Privacy Policy

Purpose

Protecting your privacy and maintaining the accuracy of data Menlo College (Menlo or the College) collects is of paramount importance and obligations the College takes very seriously. This policy applies to all Menlo’s employees, students, contractors, volunteers, and visitors, and is balanced with Menlo’s legal, policy and administrative duties in managing data.

This Privacy Policy applies to the information provided to Menlo and which Menlo maintains when you visit Menlo’s main website, www.menlo.edu, www.mymenlo.edu, other websites Menlo controls, refers to or links to this policy, as well as other information maintained by the College in carrying out its mission. This policy also outlines how this information is processed or used, as well as the choices available to you regarding the use of information you provide to Menlo which Menlo maintains.

Definitions

For purposes of this policy, Personal Data is any information that can reasonably be used to identify you. [1]

Sensitive Personal Data includes special categories of Personal Data (e.g., racial or ethnic origin, citizenship, religious affiliation, genetic data, biometric data, data concerning health, and data concerning a person’s sex life or sexual orientation) for which applicable law provides enhanced protections.

Privacy Principles

Menlo does not collect any more personal data than is necessary to provide services to the campus community;
Menlo uses personal data for improving services provided to the campus community;
Menlo uses your personal data for the purposes specified in this policy, unless agreed otherwise in writing;
Menlo does not keep personal data if it is no longer needed; and
Other than as specified in this policy, Menlo does not sell, rent, or share your personal data with third parties.

Your Rights

Right of Correction –Menlo shall comply with requests to edit and update inaccurate Personal Data promptly
Right to Deletion – Menlo shall delete your Personal Data promptly if:
- It is no longer necessary to retain Personal Data;
- Consent, which formed the basis of Personal Data processing is withdrawn
- An objection to the processing of Personal Data is submitted in writing and there are no overriding legitimate grounds for such processing;
- The Personal Data was processed illegally; or
- The Personal Data must be deleted in order for Menlo to comply with its legal obligations.
Menlo may decline requests for deletion if the processing of Personal Data is necessary to:
- Comply with Menlo’s legal obligations;
- In connection with legal action;
- To detect and monitor fraud; or
- In performing a task in the public interest.

Collecting Data

Menlo does not collect personally identifying information about you when you visit Menlo’s site – www.mymenlo.edu unless you choose to provide such information to Menlo Providing such information is strictly voluntary. This policy is your guide to how Menlo will handle information it learns about you from your visit to this website.

Reading or Downloading – Menlo collects and stores only the following information about you: the name of the domain from which you access the Internet (for example, aol.com, gmail.com, yahoo.com, or menlo.edu if you are connecting from Menlo’s domain, the date and time you access Menlo’s site, and the Internet address of the Web site from which you linked to Menlo’s site. Menlo uses the information Menlo collects to measure the number of visitors to the different sections of Menlo’s site, and to help Menlo make its site more useful to visitors.
Online Profile Updates and Donations – If you complete the Profile update forms during orientation, and share your personally identifying information, this information will be used only to provide you with more targeted content. Menlo may use your contact information to send further information about Menlo or to contact you when necessary. You may always opt-out of receiving future mailing by contacting privacy@menlo.edu.
Sending Menlo an Email – You also may decide to send Menlo personally identifying information, for example, in an electronic mail message containing a question or comment, or by filling out an internal form that provides this information to Menlo. Menlo uses this personally identifying information from email primarily to respond to your requests. Menlo may forward your email to other employees who are better able to answer your questions. Menlo may also use your email to contact you in the future about Menlo’s programs that may be of interest.
Menlo wants to be very clear: It will not obtain personally identifying information about you when you visit Menlo’s site, unless you choose to provide such information to Menlo. Providing such information is strictly voluntary. Except as might be required by law, Menlo does not share any information it receives with any outside parties.

Data Subject Rights

You have certain rights with respect to your Personal Data. Menlo takes reasonable steps to ensure your Personal Data is relied upon for its intended use, is accurate, complete, and up to date. If you wish to contact us directly about accessing, correcting, updating, or deleting your personal data, or altering your Personal Data, you may do so at any time by contacting privacy@menlo.edu. Menlo shall consider your request in accordance with applicable laws.

