This Privacy Policy (the “Privacy Policy”) explains how Emerson College collects and uses the information we collect from visitors to the officially administered and operated websites of Emerson College (the “Emerson Sites”) or the various social media sites or RSS feeds that offer our content (each a “Platform,” and collectively together with the Sites, “the Emerson Platform ”). Please see our Terms of Use for a more detailed description of the Emerson Sites and the Emerson Platform.
This Privacy Policy describes, among other things, the types of information collected about you when you visit the Emerson Platform, how your information may be used and when it may be disclosed, how you can control the use and disclosure of your information, and how your information is protected.
1. Scope of this Privacy Policy.
Please note that this Privacy Policy applies exclusively to the Emerson Platform, except as explained below.
Some websites operated and administered by Emerson College have separate privacy policies. This Privacy Policy applies exclusively to those websites where there is a link to this Privacy Policy at the bottom of the home page and/or any landing page. This Privacy Policy also applies to any official Emerson Social Media page or account to the extent that this Privacy Policy is not inconsistent with the terms of use or the privacy policy of that social media platform.
This Privacy Policy is part of the Terms of Use for the Emerson Platform and you should carefully review that document as well.
2. Information Collected.
A. Types of Information Collected.
Personally Identifiable Information (“PII”) refers to any information that can be used to identify you, to reasonably allow you to be identified, or to create an individual profile. This information includes, but is not limited to, your name, address, phone number, social security number, driver’s license or other state issued ID, birthdate, and email address. PII also includes any information we collect about you that is then linked to you or your device. For instance, if you access the Emerson Platform from a mobile device we will be able to identify some information about the mobile device you are using and your mobile provider.
This information is also considered part of your PII. PII is often aggregated so that it is no longer personally identifiable, in order to provide a snapshot of all visitors to the Emerson Platform without identifying any particular visitor.
B. Information You Provide Directly to Us.
You are not required to provide information about yourself when you visit the Emerson Platform, however, we may ask for certain information when you access certain services. For instance, some sites on the Emerson Platform allow you to sign up for emails or newsletters or to participate in surveys or other activities that involve providing personal information about yourself. In these circumstances we will have the information you provide such as your name, email, address, and other information. If you contact us on a social media site or "like" us on Facebook, we will have information about you as permitted by that social media platform.
Some of the sites on the Emerson Platform offer visitors the opportunity to buy merchandise or order tickets or to make a donation to Emerson.
C. Information You Provide To Us Via Our Vendors
In order to provide you many of the services offered across the Emerson Platform we sometimes engage third party vendors. For instance, if you order merchandise we may use one vendor to process and ship your order. In this instance we will share the relevant information you have provided to us via the Emerson Platform with our vendor so we can fulfill your order. We also engage with third party vendors to manage the information resources available on the Emerson Platform or to host a particular Emerson Site or to provide enhanced audio capabilities.
Many of these vendors are contractually prohibited from using any PII we provide them or that they may collect about you via the Emerson Platform except as necessary to process your requested service. However, other third parties provide Emerson access to enhanced services which are embedded in the Emerson Platform such as an enhanced audio and/or video player. In these circumstances, by using the enhanced service you are providing your PII and other information directly to this third party provider who may share some of this PII with Emerson.
Some Emerson Sites may have advertisements served to our Sites by one of the advertising platforms used across the Internet. For more information, please refer to our Cookie Policy
Emerson Sites that accept payments either for merchandise or services or as a donation usually use TouchNet.com to process your payment.
D. Information We Collect Automatically.
In addition to the information you provide directly, Emerson may collect certain information automatically, regardless of whether you register or request any services, including the following:
- Your browser type and operating system;
- Your Internet Protocol (IP) address, which is the number automatically assigned to your computer or other device whenever you access the Internet and that can sometimes be used to derive your general geographic area;
- Websites you visited before and after visiting the Emerson Platform;
- Web pages and advertisements you view and links you click on within the Emerson Platform;
- Unique identifiers, including mobile device identification numbers, which can identify the physical location of such devices in accordance with applicable law;
- Information collected through cookies, web beacons, and other similar technologies; we provide further details about the use of these technologies in our Cookie Policy;
- Interactions with audio and video content, such as the type of content listened to (and content viewed);
- Information about your interactions with email messages, such as the links clicked and whether messages were opened or forwarded;
- Standard server log information.
E. Information We Obtain From Other Sources.
Where permitted by applicable law, we collect information about you from other sources, including through interactive applications such as Facebook, Instagram, or Twitter. If we use a third party service to enhance certain features of the Emerson Platform those third parties may provide us information including PII they have collected about you as a result of your using these enhanced services.
We collect information about you from commercially available sources (such as data aggregators and public databases). In general the information we collect from these sources is disclosed in their respective privacy statements. We urge you to review the terms of use and privacy policies of each of these sites.
The following are examples of the type of information we may collect from other sources:
- Name, postal address, and telephone number;
- Demographic data, such as age, gender, and income level;
- Publicly-observed data, such as activities on blogs, videos, and other online postings; and
- Other navigation data, such as websites visited and advertisements viewed or clicked on.
