Data Collection Policy And Privacy Notice
The University of New Haven (hereinafter referred to as “U. New Haven”) Study Abroad Office is committed to safeguarding the privacy of students (“you”) who participate in our programs, as well as other individuals that interact with our website and our office. This online privacy statement is intended to inform you how we collect information about you, how that information may be used, and how we protect any information you choose to provide us.
This Privacy Notice describes our practices on the collection, processing, use, disclosure and storage of information about you. When you apply to our programs, or otherwise provide us with information or use our websites and other services, your information will be handled as described in this Privacy Notice. Submittal and processing of personal data is necessary to achieve the purposes specified below.
If you do not agree to the terms of this notice, please do not provide your information or otherwise use our site and/or services. Any refusal will make it impossible to carry out the necessary activities and the correct administrative and didactic management of students’ programs necessary to accomplish the contractual obligations of U. New Haven in connection with your study abroad stay at U. New Haven, currently in Prato, Italy, or other destinations described in your program, as well as the obligations imposed by law.
You also hereby waive any right to privacy or confidentiality regarding U. New Haven’s reporting to the appropriate authorities if you are seriously ill; suffer an injury; are the victim or perpetrator of harassment, whether on or off campus; are the victim or the perpetrator of sexual or gender-based misconduct and/or of criminal behavior, whether on or off campus, and grant U. New Haven staff, faculty and administrators full authority to report to the appropriate authorities at the home school any and such all incidents, under the applicable laws (including but not limited to Title IX and Clery Act), whether or not it involves disciplinary action.
Pursuant to the terms and conditions of Section 13 of D.Lgs. n. 196 of 30th June 2003 (“Codice in materia di protezione dei dati personali” – Personal Data Protection Law, hereinafter “the Law”) and to the provisions of Regulation (EU) 2016/679 (“Regulation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data”, hereinafter “the EU GDPR”), we hereby inform you that U. New Haven, in its capacity as Data Controller in Italy, pursuant to Section 29 of the above Law regarding the processing of your personal data and information, is required to provide you with the following information:
UNIVERSITY USE AND PROCESSING OF INFORMATION
The Study Abroad Office will use information that you provide to us and information we collect about you to administer your application and support your participation in our Study Abroad programs. All personal data you have provided to U. New Haven, as well as any entity from which personal data is collected, and all the further data provided in order to allow the planning and organization of the study abroad programs at U. New Haven, and thereof aimed at the performance of the academic services to be provided to you, will be processed and handled by U. New Haven in accordance with its policies and with the aforementioned Law and EU GDPR, and with the principles of fairness, lawfulness, transparency, purpose limitation, accuracy, storage limitation, integrity and confidentiality and accountability, as well as the utmost protection of your privacy; sensitive data processing will only take place in relation to data regarding your health condition (such as diseases, allergies, food intolerances) or judicial data.
All data shall be processed exclusively for U. New Haven institutional purposes, connected or related to the activities carried out by U. New Haven, such as study abroad programs in Italy or other countries, the accomplishment of bureaucratic practices for your entry in Italy or other countries, the performance of the contractual obligations of U. New Haven in connection with your study abroad stay at U. New Haven, currently in Prato, Italy, or other countries described in your program. The University may process your information in furtherance of other legitimate interests or purposes, such as:
- To fulfill the obligations established by any applicable law, including the regulations or the European Union Law.
- To execute the contractual obligations with reference to your enrollment with the U. New Haven Study Abroad Programs (such as, but not limited to course attendance certification, students’ health and safety protection).
- To obtain the necessary visa documents for your travel.
- With reference to the data provided by public authorities or hospitals should an accident or aggression occur to the student, to take the necessary actions.
Sensitive data regarding your health conditions and food habits will only be processed for the purpose of protecting students’ safety or of fulfilling the obligations established by law, by regulations or by the European Union Law; sensitive data regarding judicial measures which may have been provided to U. New Haven by public bodies will be processed only for purposes relating to a health or safety emergency and complying with any applicable mandatory provision of Italian or European Union law.
- To analyze and improve our programs.
- To fulfill other University responsibilities or purposes.
- To provide services to you.
Office of Study Abroad
University of New Haven
Maxcy Hall, Room 109
300 Boston Post Road
West Haven, CT 06516
Our website uses a built-in feature of your browser to set a “cookie.” Your name, and other personal or biographical information, is not shared. Unless you explicitly provide this information, we will not be aware of your identity. The cookies set can be classified as “performance cookies”—used to improve the speed, functionality, and usability for site visitors. Browsers give you the ability to reject specific cookies, or all cookies, if you choose. However, rejecting cookies may impact your ability to use certain features of the site.
AUTHORIZED ACCESS AND COLLECTION OF DATA
Data processing will take place, according to the aforementioned criteria, only within those offices of U. New Haven premises which are exclusively dedicated to U. New Haven study abroad programs.
The data will be handled only by the persons who are in charge and responsible of the related activities and by other persons working on the same areas as specified in internal communications; sensitive data will be handled only within those offices of U. New Haven premises which are exclusively dedicated to U. New Haven study abroad programs, for the purposes above specified, by persons officially appointed to this task.
