The following sections apply to you if you are an individual located within the European Union (EU) and your Personal Data is processed in connection with Florida National University’s (“FNU” or the “University’) offering of goods or services within the EU. Personal Data means any information that allows you to be directly or indirectly identified.
Data Controller and Contact Information
FNU is the “data controller” for the processing of your Personal Data. FNU can be contacted regarding the processing of your Personal Data by sending an email to firstname.lastname@example.org or by calling (305) 821-3333.
Purposes and Legal Basis for Data Processing
We collect your personal information such as your name, address, and e-mail address for the purposes of providing you with the educational services for which you have contracted, for marketing purposes, and/or for FNU’s other legitimate interests. We also collect financial information as necessary to process payments for tuition and related fees.
You voluntarily provide and we collect your Personal Data as part of your enrollment with FNU. Your information allows us to ensure that you receive the educational services to which you are entitled in exchange for paying tuition and fees and acting in accordance with University policies.
The collection of your Personal Data is necessary to support our legitimate interests as an educational institution. “Legitimate interests” means our interest in providing students with the educational program for which they have contracted, conducting and managing our institution, and fulfilling our educational mission. For example, we have a legitimate interest in processing your Personal Data when you enroll as a student in one of our programs. When we process your Personal Data for our legitimate interests, we ensure adequate protection of your Personal Data and consider your rights under data protection laws.
If we do not have a preexisting relationship with you, then we will obtain your consent before contacting you for marketing purposes. When you consent to receive marketing communications from FNU, we will only process your data as is necessary in relation to the purpose of sending you information about our programs and services, unless another legal basis exists that allows FNU to process your personal data. You have the ability to opt-out of receiving marketing communications from FNU at any time.
In order to provide our visitors with a better experience and usability, we do automatically collect certain information. When you visit our website, we collect the operating system you use, your IP (Internet Protocol) address, and the browser you are using in order to provide a better, more personal experience. FNU shall only process the information we receive in order to pursue legitimate business interests to establish communications with possible clients/customers and other persons with general, business related inquiries. If you request that we no longer collect your IP address, you may not be able to visit our site.
If we collect your Personal Data for reasons beyond the performance of our obligations to our members or the pursuit of our legitimate interests, we will ask for your consent to collect such data.
If we intend to use your information in a way that is different from the reasons for which it was collected, we will notify you before doing so and, if necessary, ask your permission before collecting any additional data or using it in any way.
Special Categories of Data
The GDPR considers information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, data concerning health, a natural person’s sex life or sexual orientation, and the processing of genetic data or biometric data for the purpose of uniquely identifying a natural person to be “special categories of data.” We will not process or disclose outside of our organization these categories of data.
Access to Your Personal Data
We may share your Personally Identifiable Information within Florida National University, authorized third-party agents in any part of the world, or our business partners for purposes of data enrichment, storage, processing, or to provide services to a transaction that was requested, after ensuring that such entities are they, themselves bound contractually by data privacy obligations.
If and when we transfer Personally Identifiable Information outside of the EU, it is either to countries determined by the European Commission to have an adequate level of protection or have been determined to have in place the appropriate safeguards.
Our students can access a limited amount of contact information about other students via our directory. This includes the following data: phone number, email address, name and billing address.
If we intend to transfer your Personal Data to an organization outside of the European Union, we will notify you before doing so.
Data Processing and Storage of Personal Data
We use databases on servers of cloud-based data management services with which Florida National University engages to securely store and process your Personal Data.
Any data that is no longer needed for the purposes for which it was collected will be deleted.
- Personal Data – Florida National University will keep your PII to pursue enrollment purposes and it will be kept in line with our data retention policies
- Academic Records – Any PII that is received from prospective students will be retained for the entire duration of the prospective students’ business relationship with Florida National University and 5 to 7 years thereafter.
- Financial/Payment Data – Original promissory notes should be kept until the loan is satisfied or the documents are no longer needed to enforce the obligation. Records pertaining to the amount of a loan, terms of repayment, and the repayment history should be kept for three (3) years from the date on which a loan is assigned to the DOE, is canceled, or is repaid. Records pertaining to borrower eligibility and participation should be kept for three (3) years from the end of the award year in which the student last attended. Fiscal Operations Reports should be kept for three (3) years from the end of the award year in which the report was submitted. The following records must be retained for five (5) years from the time the record is created, or for the period required under the applicable program regulations:
- Fiscal and administrative records to ensure that funds received for repayment are properly administered;
- Records regarding required disclosures to students regarding financial aid;
- Current records of students’ admission and enrollment at the institution;
- Records necessary to determine institutional eligibility, financial responsibility, and administrative capability;
- Financial records are enough to allow the DOE to conduct an annual audit. All financial aid records should be considered confidential.
Rights of Data Subjects
Subject to applicable law, you have the following rights in relation to your personal data:
- Right of access: You can request an electronic copy of your personal data contained within our system. Requests should be made by sending an email to email@example.com or by calling (305) 821-3333. In order to comply with your request, we may ask you to verify your identity.
- Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to have it rectified or completed. Updates to your Personal Data can be made by sending an email to firstname.lastname@example.org or by calling (305) 821-3333.
- Right to erasure: As permitted by law, you may ask us to delete or remove your Personal Data. Requests should be made by sending an email to email@example.com or by calling (305) 821-3333. In some situations, the deletion of certain Personal Data may affect our ability to provide proper services.
- Right to restrict or object to processing: You may ask us to restrict or block the processing of your Personal Data in certain circumstances or request no contact from us. Requests should be made by sending an email to firstname.lastname@example.org or by calling (305) 821-3333.
- Right to data portability: You have the right to obtain your Personal Data from us that is contained in our system. Requests for your data should be made by e-mail or phone number.
- Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on your prior consent. Requests should be made by sending an email to email@example.com or by calling (305) 821-3333.
- Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we have handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns. The relevant authority is the data protection authority in your country of residence, the country where you work, or the country in which the alleged unlawful use of your Personal Data occurred.