Vanderbilt University’s Online Privacy Notice
Scope and Application:
Vanderbilt University (“Vanderbilt”) is committed to protecting individuals’ privacy rights while also balancing its legal, policy, and administrative duties in the management of Vanderbilt data. This Privacy Notice applies to the information Vanderbilt collects when you visit any Vanderbilt.edu website.
Personal Information Vanderbilt Collects and Processes:
All websites collect information from users. Websites can collect information passively or actively. Vanderbilt gathers Aggregate Information passively through cookies, third-party analytics, and web servers. Vanderbilt collects Personal Information actively when users provide the information to Vanderbilt via forms, surveys, or transactions.
“Aggregate Information” is non-personal information collected from a user visiting a website. Vanderbilt websites employ cookies, third-party tracking (Google Analytics), and server logs to collect aggregate information. Examples of aggregate information collected from Vanderbilt’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
Many Vanderbilt 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 Vanderbilt. All website server logs collect basic aggregate information from site visitors to monitor site traffic and efficient performance.
“Personal Information” is any information that Vanderbilt can reasonably use to identify its website visitors. Vanderbilt 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 Vanderbilt may include:
- Email address
- Phone number
- Mailing address
- Educational history
- Relevant application materials
- Relevant financial aid documents
- Payment information
Vanderbilt has a legitimate business interest in collecting data that supports Vanderbilt’s missions in education, research, and public service, and promotes engagement with and giving to the university. Vanderbilt only collects and processes personal information in furtherance of Vanderbilt’s legitimate interests, with consent, and/or to fulfill any contractual obligations.
Vanderbilt 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 Vanderbilt’s legitimate interests;
- With trusted third parties who have contractually agreed to keep personal information confidential.
Vanderbilt does not sell personal information to third parties.
Some Vanderbilt 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. Vanderbilt 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 Vanderbilt.
How to Opt Out:
Users can opt out of the collection and use of information gathered for target advertisements by using the Digital Advertising Alliance WebChoices Tool, which scans browsers for companies that are utilizing customized advertisements.
Users can opt out of Google’s ad personalization by visiting Google’s Ad Settings.
Users can also opt-out of “internet-based advertising” by visiting the Network Advertising Initiative opt out website.
Retention of Information:
Vanderbilt 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 here for more information.
European Union’s General Data Protection Regulations:
In accordance with the GDPR, Vanderbilt may serve as the “controller” or “processor” for the purposes of personal data collection. Vanderbilt is committed to complying with the principles of the GDPR by protecting the privacy rights of individuals.
Policy Updates and Changes:
Vanderbilt 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 Vanderbilt website after the effective date will constitute acceptance of the change in the Notice.
Last updated: September 30, 2020