Naropa University and its subsidiaries, subcontractors, suppliers, website vendors and affiliated companies (“Naropa” or University”) own and operate a number of Internet domains, including but not limited to, the My.naropa.edu and www.Naropa.edu websites (collectively and individually the “Website”). This statement along with the Website Terms and Conditions which are incorporated herein, describe Naropa’s data privacy policies.
Section 1 - Privacy Statement
Section 2 - Kinds of Information Collected
A Website user may choose how much Personally Identifiable Information to provide to us. Information collected online is often defined as being either personally identifiable or anonymous:
Personally Identifiable Information tells us who is using the Website and includes information you may request that we store on the website for your future use. We may need this information to provide a personalized or enhanced service that you request – such as online payments. While we hope that you will find it beneficial to judiciously provide Personally Identifiable Information to Naropa so that we can provide the best practical service to you, the amount of Personally Identifiable Information that you choose to disclose is a decision you make.
Section 3 - Personally Identifiable Information
You may be asked at various times to provide data such as your name, e-mail address, phone number, credit card information, bank account information and address (the “Personally Identifiable Information”), as well as information specific to the service or transactions you are seeking from Naropa. Naropa collects Personally Identifiable Information online primarily for your convenience such as online payments and to make it easier for you to use the Website. It also permits Naropa to communicate with you and improve the Website and our services.
When you surf the Internet, your Internet browser automatically transmits some information to Naropa every time you access our Website. Examples of such information include the URL of the Web page you were just on (known as the “Refer”), the IP (or Internet Protocol) address of the computer you are using, the browser version you are using to access our site, the date and time you access our Website, the pages, files, documents, and links that you visit, and the Internet address of the website from which you linked to this website. Some of this information may be collected by Naropa to help us improve our Website and our services. For instance, we may use this information to ensure the content you request is presented in the best format.
To activate some of the features available within the Website, we may assign “cookies” to your Internet browser. On our system, a cookie is a small text file that contains a unique identification number stored on your computer. This unique identification number automatically identifies your browser to our server computers when you interact with our Website. When you agree to provide Personally Identifiable Information directly to us, we may assign cookies that identify you, personally, to our servers. By setting preferences in your browser, you can refuse to accept cookies, disable cookies, and remove cookies from your hard drive.
Section 4 - Anonymous Profile Information
Section 5 - How Information is Used
If you elect to provide Personally Identifiable Information on the Website, Naropa may use that information for transactions you have authorized, internal research or to correspond with you.
If you correspond with us through letters or email messages, we may store such correspondence with whatever other information you have provided to us. By engaging in transactions with Naropa or submitting correspondence to Naropa, you agree that we may store the relevant information and contact you in response.
In addition to the other uses described in this section, Naropa will use the Personally Identifiable Information you provide to us and information we collect about your use of our Website to improve access to our Website, improve the content and organization of our Website, resolve disputes, and correct technical problems with the Website.
Naropa reserves the right to use such information for any lawful purpose, including but not limited to recruiting, marketing, performance monitoring and statistical analysis. Naropa may also preserve, access, monitor or disclose information containing Personally Identifiable Information and other information, subject to the requirement of federal and state law, in the following situations:
- Preserving information and otherwise responding to requests of law enforcement, federal and state agencies, court ordered disclosure, discovery in litigation and all other compulsory legal processes.
- Naropa business or research.
- To preserve, access, and monitor information, accounts and equipment in the course of an investigation of misconduct, violations of law or violations of University policy by students, faculty or staff.
- As part of assigned responsibilities University staff may have access to all information and are restricted to using it for the purposes associated with the requirements of their position.
- Maintaining networks, auditing networks, and preventing or responding to security breaches.
Section 6 - Distribution of Information to Third Parties
Naropa’s policy is to retain Personally Identifiable Information only for our use. We do not sell your Personally Identifiable Information to third parties. Although we use industry standard hardware and software designed to protect your privacy, we cannot guarantee and you should not expect that the Personally Identifiable Information you submit to us will always remain confidential.
Our server computers may retain whatever Personally Identifiable Information you have provided to us, and such data could potentially be made available for distribution to third parties as required by law, such as to law-enforcement agencies or pursuant to subpoenas or other court orders. Naropa may also share both Anonymous Profile Information and Personally Identifiable Information to investigate allegations of fraud or other unlawful activities, civil offenses, and violations of our Terms and Conditions of Use. In such case, Naropa shall have no obligation to notify you of, or to decline, any appropriately documented request for Personally Identifiable Information or Anonymous Profile Information.
Naropa may also provide both Anonymous Profile Information and Personally Identifiable Information to third parties, such as contractors, service providers, consultants and other agents (“Service Providers”) that provide assistance to our business and the operation and maintenance of the Website. Service Providers with whom we share such information generally are bound by confidentiality obligations, and, unless we tell you differently, our Service Providers do not have any right to use the information we share with them beyond the scope and duration of what is necessary to assist us.
