International Privacy Notice

1. DEFINITIONS USED IN THIS NOTICE

• Personal data: Any information relating to an identified or identifiable individual. Some privacy laws call it personal information.
• Process/processing: Any operation or set of operations performed on personal data, for example collecting, organizing, consulting, storing, and sharing.
• Data subject: The individual whom the data relates to. Some privacy laws use a different term, for example individual or natural person.
• GDPR: The European Union's General Data Protection Regulation.
• PIPL: China's Personal Information Protection Law.
• Controller: The entity that determines the "purposes and means" of the processing, in effect that is in charge of it. Some privacy laws use a different term for the same concept, for example PIPL uses "personal information processor".
• Processor: An entity that processes personal data on behalf of a controller.

2. SCOPE OF THIS NOTICE

This Privacy Notice ("Notice") describes how Bucknell University ("Bucknell", “we", "us", "our") processes personal data collected from or about data subjects located outside the United States. This Notice meets the requirements of applicable international privacy laws (notably the GDPR and China’s PIPL) for personal data controllers to provide certain information to data subjects concerning the processing of their data.

In this Notice, "you" refers to anyone located outside of the United States about whom we process personal data. You will usually be a prospective student, an applicant to study at Bucknell, or a parent of an applicant or student. You may also be a Bucknell alumnus, donor, or an applicant for a faculty or staff position at Bucknell.

IMPORTANT NOTE: This Notice does not cover the processing of your personal data when you are located in the United States, regardless of your citizenship. For example, if you are an international student at Bucknell, this Notice does not apply to the processing of personal data collected during your stay on campus.

This Notice applies to personal data collected via our website (www.bucknell.edu); mobile app ("Bucknell University"); their associated sites, platforms, and media (for example, the myBucknell Dashboard portal); and during any offline contact with you.

Our websites and apps may contain links to external websites. This Notice does not cover those sites.

Bucknell is the controller in relation to the processing (see Section 1, DEFINITIONS).

3. CHANGES TO THIS NOTICE

We may occasionally update this Notice and will communicate material changes to you through an appropriate channel (for example, via notices on our website). The Notice was last updated on June 11, 2024 .

4. PERSONAL DATA WE COLLECT

Mostly, we collect personal data directly from you. In other words, you submit it to us and you know what it consists of. You may provide this information online (for example, using our Request for Information form or the myBucknell Dashboard portal) or in other ways (for example, while attending a college fair or during a Bucknell visit to your high school). This data may include:

• Names and contact details (for example, email, street address, and phone numbers)
• Date of birth, sex, pronouns, race and/or ethnicity, and citizenship
• High school information and your academic interests
• Self-description and interests information submitted to build your Bucknell Custom Viewbook
• Information submitted in your Coalition or Common Application
• Information that you request others to provide to us (for example, high school transcripts, reference letters, and English proficiency test scores)
• Parental information required for a student's application, for example household income, financial account statements, and details of parental education and employment
• Official identification documents and details, for example passport information
• As a donor to Bucknell, financial and other asset information provided in the context of your gift
• As an alumnus of Bucknell, you may provide us with information about your children in the context of our legacy programs

Note that the personal data you submit to us may contain "special categories of personal data", also known as "sensitive personal information". This could include, for example, your ethnicity, gender identity, financial data, or government identification numbers. We never require you to provide sensitive data that is not necessary for us to accomplish a shared purpose with you (for example, to process your application to study at Bucknell). When you provide sensitive data to us for such a purpose, you are giving us your explicit consent to process it for that purpose. When required by local law, we will obtain your additional consent to process your sensitive data for any additional purposes.

Bucknell does not request or purposely process, without parental knowledge, the personal data of children younger than a typical U.S. ninth-grader, that is, under 14 years of age.

Your obligation to provide personal data: You may choose not to provide us with personal data that we request. However, if that personal data is essential to a particular purpose (for example, your application or enrollment), Bucknell will be unable to proceed with that purpose without it.

In addition to collecting personal data directly from you, we sometimes collect data about you from other individuals and organizations:

• We receive information about you as a prospective student from organizations that connect students to colleges, for example College Board. The information may include name and contact details, academic interests, data of birth, and sex.
• As a parent, your student may provide us with information about you as part of their application and enrollment processes, for example your places of residence and employment.
• As an applicant for a position at Bucknell, we may carry out background checks on you, including those required by law. You will be made aware that these checks are being performed.
• We use publicly available data and research services to follow our alumni and to identify potential gift-givers. Such data may include social media posts, and securities and real estate ownership.
• We observe your activity on our website using cookies and other standard online technologies. Cookies enable us to recognize your device. We use them to collect information about your device and how you use our site; for example, which pages you visit and how long you stay on them. Cookies also facilitate, for example, logging into and navigating parts of our website.

