1. Transparency Regarding the Use of Your Personal Data
As part of our commitment to protecting your privacy, this statement is designed to provide you with information regarding how the UC San Diego Online platform, website at online.ucsd.edu, applications, and services (“UC San Diego,” or “Services”) collect and process your information when you interact with the Services or otherwise communicate with UC San Diego Online. This statement is applicable to all Users except matriculated University of California students. University of California students should refer to https://ucsd.edu/catalog/front/ferpa.html.
For purposes of the General Data Protection Regulation (“GDPR”), the data controller is the Regents of the University of California, with a location at 9500 GIlman Dr., La Jolla, CA 92093.
2. Your Personal Data We Use
Information you provide directly to UC
UC San Diego Online collects personal information about you called Personal Data. Your Personal Data is collected when you register or fill in a form on the UC San Diego Online Services, or contact UC San Diego Online. This includes information you provide when you register for a class, use our Services, interact with others through online courses, subscribe to newsletters, place an order, or participate in discussion boards on our Services. Depending upon the specific UC San Diego Online service you use, the information you give us includes your name, address and telephone number, e-mail address, gender, age, payment information, and your course work, writings, or comments on discussion forums, as well as any information about you that is associated with or linked to, or could be linked to, any of the foregoing data.
We also collect more sensitive information about you, with your explicit consent, where the processing is necessary to meet a legal or regulatory obligation, the processing is in connection with UC establishing, exercising or defending legal claims, the information is necessary for internal University reporting, or is otherwise expressly permitted by GDPR. This sensitive information includes: information about your racial or ethnic origin.
Log, Cookie and Device Data
We also collect log data, which is information collected whenever you visit a website. This log data includes your Internet Protocol address, browser type and some settings, the date and time of your request, how you used the Service, and cookie data. Depending on how you are accessing the Services, we may use “cookies” (small text files stored by your computer when you visit our website) or similar technologies. In addition to log and cookie data, we also collect information about the device you’re using to access the Services, including what type of device it is, what operating system you are using, device settings, unique device identifiers and crash data. Whether we collect some or all of this information often depends on what type of device you are using and its settings. For example, different types of information are available depending on whether you are using a Mac or a PC, or an iPhone or Android phone. To learn more about what information your device makes available to us, please also check the policies of your device manufacturer or software provider.
Information from Other Sources
We also obtain information about you from other sources and combine that information with information we collect from you directly. For example, we collect information about you when you make a payment through our authorized payment processor, or when you post content to our pages and/or feeds on third party social media platforms. The information we obtain from other sources includes your name, address and telephone number, e-mail address, payment information, as well as any information about you that is associated with or linked to, or could be linked to, any of the foregoing data.
3. How We Use Your Personal Data and the Lawful Basis for Such Processing
UC San Diego Online processes your Personal Data for the following purposes and bases:
- It is in our legitimate interest as an institution of higher learning to:
- Understand and improve our processes;
- Assess and appraise our process for evaluating UC San Diego Online courses; and
- Suggest and plan future online programming and course design at UC San Diego.
- Process your payments to UC San Diego Online. This is generally required to process a transaction requested by you;
- Provide you with information regarding UC San Diego Online events and initiatives. We will generally only do this where it is in our legitimate interest and where you have not objected or withdrawn any prior consent given;
- Process and deal with any complaints or inquiries made by you or legally on your behalf. We do this because it is in our legitimate interest as part of the services UC offers to you;
- UC may also be required to disclose your Personal Data to authorities who can request this information by law that is binding on UC;
- Utilize personal data including sensitive data in connection with UC San Diego Online Services, with your consent for internal reporting. and for scholarly research with IRB approval when required. For use in research projects as approved or exempt by an Institutional Review Board (IRB) and reviewed by our privacy and security teams. It is in our legitimate interest as an institution of higher learning to understand and improve digital learning and pedagogy.
