1. Introduction
1.1 – Overview
The UVA Alumni Association (the “Association”) is a nonprofit association serving the University of Virginia and its alumni. Our headquarters is located at 211 Emmet Street South, Charlottesville, VA 22903. The UVA Alumni Association is strongly committed to maintaining the privacy and security of Personal Information it collects, stores, and processes. Please note that we are a co-controller of certain Personal Information with the University of Virginia.
This Privacy Policy:
- Describes how we collect, store, and protect individually identifiable information (“Personal Information”)
- Describes how we use, process, transfer, and share Personal Information
- Describes your Personal Information privacy rights
This Privacy Policy applies to Personal Information that we collect through any means, including but not limited to the UVA Alumni Association website, digital advertising, events and activities, employment processes, and direct interactions with our staff.
1.2 – Summary of Key Points
By providing Personal Information to us, you consent to our processing and transfer of your Personal Information.
We collect Personal Information when you provide information through our websites, when you request UVA Alumni Association information, when you register for an event or donate online, or through other communications with UVA Alumni Association systems and staff. We use Personal Information to provide our products and services to you.
We transfer Personal Information to the United States and jurisdictions that may be outside of your home country as necessary for the purposes described in this Privacy Policy, including to jurisdictions that may not provide the same level of data protection as your home country.
We use cookies and other technologies to track the use of our websites and for advertising purposes.
We share Personal Information with the University of Virginia and other partners which provide products and services that may be of interest to you. We also share Personal Information that you post on our social media and networking sites.
You may email us at [email protected] to request access to your Personal Information on file. Some of this information is also visible in your Wahoo Connect profile, if you have a Wahoo Connect account.
When we process your Personal Information based on your consent, you have the right to withdraw your consent. We also provide the rights to access, rectify, and limit your Personal Information, and to restrict or object to our processing of your Personal Information. These rights are limited under the applicable local data privacy law.
We maintain reasonable and appropriate technical, physical, and administrative measures to protect the security of your Personal Information. Access to Personal Information is limited only to those employees, contractors, or agents of UVA Alumni Association or UVA-affiliated organizations who have authorization to access such Personal Information for limited and defined purposes.
Our websites may have links to other sites that we do not control. Their privacy policies may differ from ours. We encourage you to read the privacy statement of any website you may visit.
If we make any material changes to our privacy practices, we will post a prominent notice on our websites notifying users of the change.
1.3 – Privacy Policy Statement
The UVA Alumni Association is committed to safeguarding all Personal Information entrusted to the Association. This notice describes the Association’s general Privacy Policy as it relates to the collection, protection, and disclosure of such information.
1.4 – Consent
By using our websites or otherwise providing us with Personal Information, you consent to our processing and transfer of your Personal Information as we describe here.
Providing us your information constitutes your consent to the collection, use, transfer, and sharing of that information for the purposes described in this Privacy Policy. You may withdraw your consent at any time as described in section “5.1 – Right to Withdraw Your Consent.”
1.5 – Updates to This Privacy Policy
Except where limited by applicable law, we reserve the right to update this Privacy Policy to reflect changes in our information practices by prominently posting notice of the update on our websites, and, if required, obtaining your consent. Updates will become effective immediately after posting and will apply to all information collected about you, and where required, upon your consent. You agree that you will review this Privacy Policy periodically. If we make any updates, we will change the “Last Updated” date above. You are free to decide whether to accept a modified version of this Privacy Policy, but accepting this Privacy Policy, as modified, is required for you to continue using our websites.
If we make any changes to this Privacy Policy that materially and adversely impacts previously collected information about you, we will obtain your consent for processing information previously collected about you.
2.How We Collect Information
2.1 – Collection and Protection of Information
Information collected, regardless of the method of collection or format, may be used to carry out the authorized business of the Association as disclosed in this Privacy Policy.
We maintain reasonable and appropriate technical, physical, and administrative measures to protect the security of your Personal Information. Personal information we collect may be stored in a database we co-control with the University of Virginia. Access to Personal Information is limited only to those employees, contractors, or agents of UVA Alumni Association or UVA-affiliated organizations who have authorization to access such Personal Information for limited and defined purposes.
