The Ex-Students' Association of the University of Texas
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Last Updated: May 15, 2020
and how you can contact us if you have any questions or concerns. It is our sincere hope that by explaining our data handling practices we will develop a trusting and long-lasting relationship with you.
For the purposes of the EU General Data Protection Regulation 2016/679 (the “GDPR”), Texas Exes is the data controller. This means that we are responsible for deciding how we use the information that we hold. We are a 501(c)(3) non-profit organization registered in the United States with an office at 2110 San Jacinto Boulevard, Austin, TX 78712.
The GDPR applies to you if you reside in the European Economic Area (an “EEA Resident”)
This policy describes the types of information we may collect from you or that you may provide when you access or use any of the Sites, the other Texas Exes Services or other features, functions, services products and our practices for collecting, using, maintaining, protecting and disclosing that information.
This policy applies to information we collect or may collect:
- In accessing and using any of the Sites and the other Texas Exes Services.
- In becoming a member of Texas Exes.
- In signing up for HookedIn.
- In accessing and using HookedIn.
- In email, text, and other electronic messages sent through or use of any of the Sites and the other Texas Exes Services.
- From UT through the integration with the database that we manage and control on behalf of UT and which UT has access to (the “Database”).
- When you interact with other users of the Texas Exes Services.
- When you send any content through any of the Sites or any of the other Texas Exes Services.
- Through services provided to us or you by our affinity partners, third-party companies, agents, or contractors.
It does not apply to information collected by:
- Us offline or through any other means, including on any other website operated by Texas Exes, UT, any chapters or affiliates of Texas Exes or any third party; or
- Any third party, including through any application or content (including advertising) that may be accessible from or on any of the Sites or any of the other Texas Exes Services.
None of the Texas Exes Services are intended for minors under 13 years of age. No one under age 13 may provide any information on or through any of the Sites or the other Texas Exes Services. We do not knowingly collect personal data from children under 13. If you are under 13, do not use or provide any information on or through any of the Texas Exes Services or any of its features or register on the Sites use any of the interactive or public comment features of any of the Texas Exes Services or provide any information about yourself to us, including your name, address, telephone number, email address or any screen name or user name you may use. If we learn we have collected or received personal data from a child under 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
We collect or may collect several types of information from and about you and other users of the Sites and the other Texas Exes Services, including:
- Information by which you may be personally identified, including personal data such as your full name, address, birthdate, and email address (“personal data”);
- Information from your LinkedIn account if you sign-up for HookedIn using your LinkedIn account;
- Financial and billing information, including credit card information;
- Analytics information;
- Information that is about you but individually does not identify you, such as IP address and date and time of visit;
- Usage details and information, including how you communicate with other users of the Texas Exes Services;
- Information contained in the comments and postings on or through any of the Texas Exes Services;
- Device, internet and mobile information such as the hardware model, operating system version, unique device identifiers, browser type, language, wireless network, and mobile network information (including the mobile phone number);
- Geo-location information when you use any of the Sites and the other Texas Exes Services;
- Information that you provide by registering or filling in forms or applications on or through any of the Sites and the other Texas Exes Services;
- When you report a problem with any of the Sites or any of the other Texas Exes Services;
- Records and copies of your correspondence (including email addresses) if you contact us;
- Details of transactions you carry out through any of the Sites and any of the other Texas Exes Services; and/or
- Your search queries on or through any of Texas Exes Services.
We collect this information:
- Directly from you when you provide it to us.
- From the US Postal Services when we receive notices of address changes.
- Automatically as you navigate through or use any of the Sites and the other Texas Exes Services.
- From UT.
- From third parties, such as our members, affinity and business partners and other third parties that provide us or you with certain services.
Certain web transactions may also involve you calling us or our calling you. Please be aware that we may monitor and in some cases record such calls for staff training or quality assurance purposes.
You may now or in the future participate in discussion boards, chat rooms and/or provide comments, pictures, audio and video recordings, text, data, information and other input or any other content linked, posted, and/or submitted by you or other users to be published or displayed (hereinafter, “posted”) on or through any of the Sites or the other Texas Exes Services, or transmitted to third parties or other users of, the Texas Exes Services (collectively, “User Content”). Your User Content is posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Sites or the other Texas Exes Services, with whom your User Content is shared. Therefore, we cannot and do not guarantee that your User Content will not be viewed, downloaded or shared by unauthorized persons.
