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Purposes of Processing	Categories of Personal Information	Legal Basis
As part of the undergraduate and graduate admissions process, we collect applicant Personal Information to evaluate applications. We also may obtain Personal Information from third parties, such as other schools, references, family members, and education partners (e.g., The Common Application, Inc., Law School Admissions Council, The College Board, etc.) as part of an application package.	Name, address, contact details, race/ethnicity, demographic information, educational history, reference, photographs, letters, PeopleSoft ID, and other relevant information as part of the application package.	Legitimate Interest: Personal Information collected through the graduate or undergraduate application is necessary to evaluate candidates for admissions and for our internal statistical and analytics purposes Consent: Processing of Sensitive Personal Information for purposes stated above Contract:  If a contract is involved, processing will be handled for purposes stated above Legal Requirement:  Personal Information and Sensitive Information are processed and maintained as required by law
To  process financial aid and scholarship applications and awards	Name, address, contact details, demographic information, salary history, PeopleSoft ID, tax forms and other relevant information to evaluate financial aid/scholarship eligibility and opportunities.	Legitimate Interest: Personal Information collected through the financial aid application is necessary to evaluate whether the applicant is eligible to receive financial aid/scholarships Consent: Processing of Sensitive Personal Information for purposes stated above Contract: to process Personal Information and Sensitive Information pursuant to contract Legal Requirement:  Personal Information and Sensitive Information are processed and maintained as required by law
To support course registration and academic matters, such as coursework, test results, grading; to investigate claims of academic misconduct	Name, Campus AD ID, PeopleSoft ID and/or Banner ID, contact information	Legitimate Interest: Personal Information collected for matriculated students, staff, faculty and members of the public, as appropriate for the course, to enroll in courses or classes, and administer academic matters
To process requests for housing and dining services	Name, Campus AD ID,  PeopleSoft ID and/or Banner ID, contact information, dietary restrictions, special interests	Legitimate Interest: Personal Information collected to facilitate housing requests and for available meal plans Consent:  Processing of Sensitive Information for purposes stated above Contract:  Processing Personal Information pursuant to contract
To provide online training and distance educational programs	Name, Campus AD ID,  PeopleSoft ID and/or Banner ID, contact information, demographic information	Legitimate Interest: To facilitate provision of education courses to matriculated students, staff, faculty and members of the public, as appropriate for the course
For research purposes, to recruit, screen, and enroll individuals as research subjects, conduct clinical studies, and/or process data or biological samples from individuals	Name, contact/demographic information, other personal data as necessary for the research protocol, such as health information, data and/or biological samples	Legitimate Interest:  To  conduct human subjects  research Consent: Written consent requirements approved by University IRB for specific research projects Contract:  To examine, evaluate, and analyze in compliance with research contracts and awards
To establish and conduct collaborations with external scientists or companies for research purposes	Name, contact information, demographics and credentials of scientist collaborating with the University	Legitimate Interest:  To establish and collaborate on research and enter into intellectual property (IP)/licensing agreements Contract: Establishment of research contracts/awards and IP agreements
To recruit students for athletics teams, provide athletic scholarships,  administer athletics programs	Name, Campus ID, PeopleSoft ID and/or Banner ID, demographic information, health information, sport statistics	Legitimate Interest:  To recruit and coach student athletes, provide academic support services, provide and administer athletic scholarships, provide dietary and nutritional education, health care, training and sports medicine services Consent:  Upon written consent from the individual, for the purposes stated above Contract:  To provide athletic scholarships and administer athletics programs as required by contract
To provide student outreach and support services, including but not limited to reasonable accommodations, health services, tutoring, counseling and other assistance as needed	Name, Campus ID, PeopleSoft ID and/or Banner ID, demographic information, health information; other sensitive information	Legitimate Interest:  To facilitate student academic achievement; provide health services, tutoring, counseling and other assistance as needed   Consent:  Upon written consent from the individual, Sensitive Information will be processed for the purposes stated above Legal Requirement:  Sensitive Information will processed to provide reasonable accommodations
To process employment applications	Name, Campus AD ID,  PeopleSoft ID and/or Banner ID, demographic information, resumes	Legitimate Interest: For individuals interested in employment opportunities, processing applications
To enroll in wellness programs	Name, Campus AD ID,  PeopleSoft ID and/or Banner ID, health information	Legitimate Interest: For eligible individuals interested in participating in a variety of wellness programs, courses, activities, facilitate enrollment and communications about the programs Contract: If there is a contract for participation in wellness programs, Personal Information is processed pursuant to that contract
To administer employment activities of University faculty, staff and student workers	Name, Campus AD ID,  PeopleSoft ID and/or Banner ID, contact information, demographic information, dependent information, financial information, employment records, photographs, health information	Legitimate Interest:  To comply with legal requirements, administer payroll and benefits, provide reasonable accommodations, administer FMLA and sick leave policies, improve hiring practices, for regulatory reporting and auditing and other University processes and functions Consent:  Sensitive information will be processed for the purposes provided above Legal Requirement:  Sensitive Information will be processed to provide reasonable accommodations and to administer FMLA and sick leave policies
To process visa applications for incoming student, staff and faculty from overseas	Name, demographic information, financial information, passport number	Legal Requirement
For marketing purposes and donations, and to process requests for brochures and other information	Name, contact information, financial information, payment information	Legitimate Interest: To collect and process donations/gifts and donor information, to send brochures or other requested information
To process payments such as tuition and other student fees, parking passes and permits, event registrations and tickets to events	Name, Campus AD ID,  PeopleSoft ID and/or Banner ID (if applicable), contact information, payment information	Legitimate Interest:  To receive and process payments for tuition, fees, parking, and to register and receive payments for sports, cultural, educational and other University events Contract:  To process registration and payment for the purposes stated above
To submit requests for services (e.g., IT technical help, chat line, etc.)	Name, Campus AD ID,  PeopleSoft ID and/or Banner ID, contact information	Legitimate Interest: To process service requests from students, staff and faculty Contract: If there is a contract that governs your use of such services, Personal Information is processed pursuant to that contract
Website account registration	Name, contact information, alumni status	Legitimate Interest: For websites that require registration for access, to facilitate the registration
Travel administration	Name, Campus AD ID,  PeopleSoft ID and/or Banner ID, contact information, passport number, loyalty membership information, emergency contacts	Legitimate Interest: To facilitate travel arrangements and coordination for students and affiliated travelers through University programs Contract: If there is a contract that governs your use of travel sites, Personal Information is processed pursuant to that contract
To investigate claims of discrimination/harassment	Name, contact information, PeopleSoft ID and/or Banner ID, other personal data if applicable -- age, demographic information, racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, health data, sexual orientation, and salary and other employment history	Legitimate interest:  To investigate claims and complaints of discrimination/harassment Consent:  Claimant information will be processed for the purposes stated above Legal Requirement
For safety, risk management purposes	Name, address, contact information, PeopleSoft ID and/or Banner ID, age, health information, and other information as necessary to achieve purposes.	Legitimate Interest:  To provide a safe, secure campus, provide occupational and environmental safety, to investigate suspected criminal activity, to evaluate workers compensation and injury claims Legal Requirement
To receive, investigate, and resolve claims of misconduct and/or violation of University policies; to conduct disciplinary proceedings	Name, address, contact information, PeopleSoft ID and/or Banner ID, age, health information, and other information as necessary to achieve purposes.	Legitimate interest:  To investigate claims and complaints of misconduct and violation of University policies Consent:  Claimant information will be processed for the purposes stated above
To provide access to the official University app	Campus AD ID, location	Legitimate Interest: To provide access to information available through the University mobile application.  To provide notifications through the University mobile application Consent: Upon written consent from the individual to use the mobile app