2.2 – Information We Collect
We collect Personal Information to help us better understand your needs, to provide you with personalized and efficient service, and for other purposes described in this Privacy Policy. We generally obtain Personal Information directly from you, though we may engage third-party service providers and business partners to acquire information or utilize publicly available sources. We also may obtain Personal Information automatically, through the use of cookies and other technologies, and in some instances from third parties, including the University of Virginia.
Listed below are the classes of Personal Information that we collect. Please note, however, we do not collect all of this Personal Information from everyone.
Automatic/Required
- Browser/client information: device type, browser, operating system, and IP address
- Request information including the page or service accessed and source/referral details
- In some cases, internal identifiers (i.e., donor system IDs) may be passed automatically from an email to a page/form
- Cookies, as described below
Form Data
- Biographic data – name, birthday/age, race/ethnicity, gender, nationality/residency status, military/veteran status, religious affiliation, spouse
- Contact data – email address, mailing address, phone number
- Academic data – school, class year, majors/minors, GPA, test scores, UVA computing ID, first-generation college status, student ID, activities
- Financial aid data – types and amounts of financial aid, income, combined assets value
- Disability/accessibility data – mobility, dietary, and other accommodation needs
- Family data – names and birth dates of spouses/partners, children, and other familial relationships
- Alumni data – event attendance, volunteer interests, relationships, committee/board participation, awards and honors, and other organizational affiliations
- Restrictions, requests, and accommodation data – dietary restrictions/requests, accommodations requested, etc.
- Donor data – gift transactions, cumulative giving history, wealth assessment information, and indicators of interest in giving to particular areas
- Financial data – bank account and payment card details
- Transaction data – details about payments to and from you, order history, and other details about products and services you purchased from us
- Employment history or status
- Consent/agreement
- Photographs of you, if you share them (via Class Notes, etc.) or photographs taken at UVA Alumni Association events
- Miscellaneous personal details (e.g., Class Notes or obituaries)
2.3 – Information You Provide
You may provide Personal Information to UVA Alumni Association in a number of ways, including: (1) through your use of our websites, such as registering for an account and signing up to receive e-newsletters; (2) through data collection forms on UVA Alumni Association’s website; (3) upon registering for a UVA Alumni Association event, (4) through donating or volunteering with UVA Alumni Association; (5) upon becoming a member; and (6) upon communicating directly with UVA Alumni Association either electronically or by providing hard copies of documents.
2.4 – Cookies and Other Tracking Technology
Cookies are limited information that a website transfers to your computer. Our websites use session cookies (expiring when you close the browser) and persistent cookies (persisting even after you close the browser), which help our websites run more smoothly and tailor content for you. Additionally, most web browsers have options that allow you to control whether to accept cookies and give you the option to delete all cookies. However, disabling may prevent access to some parts of our sites.
Our websites use cookies and other tracking devices to collect information automatically which we may use for purposes outlined in this Privacy Policy. These tracking devices may be placed by us or by our third-party partners or vendors. By using the sites, you agree to the use of cookies and other tracking devices as described below. You may configure your internet browser to notify you when a cookie is sent (giving you the option to decide whether to accept it or not), and to reject or remove cookies. To remove cookies, please follow your browser’s instructions or contact your browser provider for more information. By removing or refusing to accept cookies, you may be unable to use or access some features of our sites.
2.5 – Log Files
We also gather Personal Information automatically and store it in log files. For instance, when you visit our websites, the server may automatically recognize information about you, including the date and time you visited our sites, the pages you visited, the referrer (the website you came from), the type of browser you are using (e.g., Chrome, Edge), the type of operating system you are using (e.g., Windows or macOS), and the domain name and address of your Internet service provider.