F. Special Disclosure Regarding Location Data.
To the extent Emerson makes location enabled Services available and you use such Services, Emerson may collect and process your location data to provide location related Services and advertisements. For example, some add-ons or offers may be available at dedicated locations. The location data is processed and stored only for the duration that is required for the provision of the location related Services.
Emerson may use, depending on the service (1) IP-based location based on the IP address presented by the end-user, (2) fine geo-location data based on coordinates obtained from a mobile device’s GPS radio, or (3) coarse, network-based geo-location data based on proximity of network towers or the location of WiFi networks.
Your fine, GPS-based geo-location is not accessed without your consent. Notwithstanding Emerson’s partners who are providing location related parts of the Service, Emerson will not share your GPS geo-location with third parties without your consent.
G. Special Disclosure Regarding Financial Data
Whenever you use the Emerson Platform to purchase services or to make a donation to Emerson, your payment is processed by a third party financial services company, usually Touchnet.com. Emerson does not maintain your financial data on Emerson’s server or in backup but relies exclusively on its financial services vendor to maintain and protect this information. You can view the privacy policy of Touchnet.com at www.touchnet.com/en/privacy-policy.
H. Combining Information.
Please note that all of the information we collect about you may be combined. This allows us, among other things, to tailor our communications to you and to develop rich online content and services across the Emerson Platform.
3. Use of Information.
We only use payment and identity verification information, such as credit card numbers, driver’s license numbers, Social Security numbers, or comparable national identifiers as necessary for completing a particular transaction or fulfilling a service (e.g., when you make a contribution or awarding prizes to contest winners) or as otherwise required by law. Unless otherwise noted, this information is not stored on Emerson’s servers or maintained in our databases.
Generally, we use other information collected about you to:
- Fulfill your requests for products, services, and information, and to authorize a purchase, send you electronic newsletters, and complete a transaction that you have requested;
- Provide you with special offers and promotional materials;
- Analyze the use of the Emerson Platform and information about visitors to the Emerson Platform to understand and improve our offerings and, in accordance with our sharing policies discussed below, to produce anonymous or aggregated data and statistics that might help third parties develop their own products and service offerings;
- Customize the content you see when you visit the Emerson Platform;
- Develop and provide advertising tailored to your interests;
- Prevent potentially prohibited or illegal activities and otherwise in accordance with the Emerson Terms of Use;
- Improve our fundraising efforts on behalf of Emerson or any of the programs we offer or sponsor including programs or events we co-sponsor with other entities; and
- For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.
Unless otherwise described above, we will use the information in this way to meet our legitimate interests. We have an interest in improving the functionality of the Services (through tailoring content, and analyzing statistics) to make sure you have the best experience using the Services, and an interest in communicating with you (through marketing, responses to customer service requests and content delivery) in a way that is most useful to you. We also have an interest in protecting our rights and upholding the law.
4. The Sharing of Information Collected.
Emerson is committed to maintaining your trust and we want you to understand when and with whom we may share information collected about you via the Emerson Platform.
A. Authorized Third Party Service Providers.
We share your contact information with third party vendors who help us with specialized services, including customer support, payment processing, business analytics, marketing, suppression list management, and data processing. These third parties use your contact information to help us provide our services. Generally, these third parties use your personally identifiable information only to fulfill your request. Also, authorized third party service providers may collect non-contact information about your use of our services with cookies, web beacons and other similar technologies that may be used to deliver advertisements tailored to your interests. For more information, please refer to our Cookie Policy.
Some of the third party services we use provide specialized platforms or “add ons” to make the Emerson Platform more advanced such as special platforms for playing music or watching video or providing access to our information resources. These platforms have their own policies and terms of use that govern how they collect data about you and how they may share that data. Whenever an Emerson Site uses such a third party vendor we will advise you on the appropriate webpage in that Site and provide a link to their terms of use and privacy policy.
We will also identify the vendor providing payment processing services during the checkout process and provide you with a link to their terms of use and privacy policy.
B. Social Media Sites.
If you access our content via Facebook, Twitter, or any other social media platform (collectively referred to as “Social Media Platforms”), you are also authorizing us to share and receive information about you with that platform. Each platform has its own privacy policy concerning what information they collect, how they use it, and with whom they will share it. Please review the relevant policies of these social media platforms carefully. You can find some of these privacy policies here:
C. Business Transfers.
We may share your information in connection with a substantial corporate transaction, such as the sale of Emerson, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy. Our third party vendors may also reserve rights to share your data under these same circumstances.
D. Legal Requirements.
We and our third party vendors may disclose information about our users, including contact information, to respond to subpoenas, court orders, legal process, and other law enforcement measures, and in order to comply with other legal obligations, such as FCC requirements. We and our vendors also reserve the right to use any information we have collected about you including your PII in order to investigate any claims or suspicions of misconduct on the Emerson Platform.