5. PURPOSES OF USE

Bucknell uses your personal data for the following purposes:

• To respond to your requests or inquiries, for example if you submit our Request for Information form.
• To administer your, or your student's, application to study at Bucknell and, if admitted, to enroll them and manage their student life. This processing includes administering student accounts with Bucknell, including financial assistance.
• To process your application for a staff or faculty position at Bucknell.
• To maintain contact with you as a parent, alumnus, or donor.
• To identify individuals who may be potential donors to Bucknell.
• To understand how our website is being used, and by whom.
• To send you engagement or marketing communications, which may be based on interests that you have shared or made known to us (see Section 10 for information about opting out of such messages).

Bucknell does not use "automated individual decision-making" tools. In other words, we do not make decisions significantly affecting you (for example, concerning your application) based solely on automated means or algorithms.

Bucknell does not sell your personal data.

Lawfulness of processing: GDPR requires that we provide EU individuals with our legal bases for processing their personal data. A similar requirement applies in some other jurisdictions, for example China and the United Kingdom. Our legal basis depends on the purpose of processing:

6. WHEN WE DISCLOSE YOUR PERSONAL DATA

Whom we disclose your personal data to depends on the types of data and the purposes we use them for. Your personal data may be disclosed to the following categories of recipients:

• Bucknell faculty, staff, and contractors: Access to your data is provided only to personnel who have roles that require it (a legitimate "need to know"). The personnel are bound by contractual terms that cover their obligation to keep personal data confidential and secure.
• Service providers ("processors"): We use service providers to perform certain tasks for us, for example, to host our student information system, to perform website analytics, or to operate our website careers pages. Service providers process your data on our behalf and according to our instructions. They are contractually bound to protect your data and are prohibited from using it for their own purposes.
• Federal and state departments and agencies: We may share your data with U.S. federal and state departments and agencies, for example with the U.S. Department of Education and the Pennsylvania Department of Education, to comply with their legal or regulatory requirements.

We will also disclose your personal data in the following exceptional circumstances:

• Legal necessity: We will disclose your data to government agencies, law enforcement, courts, and other authorities and parties if required to by applicable law.
• Individual's vital interests: If we reasonably believe based on information we collect that the safety or vital interests of an individual are at risk, we will disclose personal data to relevant parties as necessary to assist the individual.

7. INFORMATION SECURITY

We employ technical, physical, and administrative security measures appropriate to the categories of personal data we process, and require the same from any service providers who process personal data on our behalf. However, no matter how carefully we safeguard your data, it is unfortunately not possible to guarantee that it will never be accidentally or illegally breached.

8. DATA RETENTION

Bucknell will retain your personal data as long as necessary to fulfill the purposes for which it was collected, and to satisfy our legal, accounting, and reporting obligations. Personal data is deleted in accordance with our record and data retention policies.

Section 10 of this Notice below describes your right to request deletion of your data outside of our normal retention schedule.

9. INTERNATIONAL TRANSFER

Your personal data is processed and stored by Bucknell on our systems in the United States. U.S. privacy laws may be different from those of your own country. If you reside in the EU, European Economic Area, or U.K., note that the EU and U.K. authorities do not consider the U.S. to offer an adequate level of personal data protection. However, as set out in this Notice, Bucknell strives to protect your data and your privacy rights regardless of any international transfer.

10. YOUR PRIVACY RIGHTS

International laws give you various rights, subject to certain conditions and limitations, over your personal data. These may include the right to:

• Access personal data held about you
• Correct inaccurate or out-of-date personal data
• Request deletion of your personal data
• Restrict processing of your personal data
• Receive your personal data in a readily useable format (data portability)
• Object to processing for which the legal basis is our legitimate interests

Requests to exercise privacy rights should be addressed to us using the contact information in Section 11 below.

If you believe that we have infringed your privacy rights, please contact us so that we can try to resolve the issue. However, if you are an EU/EEA/U.K. resident, you have the right to lodge a complaint with your EU/EEA local supervisory authority or, in the U.K., with the ICO.

Marketing:

You can opt out of our engagement and marketing communications at any time using, for example, the "unsubscribe" in an email message.

11. CONTACT US

Privacy Officer
Bucknell University
One Dent Drive
Lewisburg , PA 17837
USA

privacy@bucknell.edu