We take every reasonable step to limit the volume of your personal data that we process to what is reasonably necessary.
We do not Engage in Automated Decision-making without Human Intervention
We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.
Consequences of not providing Personal Data
You are not required to provide all personal data identified in this policy to use any our Sites or to interact with us offline, but certain functionality will not be available if you do not provide personal data. In addition, if you do not provide the personal data, we may not be able to respond to your requests, provide the Texas Exes Services, or provide you with marketing that we believe you would find valuable.
The technologies we use for automatic data collection may include:
- Pixels and Tags. Pixels and tags are site instrumentation tools that help us to determine, for instance, whether a page has been viewed or not and, if so, how many times. Emails or electronic newsletters we send may use tools (e.g., pixel tags or web beacons) to gather email metrics and information to improve the reader’s experience such as how many of the emails are opened, if they were printed or forwarded, the type of device (e.g., mobile or PC) from which they were opened, and the associated member account details, which include name, city, state, and county associated with the applicable IP address. In general, any electronic image viewed as part of a webpage, including an ad banner, can act as a web beacon.
- Session Logs. Session logs help us determine how people travel through the Sites. In this way, we can structure our pages so that the information most frequently visited is easier to find. By tracking page visits, we can also determine if the information we are providing is being used. The only data gathered is the Internet Protocol (IP) address from which you came (which contains no personal data), the website that referred you, the pages you visited and the date and time of those visits.
Do Not Track Policy
Your web browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. We honor any web browser “Do Not Track” signals or other mechanisms that provide you with the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time and across third-party websites or online services.
Third-party Responsibilities and Services
We may use or partner with Texas Exes chapters, affiliate partners and other third-parties, agents or contractors for various purposes in connection with our business and operations (collectively, “Service Providers”), including, credit card and deposit services, the platform that powers HookedIn, insurance services, travel services, the UT rings, relationship building, the marketing and growth of Texas Exes, the awarding of scholarships, volunteer programs and the performance of services on our behalf, such as gathering and analyzing information and the provision of services to you. In the course of performing these responsibilities and providing such services, these other companies may have access to your personal data. We may also share information, including your personal data, with these Services Providers in order to enable them to perform these responsibilities and to provide these services. Many Services Providers have adopted their own privacy policies, which are not subject to control by Texas Exes. You should always review the policies of these Service Providers to make sure that you are comfortable with the ways in which they collect, use, maintain, protect and disclose your information. We do not list our current Service Providers because they change from time to time. If you would like the names of any of Service Providers, please email us at email@example.com.
Service Providers that have access to your personally identifiable information in connection with providing services are required to keep your personal data confidential and are not permitted to use this personal data for any purpose other than to fulfill the services they are performing for Texas Exes or the Sites.
The Service Providers may also transmit cookies to your computer or device, when you click on ads that appear on or through the Service. Also, if you click on a link to a third-party website, such third party may also transmit cookies to you and we do not have any control over that. Please be aware that cookies placed by third parties may continue to track your activities online even after you are no longer using any our Services, and those third parties may not honor “Do Not Track” requests you have set using your web browser.
Use of Remarketing with Google Adwords, Google Analytics, and other Remarking and Analytic Services
We use or may in the future use a variety of remarketing and analytic services including:
DoubleClick: We use “Google AdWords” remarketing codes to log when users view specific pages or take specific actions on the Sites. This allows us to provide targeted advertising in the future. If you do not wish to receive this type of advertising from us in the future you can opt out using the DoubleClick opt-out or the Network Advertising Initiative opt-out.
You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.
How We Use Your Information
- Where the use of your information is necessary for the performance of a contract we are about to enter into or have entered into with you;
- Where the use is necessary for the purposes of our legitimate interests (or those of a third party);
- Where we need to comply with a legal or regulatory obligation; or
- Where you have given your consent (which can be withdrawn at any time).
We use information that we collect about you or that you provide to us for the following purposes:
- To provide you the Texas Exes Services and the content and the other products and services that you request from us.
- To provide the Sites and their content to you.
- To confirm your identity in connection with the use of the Texas Exes Services.