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Cookies

A cookie is a file designed to contain a small amount of user and website information stored on a user’s computer. The file interacts with the user and the website to provide a webpage tailored to the user through its awareness of information held within the file.

Cookies also have the ability to carry all or parts of the information stored within the file to other websites that the user may visit or to third parties.

Cookie Policy

This Cookie Policy applies to the cookies we use when you visit any of the University websites and any other websites that we own or control and link or refer to this Cookie Policy (together, the “Sites”).

This cookie policy provides you with more information about cookies, what types of cookies we use and how we use them. Our Sites use cookies with the intention of providing you with a user experience that best suits your needs, while concurrently allowing us to improve the design and functionality of our Sites. Cookies can be adjusted or disabled, and this policy provides you with instructions to do so.

Types of Cookies

A third-party cookie is placed by a domain other than that of the website the user is visiting.

A session cookie is temporary, linking the actions of a user during the any given browser session. When the browser is closed, the cookie is deleted.

A permanent cookie, also known as a persistent cookie, is stored for a specific period of time and activates each time the user visits the website that created the cookie.

Our Use of Cookies

We use third-party, session and persistent cookies and similar technology to collect aggregate (non-personal) information about Sites usage by all of our visitors and to help us remember you and your preferences when you revisit the Sites. These cookies may stay on your browser into the future until they expire or you delete them. We also use technology to remember you the next time you log in. Some of these cookies are erased when you close your browser window and some persist for a period of time. Further general information about cookies and how they work is available at www.allaboutcookies.org.

We may allow selected third parties to place cookies through the Sites to provide us with better insights into the use of the Sites or user demographics or to provide relevant advertising to you. These third parties may collect information about a user’s online activities over time and across different websites when he or she uses our Sites.