You may also object to processing of your Personal data, ask to restrict processing or your Personal Data, or request portability of your Personal Data by contacting privacy@menlo.edu.

Similarly, if Menlo has collected and processed your Personal Data with your consent, you may withdraw your consent at any time by contacting privacy@menlo.edu. Withdrawing your consent will not affect the lawfulness of any processed conducted prior to your withdrawal, nor will it affect the processor of your Personal Data conducted in reliable on lawful processing notwithstanding the absence of consent.

Privacy Requests and Authentication

Menlo responds to all requests received from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Menlo may ask you to verify your identity in order to help Menlo respond efficiently to your request. Menlo will only use Personal Data provided in an opt-out request to review and comply with the request.

Non-Discrimination and Non-Retaliation

Menlo shall not discriminate or retaliate against anyone for exercising their rights under this policy.

Use of Cookies on Menlo.edu

Menlo College uses cookies and tracking technologies on its website to improve functionality and analyze visitor behavior. Cookies may have unique identifiers and reside, among other places, in your device, in emails Menlo sends to you and on Menlo’s website.

Menlo uses cookies to collect and use data such as IP addresses, visited pages, and browser details. These cookies enable features such as login and more convenient access to the MyMenlo portal. Cookies are usually only set in response to actions taken by users which amount to a request for services, such as setting your privacy preferences, logging-in, or filling-in forms. Users can manage their browser settings to limit the use of cookies, but disabling cookies entirely may negatively affect certain site functions.

Menlo’s website uses cookies during on-line sessions for certain legitimate business interests, which may include delivering content specific to your interests, collecting the domain name of the service which you are visiting, and providing Menlo with information about the site’s performance. Cookies also allow Menlo to avoid showing the same ad or other message repeatedly. Cookies enable Menlo to relate your use of the site to information that you have specifically and knowingly provided to Menlo’s website. Menlo College does not store or share cookies externally, nor does it allow second-party or third-party cookies to be placed on Menlo.edu.

You may control and/or delete cookies as you wish For details, including how to prevent your browser from accepting cookies or how to disable cookies, see https://www.onsulter.ft.gov/articles/0042-online-tracking or contact privacy@menlo.edu.

Legal and Regulatory Compliance

Menlo College complies with the Family Educational Rights and Privacy Act (FERPA), which prohibits educational institutions from releasing most education records without student consent.

Citizens of the European Economic Area (EEA) have additional rights regarding the use of and access to their own personal data, under the provisions of the European Union’s General Data Protection Regulation (GDPR), and California residents have additional rights when dealing with larger, profit-making entities in this state, under the California Consumer Privacy Act (CCPA). Because Menlo College is neither located in the EEA nor is it a profit-making enterprise, Menlo is not legally required to conform to either of these policies, but Menlo nevertheless pledges to do its best to respect them.

Requests for Information

Menlo shall comply with all reasonable requests for information, subject to legal obligations and legitimate interests. Any request for student information should be forwarded to registrar@menlo.edu. Menlo will not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If Menlo determines that the request warrants a fee, it will tell you why that decision was made and provide you with a cost estimate before completing your request.

If you have questions about FERPA, GDPR, or CCPA, or if you wish to contact Menlo in connection with the exercise of your own privacy rights, please contact privacy@menlo.edu. Menlo cannot respond to your request or provide you with Personal Data if it cannot verify your identity or authority to make and request and confirm the Personal Data relates to you. Requests made through your password protected account sufficiently verified when the request relates to Personal Data associated with that particular account shall be processed. Menlo will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Please note that, in certain circumstances, Menlo may not be able to delete your Personal Data without also deleting your user account. Menlo may be required to retain some of your Personal Data after you have requested deletion, to satisfy its legal or contractual obligations. Menlo may also be required by applicable laws to retain some of your Personal data to satisfy its business needs.

Menlo shall respond to your written request without unreasonable delay and in accordance with any deadlines imposed by law. Unless Menlo notifies you at the time of your request, it will not charge you any fee in connection with the exercise of your rights.

Right to Appeal

If you have any concerns about the policy or the way in which Menlo processes your Personal Data, please contact privacy@menlo.edu.