- To update the database that is managed and controlled by us and which UT has access to.
- To process and complete transactions and send you related information, including the request for and the provision of the Texas Exes Services.
- To locate events and Texas Exes chapters near you.
- To provide technical and other support to you.
- To send you promotional communications, such as providing you with information about services, features, surveys, newsletters, offers and events; and providing other news or information about us, UT, our members and our select partners, provided you have given your consent if required by applicable law.
- To enable Service Providers to perform certain responsibilities and provide certain services in connection with our business and operations.
- To fulfill any other purpose for which you provide it.
- To provide you with notices about your account.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to any of the Sites and the other Texas Exes Services.
- To allow you to participate in interactive features on or through any of the Texas Exes Services.
- To enhance the safety and security of all of the Texas Exes Services.
- To verify your identity and prevent fraud or other unauthorized or illegal activity.
- To enable marketing, remarketing and targeted advertising and similar services from us or Service Providers, including direct and indirect marketing and on-line behavioral advertising regarding our own and third-party products and services that we believe may be of interest to you, including advertisement on third party websites, provided you have given your consent if required by applicable law.
- To contact you about promotional offers, marketing programs, or communications from Texas Exes, UT, and the Service Providers with which Texas Exes has a partnership to provide certain services and products for our members, including affinity credit cards and other insurance, travel and financial products and services, provided you have given your consent if required by applicable law.
- To perform targeted and other advertising on third party websites.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
Some of the information that we collect automatically is statistical data and does not include personal data, but we may maintain it or associate it with personal data we collect in other ways or receive from third parties or you provide to us. It helps us to improve the Sites and the other Texas Exes Services, and to deliver a better and more personalized service, including enabling us to:
- Estimate our audience size and better understand usage patterns.
- Store information about your preferences, enabling us to customize the Sites according to your individual interests.
- Speed up your searches.
- Recognize you when you return to any of the Sites.
Compliance with Laws
Texas Exes’ use of any personal data and other information shall be in accordance with all applicable laws, including all privacy laws and the Family Educational Rights and Privacy Act (as amended from time to time, “FERPA”).
Storage and Transfer of Your Information
We may store any data or information that we collect (personal or otherwise) ourselves or in databases owned and maintained by us, our chapters and affiliates, agents or Service Providers.
If you access or use any of the Sites or any of the other Texas Exes Services outside of the United States, information that we collect about you may be transferred to servers inside the United States and maintained indefinitely, which may involve the transfer of information out of countries located in the European Economic Area and other parts of the world unless otherwise prohibited by applicable law or agreed by Texas Exes and you. By allowing Texas Exes to collect information about you, you consent to such transfer and processing of such information without restriction. We may also store some information locally on your computer or other devices. For example, we may store information as local cache so that you can open any of the Sites and view content faster.
Although users from all over the world may access and use the Sites and the other Texas Exes Services, keep in mind that no matter where you live or where you happen to use our services, you consent to us processing and transferring information in and to the United States and other countries whose data-protection and privacy laws may offer fewer protections than those in your home country.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
- To UT.
- To our chapters and affiliates.
- To other users in your organization in connection with any of the Texas Exes Services.
- To Service Providers we use to support our business as more particularly described in the Third-party Responsibilities and Services provision above.
- To a potential or actual buyer, assignee or other successor (including its related advisors and agents) in the event of a divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Texas Exes' assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by Texas Exes about members and users of any of the Sites is among the assets that may be or are actually transferred.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal data:
- To comply with any court order, law or legal process, including to respond to any government or regulatory request.
- To enforce or apply the Terms and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Texas Exes, UT, our members or others.
Choices About How We Use and Disclose Your Personal Data
We strive to provide you with choices regarding the personal data you provide to us. We have created mechanisms to provide you with the following control over your personal data:
- Promotional Offers from Texas Exes. If you do not wish to have your email address/contact information used by Texas Exes to promote our own or third parties' products or services, you can opt-out through your profile page or by emailing us at firstname.lastname@example.org. subject o the terms of the GDPR, this opt out does not apply to information provided to Texas Exes as a result of a service or product purchase, product service experience or other transactions.