Naropa may also provide both Anonymous Profile Information and Personally Identifiable Information for any purpose with your consent. For example, we may share your information with third parties to whom you explicitly ask us to send your information. If you ask us to release information that we have about you, we will do so if it is reasonable and not unduly burdensome.
Section 7 - Other Websites
Section 8 - Changing your Personally Identifiable Information
To review or change the Personally Identifiable Information you have previously provided to Naropa, please contact the university Registrar at firstname.lastname@example.org.
Section 9 - Family Educations Rights & Privacy Act Notification of Rights
- The right to inspect and review the Student’s Education Records within 45 days of the day the University receives a request for access.
- The right to request the amendment of the Student’s Education Records that the Student believes are inaccurate, misleading, or otherwise in violation of the Student’s privacy rights under FERPA.
- The right to provide written consent before the University discloses personally identifiable information from the Student’s Education Records, except to the extent that FERPA authorizes disclosure without consent.
- The right to restrict Naropa’s use of Student’s Directory Information, which otherwise will be shared freely by the University.
- The right to file a complaint with the U.S. Department of Education concerning alleged failures by Naropa to comply with the requirements of FERPA.
Please see Naropa University’s Family Educational Rights and Privacy Act Policy for information.
Section 11 - SMS Terms of Service
Naropa University uses SMS to communicate with potential and current students on matters relating to acceptance to and attendance of classes at Naropa University. Naropa will also use SMS to reach out to alumni about giving opportunities and campus-sponsored events.
You can cancel the SMS service at any time. Just text “STOP” to the short code. After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to join again, just sign up as you did the first time and we will start sending SMS messages to you again.
If you are experiencing issues with the messaging program you can reply with the keyword HELP for more assistance, or you can get help directly at email@example.com or 1-800-772-6951.
Carriers are not liable for delayed or undelivered messages.
As always, message and data rates may apply for any messages sent to you from us and to us from you. You will receive 5-15 messages/month. If you have any questions about your text plan or data plan, it is best to contact your wireless provider.
Section 12 - General Data Privacy Regulation
This Section is intended to comply with the European Union’s (“EU”) General Data Protection Regulation (“GDPR”) and applies to personal data that Naropa collects or processes about an individual (“Data Subject”) while the Data Subject is located in the European Economic Area (“EEA”) comprised of the EU and the countries of Iceland, Norway, and Lichtenstein, regardless of whether the Data Subject is a citizen or permanent resident of an EEA country. “Personal Data” means any information relating to an identified or identifiable Data Subject.
When subject to the GDPR, Naropa must have a lawful basis to process a Data Subject’s personal data and must do so fairly and in a transparent manner. Also, Personal Data shall be collected for specific, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; limited to what is necessary in relation to the purposes for which they are processed; accurate and kept up to date; retained only as long as necessary; and maintained securely.
Although there will be some instances where the processing of Personal Data will be pursuant to other lawful bases (e.g. processing necessary to protect the vital interests or safety of a Data Subject, processing related to legal action involving Naropa, etc.), Naropa will likely process Personal Data relying on one or more of the following lawful bases:
- Processing for the purposes of the legitimate interests pursued by Naropa or by a third party;
- Processing for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
- Processing for compliance with a legal obligation to which Naropa is subject; and
- Processing pursuant to the consent of a Data Subject for one or more specific purposes.
In addition to the right to receive the information provided in this Privacy Notice, Data Subjects
covered by this Privacy Notice have the right to:
- Request from Naropa access to and rectification or erasure of Personal Data or restriction of processing concerning the Data Subject, the right to object to processing and the right to portability of Personal Data;
- Where processing is based upon consent, to withdraw consent at any time, without affecting Naropa’s right to process Personal Data based upon consent before its withdrawal;
- The right to file a complaint with a supervisory authority appointed by an EU member state for the purpose of receiving complaints;
- Additional notice of the existence of automated decision-making, including profiling;
- If the Personal Data is going to be further processed for a purpose other than that for which it was collected, then notice of the purpose and basis or bases for the further processing;
- If Personal Data is collected for Naropa’s legitimate interests or for a task carried out in the public interest, then the Data Subject has the right to object, on the grounds of his or her particular situation, to the processing of Personal Data concerning him or her (including profiling);
- Where Personal Data are processed for direct marketing purposes, the right to object at any time to processing Personal Data concerning him or her for such marketing; and
- Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her; provided, however, that this right does not apply if the decision is (a) necessary for entering into, or performance of, a contract between the Data Subject and Naropa; or (b) is based upon the Data Subject’s consent.
Note: Exercise of these rights guarantees access to a process but does not guarantee any particular outcome.
Any Data Subject who wishes to exercise any of the above-mentioned rights may do so by filing such request at firstname.lastname@example.org.
Section 13 - Consent
Section 14 - How to Contact Us
2130 Arapahoe Avenue Boulder, CO 80302 (303)444-0202