3. How We Use Information
3.1 – Bases for Processing
Our bases for processing your Personal Information are:
- Contractual Necessity
- Compliance with Legal Obligations
- Legitimate Interests of UVA Alumni Association
- Where necessary, Consent
Before we process Personal Information on the basis of the legitimate interests of UVA Alumni Association, we review our processing in light of the interests and fundamental rights and freedoms of the data subject, taking into account their reasonable expectations. Where we believe those interests or fundamental rights and freedoms override our legitimate interests, we will seek another valid basis for processing your Personal Information or refrain from that processing activity. Examples of our “legitimate interests” for processing your Personal Information include (but are not limited to):
- Providing a program, service, or event
- Processing for direct marketing purposes or preventing fraud
- Transmission of Personal Information for internal administrative purposes and data analysis
- Processing for the purposes of ensuring network and information security
- Reporting possible criminal acts or threats to public security to a competent authority
3.2 – Purposes for Which We Use Personal Information
The purposes for which we process your Personal Information are listed below:
- General membership and account management
- Processing your orders, donations, or event registrations
- Processing applications that you submit to us
- Marketing
- Fundraising
- Website management and improvement
- Scholarship program award and administration
- Measuring the effectiveness of our products and services
- Keeping you informed about University of Virginia and UVA Alumni Association news, events, and activities
- Maintaining the online UVA Alumni Association member directory (Wahoo Connect)
- Identifying and recruiting volunteers
- Conducting surveys
3.3 – Cross-Border Data Transfers
UVA Alumni Association has its headquarters in the United States. By providing the Association with your Personal Information, you acknowledge that your Personal Information will be transferred to the United States and will be processed and stored in the United States by UVA Alumni Association and third-party data processors that we select. Some third parties may store data outside the United States.
4. How We Share Information
4.1 – UVA Alumni Association Staff, Contractors, Student Workers and Volunteers
To perform the functions listed in section “3.2 – Purposes for Which We Use Personal Information”, it may be necessary to share your Personal Information with staff, contractors, student workers and/or volunteers. All individuals performing professional or volunteer functions in support of the endeavors of the UVA Alumni Association are informed regarding the appropriate handling of confidential information (i.e., your Personal Information) and are required to sign a non-disclosure agreement.
4.2 – UVA Alumni Association Client Organizations
The UVA Alumni Association provides services (including financial and endowment management services, event management, membership management, and fundraising support) to foundations, alumni groups, and other organizations associated with the University of Virginia, and we may share information with these organizations when it is related to the services we provide them. We may also collect information from our clients to update alumni contact information.
4.3 – University of Virginia and Affiliated Organizations
The UVA Alumni Association is a co-controller of certain Personal Information with the University of Virginia. This data is shared with the University and with its affiliated organizations. Access is limited to authorized employees and protected by a non-disclosure agreement. The data is only available to staff for authorized uses.
4.4 – Third Party Processors and Transaction Processing
We engage third parties to perform services in connection with the operation of these websites and our organization. Examples of these third parties include website hosting service providers, technology service providers, payment processors, legal advisers and consultants, and/or related services. We share Personal Information with these third parties, but we authorize them to use this Personal Information only in connection with the services they perform on our behalf. Such parties are bound by contract to establish appropriate measures to protect your Personal Information from unauthorized access, use, or disclosure. In addition, we share certain Personal Information with third parties as necessary to facilitate our offering of products and services to you.
4.5 – Third Party Products and Services
We may share your Personal Information with select third parties that offer products or services that we believe may be of interest to you. These third parties may contact you with communications regarding their own products or services. Such third parties may include sponsors of UVA Alumni Association events and other UVA Alumni Association partners. Please note that if you receive communications from these third parties, you may contact them directly to opt out of receiving further communications from them.
4.6 – Event Attendees, Sponsors and Volunteers
For some UVA Alumni Association events, we may make certain Personal Information of event attendees (or potential attendees) available to other event attendees, event sponsors, and/or event volunteers. The Personal Information made available may include name and contact information.
4.7 – Social Media Sites
Social media sites offer opportunities to engage in social networking, interact with others, and/or submit or post messages or other content, such as on UVA Alumni Association Facebook pages. The sites may also provide for interactions with third party websites or services through plug-ins. Please note that any information or materials that you post or submit through such UVA Alumni Association social media sites will be publicly posted to everyone that has access to the relevant sites. Posts to third party social media or other sites, including any content on our sites that you “share” or “like,” will be controlled by and subject to the terms of such social media or other sites.