We do not control third parties' collection or use of your information to serve interest-based advertising. You may be able to opt out of receiving personalized advertisements from companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance's Self-Regulatory Principles for Online Behavioral Advertising. For more information about this practice and to understand your options, please visit: http://www.aboutads.info and http://www.networkadvertising.org/choices/. You may also use TRUSTe's Preference Manager at http://preferences-mgr.truste.com.
Our Legal Bases for Handling Your Personal Data
GDPR and the laws in some other jurisdictions require companies to tell you about the legal bases that they rely on to use or disclose your personal data. To the extent that those laws apply, we rely on the following legal grounds to process your personal data:
- Performance of a contract: In most cases, we collect and use your personal data and other information to meet our obligations under a contract to which you are a party or pursuant to which we are providing services to you. For example, when you use any of the Texas Exes Services, we will use your personal data to respond to your requests and to provide you with these services.
- Legitimate interests: We may use your personal data information for our legitimate interests on the grounds that it furthers our legitimate interests in commercial activities (but only to the extent that such interests are overridden by the interests or fundamental rights and freedoms of the affected individuals) including:
- Analyzing and improving the Texas Exes Services and our business
- Providing the services pursuant to our contracts with our clients
- Legal compliance: We may use and disclose personal data in certain ways to comply with our legal obligations under European or Member State law or other applicable law.
- Consent: To the extent required by law, and in certain other cases, we handle personal data on the basis of implied or express consent.
Accessing and Correcting Your Personal Data
You may change, correct or delete any personal data that you have provided to us through your subscriber profile page or by emailing us at email@example.com. We may not accommodate a request to change personal data or other information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you delete your User Content from any of the Texas Exes Services (including any User Content stored in the cloud), copies of your User Content may remain viewable in cached and archived pages, or might have been copied or stored by other users of the Sites or the other Texas Exes Services. Proper access and use of information provided on or through any of the Texas Exes Services, including User Content, are governed by the Terms.
Your California Privacy Rights
California Civil Code Section §1798.83 permits users of any of the Sites or any of the other Texas Exes Services that are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org or write to us at: Ex-Students' Association of The University of Texas, P.O. Box 7278, Austin, TX 78713.
European Privacy Rights for EEA Residents.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your personal data) if we intend to use your personal data for such purposes or if we intend to disclose your personal data to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal data. You can also exercise the right by contacting us directly.
In certain circumstances, you have the right to: (a) request access to any personal data we hold about you and related data, (b) obtain without undue delay the rectification of any inaccurate personal data, (c) request that your personal data be deleted provided that the personal data is not required by us for (i) compliance with a legal obligation under European or Member State law or other applicable law or (ii) the establishment, exercise or defense of a legal claim, (d) prevent or restrict processing of your personal data, except to the extent processing is required (i) to comply with a legal obligation under European or Member State law or applicable law or (ii) for the establishment, exercise or defense of legal claims; and (e) request transfer of your personal data directly to a third party where this is technically feasible.
If you are an EEA Resident in France, you also have the right to set guidelines for the retention and communication of your personal data after your death.
If you reside in a jurisdiction other than the European Economic Area, you may also have similar rights to the above. Please contact us at email@example.com if you would like to exercise one of these rights, and we will comply with any request to the extent required under applicable law.
You can exercise any of these rights by contacting us at firstname.lastname@example.org or write to us at: The Ex-Students' Association of the University of Texas, P.O. Box 7278, Austin, TX 78713.
How Long We Store Your Personal Data
We will only retain your personal data, in a form which permits us to identify you, for as long as necessary to fulfil the purposes we collected it for. We will retain and use your personal data as necessary to satisfy any legal, accounting or reporting requirements, to resolve disputes or to enforce our agreements and rights. After that, we will either securely delete or anonymize your personal data so that it cannot be linked back to you.
We understand that the security of your personal data is important. We provide reasonable administrative, technical, and physical security controls to protect your personal data. However, despite our efforts, no security controls are 100% effective and Texas Exes cannot ensure or warrant the security of your personal data. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Sites.
The safety and security of your data also depends on you. Where we have given you (or where you have chosen) a password for access to and use of certain parts of the Sites and/or the other Texas Exes Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of any of the Texas Exes Services. The information you share in public areas may be viewed by any user of the Sites.
© Copyright The Ex-Students' Association of The University of Texas 2020