Policy Changes

Menlo intends this policy to be a general statement and may be subject to more specific privacy notices that pertain to personal information related to specific departments or functions at Menlo. Likewise, Menlo reserves the right, at our discretion, to change, modify or remove portions of this policy at any time. Please check this policy periodically for changes.

Examples of the Types of Information that may be Collected

Menlo College uses email and web links to respond to questions or comments directly. Occasionally, our website includes links to external resources for convenience. These external sites are not controlled or endorsed by Menlo College and may have their own privacy policies or none at all. When you access or use Menlo’s sites, it may collect and process the following information from you.

Purpose of Processing	Categories of Personal Data	Legal Basis
As part of the undergraduate and graduate admissions process, Menlo collects applicant Personal Data to evaluate applications. Menlo also may obtain Personal Data from third parties, such as other schools, references, family members, and education partners (e.g. FAFSA) as part of the application package	Name, address, contact details, race/ethnicity, demographic information, educational history, testing history, and other relevant information as part of the application process	Necessary to evaluate candidates for admission and for internal statistical and analytics purposes Consent: Processing of Sensitive Personal Data for purposes stated above
To evaluate and determine whether financial aid opportunities are available to an applicant	Name, address, contact details, demographic information, salary history, tax forms, and other relevant information to evaluate financial aid eligibility and opportunities	Necessary to evaluate whether the applicant is eligible to receive financial aid and for our internal statistical and analytics purposes Consent: Processing of Sensitive Personal data for purposes state above
To enroll in wellness programs	Name, ID	To identify eligible individual interested in participating in a variety of wellness programs, courses, activities, facilitate enrollment and communications about the programs Contract: Waiver or contract for participation includes personal data in order to process
To process employment applications	Name, ID, demographic information, resumes	For individuals interested in employment opportunities and in order to process applications
To process visa applications	Name, demographic information, financial information, passport number, USCIS information	US Government legal requirements
To support course registration	Name, ID, contact information	Necessary for students, staff, faculty and administration as appropriate for the courses or classes
To process requests for housing and dining services	Name, ID, contact information	Facilitates housing requests and meal plans
To provide online/hybrid training, academic courses and educational programs when necessary	Name, ID, contact information, demographic information, platform usage and interaction, student provided data and content	Facilitates provision, administration, instruction, and quality improvement of platform use, courses, learning, and teaching/instruction to students, staff, faculty members, as appropriate for the courses and classes
To enroll interested individuals in research opportunities	Name, contact information	Upon request from students and faculty, information informs candidates about research opportunities
To process student worker assignments	Name, contact information	Upon request from students, faculty, administration and third party vendors, information informs candidates about opportunities
To submit requests for services (e.g., IT, helpdesk, helpline, Safety & Security)	Name, ID, contact information	To process service requests from students, staff and faculty; to gather metrics regarding use of services Contract: If a contract governs use of the services, personal data is processed pursuant to that contract
Website account information	Name, contact information, relationship to college	For websites that require registration for access, to facilitate the registration
Travel sites	Name, ID, contact information, passport number, emergency contacts	To facilitate travel arrangements and coordination for students, faculty and staff through college programs Contract: If there is a contract governing use of travel sites, personal data is processed pursuant to that contract
To request and receive donations, and assess donor and prospective donor giving activities	Name, contact information, demographic and biographic information, education records, employment information, affiliation with the college, giving history, payment information	To college and process donations/gifts anddonor and prospective donor information
To receive brochures or other information	Name, contact information	To send brochures or other requested information
To purchase tickets to campus events	Name, ID, contact information	To process ticket payment for a variety of events
For campus event registration	Name, ID, contact information	To process registration for sports, cultural, educational and other university events
To purchase parking passes and permits	Name, ID, contact information	Contract: to facilitate payments for parking passes and permits

[1] Personal Data does not include:

• Publicly available information from government records;
• Lawfully obtained, truthful information that is a matter of public concern;
• Deidentified or aggregated consumer information or information specifically excluded from the scope of applicable data protection laws such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Family Education Rights and Privacy Act (FERPA); and
• Clinical trial data or other biomedical research study or Personal Data covered by certain sector-specific privacy laws including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), and the Drivers Privacy Protection Act of 1994.

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