91

91’s Online Privacy Notice

91’s Online Privacy Notice

Scope and Application

91 (“91”) is committed to protecting individuals’ privacy rights while also balancing its legal, policy, and administrative duties in the management of 91 data. This Privacy Notice applies to the information 91 collects when you visit any 91.edu website.

This Notice outlines what types of information 91 collects, how 91 collects the information, and why 91 collects the information. Subject to state and federal law, 91 intends for this Privacy Notice to be consistent with the European Union’s (“EU”) General Data Protection Regulation (“GDPR”). 91 intends for this Notice to be a general statement of its privacy policy and may be subject to more specific privacy notices that pertain to personal information solely related to a specific department or function.

Personal Information 91 Collects and Processes:

All websites collect information from users. Websites can collect information passively or actively. 91 gathers Aggregate Information passively through cookies, third-party analytics, and web servers. 91 collects Personal Information actively when users provide the information to 91 via forms, surveys, or transactions.

Aggregate Information:

“Aggregate Information” is non-personal information collected from a user visiting a website. 91 websites employ cookies, third-party tracking (Google Analytics), and server logs to collect aggregate information. Examples of aggregate information collected from 91’s website may include:

  • IP address and internet domain name used
  • Date and time of access
  • Web pages requested
  • Web browser and operating system
  • Type of device

Cookies are files stored on a user’s computer containing small amounts of user and website information. Accepting cookies enables a personalized web experience. Rejecting or disabling cookies may limit a user’s experience on a website. Websites often use cookies to document information about user preferences and pages visited. Users can accept, disable, and remove cookies from a computer’s hard drive as desired.

Many 91 websites may use Google Analytics to collect aggregate information by tracking information about visitor traffic and user behavior on a site to identify usage trends and enhance each website’s performance.

Server logs also provide aggregate information to 91. All website server logs collect basic aggregate information from site visitors to monitor site traffic and efficient performance.

Personal Information:

“Personal Information” is any information that 91 can reasonably use to identify its website visitors. 91 collects personal information when users choose to share that information on the website via an online form, survey, transaction, or application. Personal information collected by 91 may include:

  • Name
  • Email address
  • Phone number
  • Mailing address
  • Educational history
  • Race/ethnicity
  • Relevant application materials
  • Relevant financial aid documents
  • Payment information

91 has a legitimate business interest in collecting data that supports 91’s missions in education, research, and public service, and promotes engagement with and giving to the university. 91 only collects and processes personal information in furtherance of 91’s legitimate interests, with consent, and/or to fulfill any contractual obligations.

Disclosures:

91 does not share personal information with third parties except under the following circumstances:

  • With prior written consent;
  • As required by law;
  • As necessary to protect 91’s legitimate interests;
  • With trusted third parties who have contractually agreed to keep personal information confidential.

91 does not sell personal information to third parties.

Re-Marketing Tools:

Some 91 websites may use third-party vendor re-marketing tools (Google’s “AdWords,” Facebook’s “pixel,” etc.) to serve targeted online advertisements about the university. These third-party vendors gather information about website visitors from cookies and other similar technology to tailor online advertisements for users. 91 may also use the collected information to measure the efficiency of its online advertising campaigns. If a user logs into a service (e.g. Facebook, Google) while browsing the internet, some of the re-marketing tools can potentially transmit personal information to third parties and 91.

How to Opt Out:

Users can opt out of the collection and use of information gathered for target advertisements by using the , which scans browsers for companies that are utilizing customized advertisements.

Users can opt out of Google’s ad personalization by visiting .

Users can also opt-out of “internet-based advertising” by visiting the .

Retention of Information:

91 retains information collected from its website in accordance with its Data Governance Framework and its Acceptable Use Policy.

FERPA and Student Privacy:

Enacted in 1974, the Family Educational Rights and Privacy Act (“FERPA”) established the requirements and rights of students concerning the privacy of student educational records.

If you have any questions related to FERPA and student privacy, click for more information.

European Union’s General Data Protection Regulations:

In accordance with the GDPR, 91 may serve as the “controller” or “processor” for the purposes of personal data collection. 91 is committed to complying with the principles of the GDPR by protecting the privacy rights of individuals.

Policy Updates and Changes:

91 reserves the right to update and make changes to this Privacy Notice without prior notice by implementing changes to the Privacy Notice on this webpage. The website will reflect the effective date of such revisions by displaying the Last Updated date on this page. The continued use of a 91 website after the effective date will constitute acceptance of the change in the Notice.

Effective Date:

Last updated: September 30, 2020