Data of common nature will be collected and processed automatically and/or manually in compliance with the provisions of Article 11 and 31 of the Italian Personal Data Protection Code and by adopting the related minimum safety measures, securing strictly monitored access; the collecting and processing of sensitive data will be carried out in compliance with the provisions of Art 11 and 31 of the Italian Personal Data Protection Code and by adopting the related minimum safety measures. Your personal data you have provided, with the exception of sensitive data, may be transferred overseas pursuant to the terms, conditions and limits specified by Title VII of Part I of Legislative Decree n. 196/2003.
Your data may be communicated, in compliance with the rules indicated above, to public or private subjects to which may be necessary in order to fulfill obligations set forth by laws, regulations or EU laws. Sensitive data may be communicated to public bodies and health authorities (such as Aziende USL) or public hospitals, public safety authorities, Police offices, courts, magistrates and the like) and to private subjects (such as private hospitals and clinics, security supervisors, insurance companies) only for purposes relating to health and safety, emergency situations or to fulfill obligations set forth by laws, regulations and EU laws. We may disclose your information to third parties as follows:
- Parents and Guardians: In some cases, we may share your information with a parent or guardian, if necessary, in the event of an emergency.
- Service Providers: We may use third parties to support our operations at the University and the Study Abroad sites. In such cases, we may share your information with such third parties.
- Travel Providers: We may share your information with travel providers, including travel agents and airlines to secure the necessary travel arrangements. This may involve the communication of sensitive medical information or food allergies you provide to us to ensure that a preventable emergency does not arise during your travel to your destination.
- Italian Consulate: To secure the necessary documentation for your travel to the U. New Haven campus, currently in Prato, Italy, we will share any data we collect, including but not limited to, Visa applications, financial documents, passport information, insurance information, and student status with the Consolato Generale d’Italia, located at 690 Park Avenue, New York, NY 10065.
- Required by Law: We may share your information with third parties to the extent we are required to do so by law, court order, or subpoena.
- Emergency Circumstances: We may share your information with third parties if, in our sole judgment, such disclosure is necessary to protect the health, safety, or property of any person.
- Consent: We may seek your consent to disclose your information to third parties if we are required to do so. Where we have sought, and you have provided, your express consent for a particular purpose, please note you have the right to withdraw your consent at any time by notifying us at the contact information above.
- De-Identified and Aggregate Information: We may use and disclose information about our program participants in de-identified or aggregate form without limitation.
- International Transfers: We may transfer your information to third parties located in other countries. These transfers are made subject to appropriate technical safeguards and contractual provisions to ensure the security of your information.
DATA CONTROLLER AND DATA MANAGER
The Data Controller, under the law and, with particular reference to the safety obligations related to the automatic processing of your data, is the University of New Haven.
All data will be processed by U. New Haven in its capacity as Data Controller with the supervision of William Norton, Data Manager, available in compliance with art. 7 of Legislative Decree 196/2003, whom you can reach at the following email: firstname.lastname@example.org
The period for which hard copies of your personal data will be stored will be from now up until five (5) calendar years after your graduation from U. New Haven. Due to software limitations, data provided or stored electronically in your Study Abroad application will be stored indefinitely.
Various jurisdictions grant individuals rights regarding their data, including:
- The right to request access to your information held by the University.
- The right to obtain confirmation of the existence or not, of your personal data, even if not yet recorded, and their communication in intelligible form, including, but not limited to:
- The origin of the personal data.
- The ends and methods of its processing
- The logics applied in the event of processing being carried out with the aid of electronic equipment.
- The identification data of the controller, of those responsible and the appointed representative as per art. 5 paragraph 2, of the organizations or categories to whom personal data can be communication or who are likely to get to know them in their capacity of designated representative in any area of the country, of officers and appointees.
- The right to have inaccurate or incomplete personal data rectified, including but not limited to:
- The update of incorrect data
- The integration of the data
- The cancellation of the data, transformation in anonymous form, or the blockage of any data processed unlawfully, including those whose storage is not necessary in relation to the aims for which the data was collected or later processed.
- A statement that the operations indicated above, including their content, have been made known to those whom the data has been communicated or released, except in the case of this being found to be impossible, or requiring the use of means which are clearly disproportionate to the protected right.
- The right to erasure of your information, provided there is no legitimate reason for the University to continue to process or retain it.
- The right to completely or partially restrict the processing of your information in specific situations:
- For legitimate reasons, the processing of personal data regarding the individual, even if relevant, to the nature of their collection.
- The processing of personal data regarding the individual for the person of sending public material, direct sales, or for carrying out market research or commercial communications.
- The right to request provision of some elements of your information.
- The right to object to automated decision-making and profiling, where applicable.
While we encourage you to bring your concerns to us in the first instance, in certain jurisdictions, you may also have the right to submit a complaint to the jurisdiction’s supervisory authority for data protection matters.
You can read Regulation (EU) 2016/679 at:
UPDATES TO THIS NOTICE
Changes may be made to this Privacy Notice and personal information may be used for new purposes. When significant changes are made to our privacy practices, they will be disclosed here.