Hebrew University Privacy Policy

Last Updated: January 2^nd, 2020

About this Privacy Policy

This Privacy Policy was developed to assist you in understanding how Hebrew University and its units and affiliates (collectively, “we,” “us,” or “HU”) collect, use and safeguard the information we obtain and hold about you. HU students and alumni should also review our FERPA Student Right to Privacy Policy at http://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html and https://studentprivacy.ed.gov/?src=fpco which outlines student rights concerning education records held by HU.

By using our websites, learning management system, and other online properties (our” Sites”), you expressly consent to our use of your information collected through those sites for the purposes described in this Privacy Policy. You acknowledge that communications to, from, and through our Sites are not confidential. You agree that by submitting communications through our Sites, no confidential, fiduciary, contractually-implied or other relationship is created between you and HU other than as specifically set out in and under this Privacy Policy or other terms posted to those sites.

Children’s Online Privacy Protection

Our Sites are not intended for use by any individuals under 13 years of age. If you are a minor between the ages of 13 and 18, you may use our Sites only in conjunction with your parent, legal guardian, or other responsible adults. Any other use by minors is strictly prohibited.

What We Collect and Why

As an educational institution and employer, HU maintains records for our past, present, and prospective students and employees. HU also has business relationships with the community, educational, and workplace partners and, as such, maintains records for the individuals we work with through those partnerships. Information, including personal information, is collected by HU in a variety of ways at different points in an individual’s interaction with the institution for many different purposes. The following sections describe in more detail the types of information we hold and how we may collect and use that information.

Types of Information We Hold

The information collected, stored and processed by HU may include:

• Your contact information (e.g., name, personal or work mailing address, email address, phone number, employer and job title) and other types of personal information, including sensitive personal information, used to process requests and applications relating to admission, financial Services, employment, partnerships, study abroad or other HU programs and services (e.g., birth date, age, gender, sex, state or federal ID numbers, race, marital status, military status, parental and dependent information, educational history, employment history, professional certifications, passport and visa information, medical history information, insurance, tax, and income information)
• Records of your communications with HU (e.g., your IP address, login/logout dates, open email dates, email clicks, web traffic, contact preferences, student contact history, chat communications and information from feedback surveys)
• Technical information about your visit to or use of our Sites, (e.g., site analytics, browser information, referring URL’s, pages accessed, time and date accessed, operating system used, Google Analytics ID, other tracking data, session count, user count, and device type)
• Marketing information such as prospective student and partner leads, current interests and preferences (contact preferences, settings, etc.), your likeness and photo
• Records about your time at HU and your continuing affiliations with HU (e.g., records of student work submitted through our learning management system and other academic records, financial aid records, athletic eligibility records, housing information, records of participation in academic organizations, disciplinary records, employment records, and alumni and donor records)

The above list is not exhaustive, but we hope it will help you better understand the general types of information we collect. The exact information we collect, store, and process about you will depend on your relationship with us. Not all types of information are collected on all individuals.

How We Collect Your Information

We generally collect information in two ways, (1) when you voluntarily provide it to us, and (2) automatically when you visit or use our Sites.

Voluntary Collection

You voluntarily provide information to us when you choose to use the webforms, electronic applications, chat functions and other online communication tools available through our Sites, and when you choose to disclose information through your interactions with our student advisors, admission and financial aid personnel and other authorized HU representatives conducting university business.

Automatic Collection through Cookies and Other Technologies

We automatically collect information through the use of cookies, web beacons, and other technical tools that are part of our Sites. Cookies are small data files that are transferred to your computer or mobile device that allow us to recognize you and to pass information about your visit to different portions of our Sites. Cookies may be set by us (first-party cookies) or may originate from unaffiliated third-party websites through “plug-ins” that we enable (third-party cookies). Cookies may include:

• Strictly necessary cookies required for the operation of our Sites.
• Performance and functionality cookies that enhance the performance and functionality of our Sites and services enable us to remember you and personalize content.
• Analytics and advertising cookies that allow us to understand the effectiveness of our marketing and make our advertising more relevant to you and your interests.

We do not control third-party cookies. To understand how third-parties use cookies, you should review their respective privacy policies. Google Analytics is one of the tools we use on our websites. You can find more information about how Google Analytics collects and processes data at www.google.com/policies/privacy/partners/.

Most internet browsers accept cookies by default. You can control the use of some cookies and similar technologies by activating certain settings on your browser. You should visit the help and support area on your internet browser for instructions on how to block or delete cookies. Please note, however, that disabling cookies may affect your ability to access the full functionality of our Sites.