4.8 – Links
Our websites provide links to websites or services created and maintained by other individuals or organizations, including the University of Virginia. Please note that these websites’ privacy policies may differ from this Privacy Policy. We encourage you to read the privacy statement of any website you may visit, as we are not responsible for such websites’ content and policies. We do not control these sites nor are we responsible for the accuracy, timeliness, security, or continued availability or existence of the information provided on these sites. Other organizations linked from the sites may collect information about you when you visit their websites. We cannot control this collection of information. You should contact these companies directly if you have any questions about how they use the information they collect.
5. Your Data Privacy Rights
You have the right to:
- Withdraw your consent to processing your Personal Information
- Request access to your Personal Information
- Request rectification of your Personal Information
- Request erasure of your Personal Information
- Request restriction of processing
- Request data portability
- Object to processing of your Personal Information
Please note that these rights are limited under your applicable local data privacy law. If you exercise or seek to exercise your rights, our obligations to respond are limited by and subject to applicable law.
To exercise your rights, please contact us as stated under section “5.9 – Contact Us”. In some cases, you also have the right to lodge a complaint with the appropriate data protection supervisory authority.
5.1 – Right to Withdraw Your Consent
If a specific element of our processing of your Personal Information relies upon your consent, you may withdraw your consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.
The “5.8 – Your Communications Preferences” section of this Privacy Policy describes the options we provide to allow you to easily withdraw consent for certain elements of our processing (e.g., email marketing). In instances where you have opted in to sharing your Personal Information with third parties, you may contact us to opt-out of future sharing of your Personal Information with such parties; however, such withdrawal will not affect the lawfulness of the transfers that occurred prior to the consent withdrawal.
If you are subscribed to UVA Alumni Association marketing emails, you may withdraw your consent to receive such emails through the unsubscribe link contained in each email or by contacting us directly.
5.2 – Right to Request Access
You may email us at the address listed in section “5.9 – Contact Us” to request your Personal Information on file. Some of this information is also visible in your Wahoo Connect profile, if you have a Wahoo Connect account.
You also have the right to obtain from us confirmation as to whether Personal Information concerning you is being processed, and, where that is the case, to request access to the Personal Information. This access information includes:
- The purposes of the processing
- The categories of Personal Information involved
- The recipients or categories of recipient to whom the Personal Information has been or will be disclosed
5.3 – Right to Request Rectification
You have the right to request the rectification of inaccurate Personal Information concerning you. Depending on the purposes of the processing, you may have the right to have incomplete Personal Information completed, including by means of providing a supplementary statement. You may also change some of your Personal Information by visiting your profile on Wahoo Connect as described above in “5.2 – Right to request access”.
5.4 – Right to Request Erasure
Under some circumstances, you have the right to obtain from us the erasure of Personal Information concerning you. This is not an absolute right and may be limited by our need to retain data to support our business operations or comply with legal or regulatory requirements.
5.5 – Right to Request Restriction of Processing
Under some circumstances, you have the right to obtain from us restriction of processing your Personal Information. In such case, the respective data will be marked and may only be processed by us for certain purposes.
5.6 – Right to Request Data Portability
Under certain circumstances, you have the right to receive the Personal Information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you have the right to transmit those data to another entity without hindrance from us.
5.7 – Right to Object
Under certain circumstances, you have the right to object to the processing of your Personal Information by us and we can be required to no longer process your Personal Information. Such right to object may especially apply if we collect and process your Personal Information in order to send offers regarding our products and services or for direct marketing or solicitation of donations. If you exercise this right, your Personal Information will no longer be processed for such purposes by us. You may exercise this right by contacting us as stated in the “5.9 – Contact Us” section of this Privacy Policy. Such a right to object may not exist if the processing of your Personal Information is necessary to take steps to perform a contract or legal obligation.
5.8 – Your Communication Preferences
You may change your preferences for how we contact you at any time by using the “Contact” link on our website or via email at [email protected].
5.9 – Contact Us
For further information about UVA Alumni Association’s privacy practices or to exercise your data privacy rights, please contact [email protected].