The cookies used on our Sites may include, but are not limited to, the following:

Category	Description
Session	These cookies expire when the browser is closed. The purpose of these cookies is to temporarily retain information related to the user’s visit to a Site, such as the number of visits, average time spent on the Site, and what pages have been loaded.
Permanent	These cookies remain in operation, even when the browser is closed. The purpose of these cookies is to retain information to help the user avoid retyping data.
Third-party	Third parties install these cookies to collect certain information for statistical purposes and conducting research into behavior, demographics, and similar topics about our users.
Analytics	These cookies help us understand how our visitors engage with our Sites. These cookies collect information and report website usage statistics. Some of these cookies are used to see how people use our Sites, which helps us improve it.
Preferences	These cookies allow our Sites to remember information that changes the way the site behaves or looks for you, such as your preferred language or the region you are in. For instance, by remembering your region, a website may be able to provide you with local weather reports or traffic news. These cookies can also assist you in changing text size, font, and other parts of web pages that you can personalize. Loss of the information stored in a preference cookie may make the website experience less functional but should not prevent it from working.
Security	We use security cookies to authenticate users, prevent fraudulent use of login credentials, and protect user data from unauthorized parties. Some of these cookies may collect the request made by your browser to the server hosting the website which includes the IP address, the date and time of connection and the page you ask for. We use this information to ensure the security of our Sites. Some of these cookies help make the Sites work and deliver services that the website visitor expects, like navigating around web pages or accessing secure areas of the website. Without these cookies, the Sites cannot function properly.
Advertising	We use cookies to make advertising more engaging to users and more valuable to publishers and advertisers. Some common applications of these cookies are to select advertising based on what’s relevant to a user; to improve reporting on campaign performance; and, to avoid showing ads the user has already seen.

Adjusting Cookie Settings

You can change your cookie settings by reviewing your internet browser’s cookie options. The links below to popular browsers may help you understand your cookie options better. Typically, such information can be found under the browser’s ‘Help’, ‘Preferences’ or ‘Options’ menus.  Information about how you can opt out of Google's use of cookies can be obtained by visiting Google's Ads Settings and how you can opt out of a third-party vendor's use of cookies by visiting the Network Advertising Initiative opt-out page.

• Cookie settings in Chrome
• Cookie settings in Firefox
• Cookie settings in Internet Explorer
• Cookie settings in Safari – iOS
• Cookie settings in Safari – macOS

Interest-Based Advertisements

Some of our Sites engage in online interest-based advertising to enhance your experience and show you advertisements that might interest you. Like many organizations, we and our advertising partners display tailored interest-based advertising using information you make available to us when you interact with our Sites.  Interest-based ads, also sometimes referred to as personalized or targeted ads, are displayed to you based on information from activities such as searching on our Sites or visiting websites that contain our content or ads. We do this using a variety of digital marketing networks and ad exchanges, and we use a range of advertising technologies like web beacons, pixels, ad tags, cookies, and mobile identifiers.

To learn more about interest-based ads or to opt-out of receiving third-party interest based ads, please visit http://optout.aboutads.info or www.youronlinechoices.eu. Please note that if you opt out of interest-based advertising, you will still see advertisements – they will just not be tailored to your interests.  Also note that deleting browser cookies can remove the cookie preferences you have made, so you may need to opt-out again in the future.

Blocking Cookies

Should you choose to decline or block cookies by adjusting your browser settings, including cookies essential to the Sites.  Please note that all or parts of our Sites may not be functional or accessible to you. Our Sites will issue cookies as soon you visit the Sites, unless your browser cookie settings are adjusted to prevent such an occurrence. Please review the information provided in this cookie policy on adjusting cookie settings for the browser of your choice.

Sharing your Personal Information

We share your information internally to facilitate and manage the purposes listed above. This includes third parties whom the University engages to process your Personal Information on our behalf for the purposes stated above, such as vendors who help us with our marketing, application processing, and web hosting. The University may also share your personal data with government and law enforcement agencies or regulators to 1) comply with a legal process, subpoena, order or other legal or regulatory requirement applicable to us; 2) enforce our terms of use or other policies; or 3) pursue available legal remedies or defend against legal claims. The University may also share your personal data with other third parties you may have requested to receive your Personal Information to the extent permitted by this and other applicable University policies and applicable laws and regulations. We will not sell any personal information to third parties for their use in direct marketing, advertising, or promotion of their products or services.

International Transfer of Personal Information

If you live or provide us information from outside the United States, data protection laws in the United States may differ from those in your home country.  Therefore, if you are a user from outside of the United States, by providing us with your Personal information, you acknowledge that your information will be transferred to the United States, processed on servers in the United States, and handled in accordance with the applicable data protection laws, including the GDPR if you are located within the EEA.  In certain instances, your Personal Information may be transferred to other countries, including your home country.  Regardless, we will take all reasonable steps to protect your privacy in accordance with applicable law and University policy. Information Security

We take the security of your personal information seriously. Our minimum security standards can be found at: http://www.uh.edu/af/universityservices/policies/sam/7InfoServices.htm

Marketing

Personal Information you submit, such as your name, address and other contact information, may be collected by us for internal marketing and development purposes as well as to respond to your inquiry, complete a transaction for you, or fulfill other forms of customer service. You can choose not to receive marketing from us by “unsubscribing” using the instructions in any marketing email you receive from us or contacting the sender and requesting to be removed from further marketing emails.

