Website Privacy Notice


The George Washington University is committed to safeguarding and maintaining the privacy of your personal information.  In order for the university to provide our services, it is necessary for us to collect and use (process) personal information of our website visitors. This Privacy Notice describes our practices with regards to the collection and processing of personal information through the university’s websites.

For purposes of clarity, “processing” as used in this notice includes the collection, use, storage, transmission, disclosure, and destruction of personal information. This Privacy Notice applies to all information collected by the university and its third-party service providers (collectively, GW, university, us, or ours), including but not limited to websites and applications that post a link to this Privacy Notice.

By continuing to use and interact with GW websites and by providing GW your personal information, you are accepting the terms of this Privacy Notice.  

Information Collected

In general, GW collects and processes two types of information through its websites: (1) information voluntarily provided by you in order to receive requested information and/or services, and (2) information automatically collected upon your navigation of our websites.

Information You Provide

GW collects information about you when you interact with our websites.  GW processes the information you provide from the devices used when you access our websites, including, for example, when you request information, register an account, log in to the website, submit a test, register for courses, complete a web form, add or update your account information, or otherwise correspond with the university via our websites. 

Information Automatically Collected

When you use GW websites, the university also automatically collects information about the devices you use to visit GW websites, including computers, tablets, and mobile phones.  We automatically collect your device identifier, web browser, IP address, and browsing information collected through cookies and beacons.  GW also automatically collects information about how you use the websites, such as what you have searched for and viewed on the websites.  The information automatically collected will be associated with any personal information you have provided. 

Cookies and Other Technologies We and Our Third-Party Advertising Service Providers Us


We collect information automatically through various means such as “cookies,” and “web beacons.”  

Cookies.  GW’s websites make use of “cookies,” which are small text files placed on your device to keep track of information about your browsing on a website. The utilization of cookies allows GW to enhance your experience by allowing GW to save your preferences. Your decision to set your web browser to accept or disable cookies is a personal choice.  However, without cookies you may not be able to take full advantage of features and functionality of GW websites.  

If you would like more information on how to opt out of cookies, please visit: http://optout.aboutads.info or http://www.youronlinechoices.eu/.

Web Beacons.  GW uses web beacons to collect data from individuals who interact with GW websites. These technologies, which are often small, transparent images, when loaded collect information about the requestor. This could include your IP address, and the date and time a website was accessed.  Web beacons work in conjunction with cookies so if cookies are disabled, we are unable to collect unique information about you.

Processing Your Information


GW processes personal information to achieve the following purposes:

  • Carry out the operations and managing the educational, research and administrative needs of the university and our community
  • Improve our websites and services
  • Respond to your requests or inquiries
  • Provide newsletters, articles, service or safety alerts or announcements, event invitations, and other information that we believe may be of interest to you
  • Request gifts and donations
  • Analyze your use of the GW websites and perform other market research activities, such as interest-based advertising, targeted advertising, and online behavioral advertising in order to determine the content would be of interest to you
  • Comply with legal obligations, enforce our agreements, and protect the health, safety, rights or property of you, us or others; and meeting legal obligations
  • Prevent, investigate and take actions regarding possible fraud, unlawful or criminal activity, other misconduct, security or technical issues, or unauthorized access to or use of personal information, our website or data systems.

GW will process your information consistent with the consent you have provided for a stated purpose, or as necessary (i) for purposes of GW’s legitimate interests, (ii) for performance of a contract with you or to fulfill a request you have made, or (iii) for compliance with a legal obligation.

How GW Uses Your Information

How Information is Shared


GW may share your information with our third-party service providers to provide services or to support the university’s activities.  These activities include, for example, online course support for students, benefit services for faculty and staff, or study abroad and international studies / teaching opportunities.  GW third-party service providers are not authorized to disclose information except as necessary to perform the services on GW’s behalf or to comply with legal requirements. In certain instances, in order to provide services and to support university’s activities, or as required by law, GW may share your information with other departments within GW, other than the department with which you originally shared your information. In all of these instances, the information provided to the third-party or GW department will be limited to the extent necessary to provide the user-requested information and/or services, or as required by applicable law enforcement agencies.