E. Sharing Information To Protect Emerson, our Partners, Vendors, and Users.
We may disclose information to protect and defend the legal rights (including enforcing our agreements), interests, safety, and security of Emerson and users of the Emerson Platform including students, employees, agents contractors, and members of the public.
F. Sharing Information With Advertisers.
When you use the Emerson Platform you may find third-party advertisements. We share information with advertisers as explained in the in the privacy policies of our Social Media Platforms and as set out in our Cookie Policy.
In addition, information collected about your interactions with any of the vendor platforms may be shared with advertisers or other third parties as they disclose in their respective privacy policies or as set out in our Cookie Policy.
G. Aggregated Or Anonymized Data.
Finally, we also may share aggregated information with third parties to help us develop content and services we hope will interest you, or to help these third parties develop their own product and service offerings, including targeted marketing.
5. Your Choices.
You can choose to enjoy content and features on the Emerson Platform without providing us directly with any information about you; however, as described above, some information may be collected automatically or be requested so that you can take advantage of certain features and services offered on the Emerson Platform.
You can opt out of receiving commercial email from us by following the instructions contained in any such message. Please note that even if you unsubscribe to commercial messages, we may still need to send you communications relating to your use of the Emerson Platform, such as service announcements. And if you are a student you will continue to receive certain information from us about class schedules, tuition, and similar matters.
Finally, you may have choices about whether cookies and other similar technologies are placed on your computer or mobile device, and you may have choices about the collection and use of your information by third parties or by Social Media Platforms, with respect to displaying relevant advertisements. We describe these practices in our Cookie Policy.
6. Your Rights.
In some cases, you may be entitled under local law to access, correct, delete, restrict the processing of, object to the processing of, or receive a portable copy of PII that we hold, which specifically relates to you. You also may have a right to lodge a complaint with your local data protection or privacy regulator. Where you have provided your consent to any use of your PII, you can withdraw this consent at any time. Please note that we may require additional information from you in order to honor your requests. If you would like to discuss or exercise any rights you may have under law, please contact us at the contact information set forth below.
If you want to exercise your rights with respect to the Social Media Platform or any third party that independently collects information through the Emerson Platform you will need to contact those sites directly.
7. Protection of Information.
We are committed to protecting your information. We have adopted commercially reasonable technical, administrative, and physical procedures to help protect your information from loss, misuse, unauthorized access and alteration. Please note that no data transmission or storage can be guaranteed to be 100% secure. We want you to feel confident using the Emerson Platform, but we cannot ensure or warrant the security of any information you transmit to us.
8. Information Storage.
Emerson is headquartered in the United States. If you access the Emerson Platform from outside the United States, your data will be processed by Emerson in the United States, whose laws may not be regarded as providing the same level of protection for PII as the laws of the country from which you access the Emerson Platform.
We retain your PII as long as we have a relationship with you. When deciding how long to retain your PII after our relationship with you has ended we take into account our legal obligations. We may also retain your PII as needed to investigate or defend against potential legal claims.
9. User-Generated Content.
The Emerson Platform may enable users to submit their own content for use on, social media, blogs, podcasts, online audio and video streams, message boards, and other functions. Publication of user-generated content on the Emerson Platform is subject to our Terms of Use. Please remember that any information you disclose becomes public information. Exercise caution when choosing to disclose your contact, financial, and other information in a submission. We cannot prevent others who access such publicly available information from using it in a manner that may violate this Privacy Policy, the law, or your personal privacy and safety. You should also be aware that we may also engage a third party to provide some of the services associated with the blogs, message boards and similar functions. This third party will collect and host the information that you submit to the Emerson Platform, but will not use any of this information for purposes other than providing the service.
10. Third Party Websites and Services.
Please note that there may be links to other websites and services on the Emerson Platform. We are not responsible for the privacy practices of those websites, and we recommend that you review the privacy policies of each website that you visit. When you select a link to a third party website from the Emerson Platform (e.g., if you click on one of the advertising links on the Site), you will be leaving the Emerson Platform. Any information that you disclose on the third party website will be governed by that website's privacy policy.
11. Changes to this Privacy Policy.
We may update this Privacy Policy to reflect changes in our practices and service offerings. If we modify our Privacy Policy, we will post those changes to this page and update the “Last Modified Date." If we make any revisions that materially change the ways in which we process your previously collected PII, we will notify you of these changes before applying the changes to that PII.
12. Questions.
If you have questions regarding this Privacy Policy, please contact us at privacy [at] emerson.edu (privacy[at]emerson[dot]edu) and we will endeavor to respond to your request within a reasonable period of time. You may also submit questions or comments using the postal address listed below:
Emerson College
Attention: Chief Information Security Officer
120 Boylston Street
Boston, Massachusetts 02116
Our representative in the European Union is:
Emerson College European Center – Kasteel Well
Kasteellaan 20
5855 AE Well
The Netherlands
We are committed to working with you to obtain a fair resolution to any privacy concern.
Last Modified Date: 11-1-2019