EEA Data Subject Rights

If you are an individual located in the EEA only, you will have the following rights with regard to your Personal Data:

1. Right of access 
   You may request details of your Personal Information that we hold. We will confirm whether we are processing your Personal Information and we will disclose supplementary information including the categories of Personal Information, the sources from which it originated, the purpose and legal basis for the processing, the expected retention period, and the safeguards regarding Personal Information transfers to non-EEA countries, subject to the limitations set out in applicable statutes, regulations and other law
2. Right of correction 
   We will comply with your request to edit and update incorrect Personal Information promptly.
3. Right to be forgotten
   At your request, we will delete your Personal Information promptly if:
   • it is no longer necessary to retain your Personal Information;
   • you withdraw the consent which formed the basis of your Personal Information processing;
   • you object to the processing of your Personal Information and there are no overriding legitimate grounds or other legal basis for such processing;
   • the Personal Information was processed illegally; or
   • the Personal Information must be deleted for us to comply with our legal obligations.

   We will inform any third parties with whom we might have shared your Personal Information of your deletion request.

   We will decline your request for deletion if processing of your Personal Information is necessary:

   • to comply with our legal obligations;
   • to defend or pursue legal action;
   • to detect and monitor fraud; or
   • for the performance of a task in the public interest.
4. Right to restrict processing of your Personal Information
   

   At your request, we will limit the processing of your Personal Information if:

   • you dispute the accuracy of your Personal Information;
   • your Personal Information was processed unlawfully and you request a limitation on processing, rather than the deletion of your Personal Information;
   • we no longer need to process your Personal Information, but you require your Personal Information in connection with a legal claim; or
   • you object to the processing pending verification as to whether an overriding legitimate ground or other legal basis for such processing exists.
5. Right to notice related to correction, deletion, and limitation on processing
   In so far as it is practicable, we will notify you of any correction, deletion, and/or limitation on processing of your Personal Information.
6. Right to data portability
   At your request, we will provide you free of charge with your Personal Information in a structured, commonly used and machine readable format, if: (i) you provided us with Personal Information; (ii) the processing of your Personal Information is based on your consent or required for the performance of a contract; or (iii) the processing is carried out by automated means.
7. Right to object
   Where we process your Personal Information based upon our legitimate interest then you have the right to object to this processing.  However, we may decline your request if another legal basis for such processing exists.
8. Right not to be subject to decisions based solely on automated processing
   You have the right to request to not be subject to decisions that are based solely on the automated processing of your Personal Information.
9. Right to withdraw consent
   You have the right to withdraw any consent you may have previously given us at any time. If you withdraw your consent, this will not affect the lawfulness of our collecting, using and sharing of your Personal Information up to the point in time that you withdraw your consent. Even if you withdraw your consent, we may still use your information that has been fully anonymized and does not personally identify you or if another legal basis enables us to continue processing and using your data.
10. Right to complain to a supervisory authority
    If you are not satisfied with our response, you have the right to complain to or seek advice from a supervisory authority and/or bring a claim against us in any court of competent jurisdiction.  If you wish to contact us in connection with the exercise of your rights listed above, please email us at privacy@uhs.edu.  We will respond to your written request without unreasonable delay and in accordance with any deadlines imposed by law. Unless we notify you at the time of our response, we will not charge you any fee in connection with the exercise of your rights.

Access and Choice

University students can manage privacy settings for their directory information in myUH Self Services or Banner. Faculty, staff and other University affiliates can manage their privacy settings in P.A.S.S. (Employee Self Service).

You can choose not to receive emails from us by “unsubscribing” using the instructions in any email you receive from us.  This will not stop us from sending emails about your account or your transactions with us.

Document Retention

We keep your Personal Information for as long as needed to fulfill the particular purpose for which it was collected. We may also retain your records if legally required or to fulfill a legitimate interest.

Updates to the Privacy Notice

We reserve the right to modify this Privacy Notice at any time. Prior to changes to the Privacy Notice, we will provide you notice, which shall be available at privacyofficer@uh.edu, prior to the effective date of any notice. Your provision of Personal Information to use after any change in this Privacy Policy will constitute your acceptance of such change.

Contact information

For more information on how we collect and process your Personal Information, or if you have any complaints please contact privacyofficer@uh.edu.

 

Effective Date

The effective date of this policy is May 25, 2018.