Third-Party Websites and Content


GW websites may contain links to other websites as a convenience to you. These websites may operate independently from GW websites and if you decide to use these links, you will leave the GW website. GW is not responsible for the privacy practices or the content of such other websites and does not make any representations or endorsements about them. If you decide to leave the GW website and access any third-party website, we strongly suggest you review the privacy notices or policies of that third-party website, as GW’s policies will no longer govern. You should review the applicable terms and policies, including privacy and information gathering practices, of these third-party sites.

Your Personal Accounts


Although GW has security measures in place to protect personal information you provided to us, you are encouraged to take steps on your own to protect your information by, for example, logging out of online applications, closing all web browsers after use of a website, and keeping your account and passwords confidential.  You should be aware that any information you post or disclose in news groups, forums, message boards and similar contexts may become public. You should always exercise caution before disclosing any personal information in such contexts.

Retention of Information and Security


Information you provide GW will be retained in accordance with the university’s record retention schedule, applicable laws, or until such time the service requested is no longer available.  The university maintains administrative, technical, and physical safeguards to protect against loss, misuse, unauthorized access, disclosure, alteration, or destruction of the information you provide when visiting or using GW websites.  GW implements appropriate security measures to promote the confidentiality, integrity, and availability of any information in the possession (or control) of GW. GW utilizes Transport Layer Security (TLS) encryption technology for instances where GW websites process your personal information. The purpose of TLS is to protect your information from being viewed by an unauthorized person.  Additionally, some features on GW websites may enable credit card transactions in order for you to purchase goods and services. GW subcontracts the processing of online transactions to third-party services providers that comply with the Payment Card Industry Data Security Standard (PCI DSS).

Rights for Individuals in the European Economic Area (EEA)


If you reside in a member state of either the European Union or European Free Trade Association that is a party to the EEA Agreement (collectively, EU Residents), you have the right to access your personal information the university has collected about you for the purpose of reviewing, modifying, correcting or requesting erasure of your information.  You may also have the right to request a copy of your information.  Further, you may also request that the university restrict or stop processing your information.  Finally, you may object to communications, direct marketing, or automated processing of your personal information.

To the extent applicable, the EU’s General Data Protection Regulation provides further information about your rights. You also have the right to lodge complaints with your national or regional data protection authority.

If you wish to exercise these rights, please contact us at the address included under the “Contact” section, below. To protect the personal information GW holds, the university may also request further information to verify your identity when exercising these rights. Upon a request to erase information, GW will maintain a core set of personal information to ensure we do not contact you inadvertently in the future, as well as any information necessary for archival purposes. We may also retain financial information for legal purposes, including United States Internal Revenue Service compliance. Additionally, in the event of an actual or threatened legal claim, GW may retain your information for purposes of establishing, defending against, or exercising our rights with respect to such claim.

By providing information directly to GW, you consent to the transfer of your personal information outside of the EEA to the United States. Please note that the current laws and regulations of the United States may not provide the same level of protection as the data and privacy laws and regulations of the EEA.

Policies


Below are a number of pertinent policies and procedures implemented by GW related to this policy:

•    Personal Information and Privacy Policy
•    GW Web Content Policy
•    Security Breaches Involving Confidential Personal Information
•    Information Security Policy
•    Records Management Policy
•    Health Information Privacy Policy
•    Privacy of Student Records Policy
•    Social Security Number and GWid Usage Policy

Additional university policies may be found through the Office of Compliance & Privacy website.

Children


If you are a US resident under the age of 13 or an EU Resident and under the age of 16, please do not provide any personal information on this website or through any of its features, unless authorized by parental consent.  For more information, US residents may consult the Children’s Online Privacy Protection Act, and EU Residents may consult the General Data Protection Regulation.  

If you believe that GW has collected personal information about a child, please contact GW immediately, at the address included under the “Contact” section below, so that GW can take appropriate action.

Contact


If you have any questions, concerns or wish to make a report with respect to this Privacy Notice or regarding how GW processes personal information, please contact us at [email protected].

Updates to this Privacy Notice


GW may modify this Privacy Notice from time to time, in its sole discretion.  We recommend you read the Notice periodically. If we make any significant changes to this Privacy Notice that increase the university’s rights to use personal information that we previously collected about you, we will obtain your consent through an email to your registered email address or by prominent posting on the university’s websites.  If GW intends to further process collected personal information for a purpose other than that for which the information was collected, prior to that further processing, the university shall provide you with information on that other purpose with additional information necessary to ensure fair and transparent processing.
 

Updated on January 9, 2019