cookies may require you to renew your online behavioral advertising opt outs periodically. Consult your browsers Help menu for assistance in changing cookie settings or removing cookie files.

Electronic Communications

We comply with Canada’s anti-spam legislation (CASL) and we will not send you electronic communications in contravention of this law.  You may have also opted in to receive email communications from us.  If you opted-in to receive such communications, we may use the information to: communicate with you regarding the University and our programs and course offerings.

You will always have the opportunity to “unsubscribe” from receiving any of our e-mail or other communications at any time and we will ensure that our e-mails include instructions on how to unsubscribe if you no longer wish to receive future e-mails from us.  At any time, may opt-out of contact from us by clicking on the unsubscribe link in the e-mail.  If you decide to unsubscribe, we will only contact you for the purposes allowed under applicable law. 

Third Party Sites

Some of our sites may contain links to websites hosted by education partners, unrelated entities, and business associates operating websites on their own behalf or on behalf of multiple entities. Some of these websites may collect your personal information and may apply their own policies on how your personal information is used. In addition, some of our Sites may have additional policies that apply to the use of personal information collected on that site. Please make sure to read the policies of any websites you visit on the Internet carefully. Please be aware that we are not responsible for the privacy practices of the content of any websites that are not operated by or exclusively for us, and the collection, use, and disclosure of information about you will be subject to the policies applicable on those websites.

Children or Minors

We are committed to protecting the privacy of children and we do not knowingly solicit Personal Information from children under the age of 16. If you are under 16 years of age, then do not use the Site at any time. If a child has already provided us with Personal Information, his or her parent or guardian may contact us for the purpose of deleting this information.

Privacy Policy Changes

The University reserves the right to append or otherwise modify its Privacy Policy at any time. We expect any such changes to be minor, and notification of any changes will be made on this page. You should check back at this site periodically to obtain a current copy of this Privacy Policy. We urge you to review this Privacy Policy frequently to obtain the current version. Your continued provision of personal information or use of our services following any changes to this Privacy Policy constitutes your acceptance of such changes if we intend to use information that personally identifies you.