When you interact with any HU page or account on a social media platform, such as Facebook, Twitter, Instagram, LinkedIn, Tumblr, YouTube, or Pinterest, when you use a third-party platform’s social login to our properties, or when you use web forms on those platforms, we may collect the public information that you make available on those platforms following those platforms’ respective policies. Also, we sometimes collect personal information about you from third party sources such as our service providers and partners that have obtained your personal information through their data collection practices (for example, if you sign up directly with that third party for their service). Some third parties that provide information to us may also share your information with other parties. Please be sure to read these parties’ respective privacy policies to understand their data collection practices, including how they may use the information they collect from you and your options to manage the data that is shared by them.

Aggregate Information

To the extent permitted by applicable law, we may use, process, transfer and store information about individuals in an anonymous (or pseudonymous) and aggregated manner. We may combine personal information with other information collected online and offline, including information from third-party sources. We may also use information in other ways with consent. By using our Sites and services, you agree that we are licensed to collect, use, share and store anonymized (or pseudonymized) aggregated data collected through our Sites and Services for benchmarking, analytics, research, reporting, machine learning, and other business purposes.

Automated Decisions

To the extent permitted by applicable law, we may collect data in an automated manner and make automated decisions, including machine learning algorithms, about individual users of HU educational programs, our Sites and services to provide or optimize our offerings, for security and analytics purposes and other lawful purposes.

How We Use the Information We Collect

We will use your personal information to contact you regarding information that you have requested, in conjunction with aggregated information and cookies, and for improving our education and other services, our marketing, and our Sites. We may store your information to communicate with you about the educational programs and services offered by our university and send you updates if and when they become available. We also use the information we collect for purposes of administering our educational programs and conducting other university business, to provide services to our students, partners, and employees, and to make other products and services available to individuals within the HU community. Occasionally, we may also use the information we collect to notify you about important changes to our Sites or services, new services, educational programs, and related offers we think you will find valuable.

Some more specific examples of how we may use your information include:

• Providing services to our students such as evaluating applications for admission, financial services or student-employment, completing course registrations, enrolling you in academic groups or other programs, collecting tuition payments, facilitating study abroad, providing parking passes and permits, facilitating your requests for IT support, to carry out your requests to affiliate with our community or workplace partners and to deliver our online training and educational programs.
• We are providing services to our alumni, such as mailing alumni news, information, invitations, and surveys, sending donation and engagement solicitations, reviewing web traffic, and click-throughs on email to provide engagement statistics.
• We are providing you with service or safety alerts or announcements.
• Evaluating applications for employment and providing employee onboarding and other employment-related services such as payroll services, benefits enrollment, technical support, and employee training.
• Marketing uses such as targeted advertising via social media and other digital channels, audience classification and creation, sharing social content, tracking leads for analytics and communications purposes, conducting market research, surveys, and similar inquiries to help us understand trends and needs of our users, and offering newsletters, articles, event invitations and other information that we believe may interest you.
• We are preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or unauthorized access to or use of personal information, our website or data systems, investigating or resolving inquiries initiated by current or prospective students, to meet our legal obligations, to serve the public interest or public health, and for other lawful purposes.

Legitimate Interests for Processing Personal Information

Most of HU’s collection and processing of personal information will fall under one or more of the following categories, depending on your relationship (past and present) with HU:

• Processing is necessary for the legitimate interests pursued by HU, such as providing, improving and customizing our educational offerings, administering our operations, maintaining relationships with and fostering connections among HU community members, exploring ways to develop and grow our operations, enhancing protection against fraud and security risks, offering attendance at events and other engagement opportunities, understanding how our online platforms are used, etc.
• Processing is necessary for the performance of a contract to which you are a party or to carry out your requests of us.
• Processing is necessary for compliance with a legal obligation to which HU is subject.
• You have given your consent to the processing of your personal information for one or more specific purposes.

There are some instances where the collection and processing of personal information will be under other lawful bases.

Data Retention

At HU, we believe in maintaining a lifelong relationship with our HU community members. As such, unless otherwise required by applicable law, we typically will maintain a record for you.

Sharing Information with Third Parties

HU does not sell personal information to outside parties for their commercial use. However, we may share information with third-parties, including our service providers, partners, and affiliates, as follows:

Service Providers

We sometimes use third-party service providers to perform services on our behalf. We may share your personal information with such third-party service providers to allow them to perform the duties for which they have been retained, subject to confidentiality, and use obligations consistent with this Privacy Policy. These service providers are used for things like:

• Payment and donation processing
• Marketing and analytics
• Processing employment applications
• Processing admission applications
• Alumni outreach and engagement
• Event registration and coordination
• Course registration and coordination
• Course evaluations and assessments
• Research insights and analytics
• Human Resources administration

Affiliates

We may share your personal information with affiliated legal entities and among HU units and departments for purposes and uses that are consistent with this Privacy Policy.