In certain instances, UC may be required to obtain your consent to collect and process your Personal Data for a specific purpose. This depends on the specific category of data collected and the intended use of the data. In these instances, the UC Service will inform you of the specific category of Personal Data that will be collected and the intended purpose of the collection, and will request that you affirmatively indicate that you consent to the intended collection of your Personal Data for that purpose, prior to collecting the data.
In these instances, if you do not consent to the collection and intended processing purpose, UC will refrain from collecting and processing your Personal Data.
4. Recipients of Your Personal Data
UC San Diego Online may share your Personal Data with the following recipients:
- Other UC locations or departments: Other UC locations or departments in order to provide you with a UC Service or where it is in UC’s legitimate interests.
- Service Providers: Vendors that need access to your Personal Data in order to provide UC San Diego Online’s Services.
- Public and Governmental Authorities: Entities that regulate or have jurisdiction over UC such as regulatory authorities, law enforcement, public bodies, and judicial bodies.
- Corporate Transactions: A third party in connection with any proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of UC’s business.
If your Personal Data is shared with a third party, UC will require that the third party use appropriate measures to protect the confidentiality and security of your Personal Data.
We may also need to share your Personal Data as required to respond to lawful requests and legal process; to protect our rights and property and those of our agents, customers and others, including to enforce our agreements and policies; and in an emergency, to protect UC and the safety of our students, faculty and staff or any third party.
UC takes appropriate physical, administrative and technical measures to protect Personal Data that are consistent with applicable privacy and data security laws and regulations. For more information about how UC protects data, refer to Systemwide Information Security Policies and Standards.
6. Retaining and Deleting Your Personal Data
UC will only retain your Personal Data for the duration necessary for the data collection purposes identified above, unless there is a legal requirement to maintain it for a longer period.
7. International Transfer of Your Personal Data
In order to fulfill the intended processing purposes described above, your Personal Data will be transferred outside of the European Economic Area (EEA), which may not protect Personal Data in the same way that it is protected in the EEA. UC will undertake appropriate measures to ensure adequate protection of Personal Data, including utilizing appropriate physical, administrative, and technical safeguards to protect Personal Data, as well as executing standard contractual clauses approved by the European Commission or a supervisory authority under GDPR, or obtaining your consent, where appropriate.
8. Your Rights
As required by the General Data Protection Regulation and applicable EU Member State and EEA state law, if you are located in the European Economic Area, you have a right to:
- Access your Personal Data, as well as information relating to the recipients of your Personal Data, the purposes of processing your Personal Data, the duration for which the Personal Data will be stored, and the source of Personal Data that has not been provided by you;
- Rectify or correct inaccurate or incomplete Personal Data concerning you, taking into account the purposes of the processing, and the right to have incomplete Personal Data completed;
- Move your Personal Data to another controller or processor. UC will facilitate the lawful transfer of your data to the extent possible;
- Have your Personal Data erased in certain circumstances;
- Restrict the processing of your Personal Data in certain circumstances;
- Object to the processing of Personal Data in certain circumstances;
- Withdraw your consent to the processing of your Personal Data, should UC ask for your consent for the processing of your Personal Data. The withdrawal does not affect the lawfulness of processing based on your consent before its withdrawal.
- Know whether your Personal Data is being used for automated decision-making, including profiling. In those cases, UC will give you meaningful information about the logic involved, the significance and the envisaged consequences of such processing for your data, and the right to request human intervention; and
- Lodge a complaint with a supervisory authority.
UC may be obligated to retain your Personal Data as required by U.S. federal or state law.
If you wish to exercise your rights, you can contact the UC Privacy Official identified below.
9. Questions and Complaints; UC Privacy Official
If you have questions or complaints about our treatment of your Personal Data, or about our privacy practices more generally, please feel free to contact the UC San Diego Campus Privacy Officer: Pegah Parsi, UC San Diego Campus Privacy Officer, firstname.lastname@example.org, 858-822-4439.
Effective Date: This statement is effective as of March 3, 2020.