Partners

We may share your personal information with our workplace, community, and educational partners to administer programs and services, such as:

• Cross-registration for courses with other institutions
• Study abroad at foreign universities
• Online education offerings through online platforms
• Partner sponsored training and events
• Joint research arrangements with other universities or entities
• Events with clubs and special interest groups
• Partner sponsored tuition reimbursement or discount programs

Directory Information

We also may share student directory information as permitted by applicable law. More information about student rights concerning directory information can be found in our FERPA Student Right to Privacy Policy at http://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html.

How We Protect Your Personal Information

To protect personal information from unauthorized access, use, and disclosure, HU maintains an information security program and employs reasonable and appropriate physical, administrative, and technical safeguards. HU performs periodic risk assessments of its information security program and prioritizes remediation of identified security vulnerabilities. However, we cannot guarantee that unauthorized access, use, or loss will never occur.

Legally Compelled Disclosure

We may release personal information about you that we possess (e.g., to legal or government regulatory authorities or third parties) when we believe release is appropriate to comply with, the law; to enforce or apply our Privacy Policy and other agreements; or to protect the rights, property or safety of us, users of our Sites or others.

Links to Other Sites

This Privacy Policy does not apply to third-party applications or software that integrates with our services through our Sites, or any other third-party products, services, or websites. Please be aware that once you leave our Sites and enter another website, our Privacy Policy is no longer in effect. We are not responsible for the privacy practices employed by these sites, nor the information or content contained therein. Please read over the rules and policies of these sites before proceeding.

User-Generated Content

Some of our Sites and services may enable users to submit their content for courses, assignments, contests, blogs, videos, chat functions, and other functions. Unless otherwise indicated, please remember that any information you submit or post as user-generated content to the services becomes public information. Please do not disclose your personal, financial, or other information in such submissions or posts. We cannot prevent others from using such information in a manner that may violate this Privacy Policy, the law, or your privacy and safety. We are not responsible for the results of such postings.

Accessing our Sites from Outside the U.S.

If you are accessing our Sites from outside of the United States (“U.S.”), including from the European Economic Area and Switzerland (collectively the “EEA/CH”) or other foreign countries, and you use our Sites or provide us with personal information via our Sites or through your communications with HU representatives, your information will be handled following this Privacy Policy. By using our Sites or giving us your personal information, you acknowledge that your information will be transferred to and processed on servers located in the U.S. and potentially other jurisdictions that may not have the same level of data protection as your jurisdiction. However, you agree and consent to our collection, transfer, and processing of your information following this Privacy Policy. HU may transfer your information within other HU units and affiliates and the third parties as outlined above in Sharing Information with Third Parties. Besides, we may transfer your information outside your jurisdiction if the transfer is necessary to establish, exercise, or defend legal claims, as well as if the transfer is necessary to protect your vital interests.

Additional Rights under the General Data Protection Regulation (“GDPR”)

If you interact with our Sites and services while physically located in the EEA/CH, you may have one or more of the following additional rights under the GDPR:

• To request a copy of the “personal data” (as that term is defined under GDPR), we have collected about you by contacting us
• To request that we rectify or delete any of your data, subject to the exceptions listed in the GDPR
• To object to the processing of your data for direct marketing purposes
• To restrict or limit how we use your data
• To obtain a copy of your data in an easily accessible format
• To complain about a supervisory authority

You may also have the right to withdraw your consent to our processing of your data if our processing is solely based on your consent. You can do this by discontinuing the use of our services, including closing all your online accounts with us. If you withdraw your consent to the use or sharing of your data for the purposes outlined in this Privacy Policy, you may not have access to all (or any) of our services, and we might not be able to provide you all (or any) of our services. Please note that, in certain cases, we may continue to process your data after you have withdrawn consent and requested that we delete your data as required under applicable law or as needed to resolve disputes or protect our legal rights or if we have a legal basis to do so.

Privacy Policy Updates

Because technology and the rules regarding data management and privacy continue to change, we may update this Privacy Policy from time to time. Updates, including the date of revision, will be posted to this page.

Opt-out and Questions

If you no longer wish to receive marketing related email communications from HU, please send an email to marketing@jewishus.org