This Privacy Policy has been developed to help you understand how Florida Global University (hereinafter “FGU”) collects, uses and protects the information they obtain and maintain about you. FGU students and alumni should also review our FERPA Student Right to Privacy Policy, which describes the rights of students with respect to education records held by FGU.
PROTECTING CHILDREN’S ONLINE PRIVACY
Our Sites are not intended for use by persons under the age of 13. If you are a minor between the ages of 13 and 18, you may use our Sites only in the company of a parent, legal guardian or other responsible adult. Any other use by minors is strictly prohibited.
What do we collect and why?
As an educational institution and employer, FGU maintains records of our past, present and prospective students and employees. FGU also has business ties with educational and employment partners and, as such, maintains records of the individuals with whom we work through those partnerships. Information, including personal information, is collected by FGU in various ways at different points in an individual’s interaction with the institution for many possible purposes. The following sections describe in more detail the type of information we hold, and how we may collect and use that information.
How we collect your information
We generally collect information in two ways: (1) when you voluntarily provide it to us, and (2) automatically when you visit or use our Sites.
Voluntary compilation
You voluntarily provide information to us when you choose to use the web forms, electronic applications, chat features and other online communication tools available through our Sites, and when you choose to provide information through your interactions with our student advisors, admissions and financial aid staff and other authorized FGU representatives who conduct university business.
Automatic Collection through Cookies and Other Technologies
We automatically collect information through the use of cookies and other tracking technologies that are part of our Sites. Cookies are small data files that are transferred to your computer or mobile device that allow us to recognize you and pass information about your visit to different sections of our Sites. Most Internet browsers accept cookies by default.
Some third parties that provide information to us may also share your information with other parties. Be sure to read the respective privacy policies of these parties to understand their data collection practices, including how they may use the information they collect from you and their choices for managing the data they share.
Aggregate information
To the extent permitted by applicable law, we may use, process, transfer and store information about individuals on an anonymous (or pseudonymous) and aggregated basis. We may combine personal information with other information collected online and offline, including information from third party sources. We may also use information in other ways with consent. By using our Sites and services, you agree that we are authorized to collect, use, share and store anonymous (or pseudonymous) aggregated data collected through our Sites and services for benchmarking, analysis, research, reporting, machine learning and other business purposes.
How we use the information we collect
In general terms, your personal information will be used by us in order to contact you regarding the information you have requested, together with aggregate information and cookies, and/or to improve our education and other services, our marketing and our Sites. We may store your information in order to communicate with you about educational programs and services offered by our university and to send you updates as they become available. We also use the information we collect to administer our educational programs and conduct other university activities, to provide services to our students, partners and employees, and to make other products and services available to people in the FGU community. From time to time, we may also use the information we collect to notify you about important changes to our Sites or services, new services, educational programs and related offerings that we believe will be of value to you.
Data Retention
At FGU, we believe in maintaining a lasting relationship with the members of our FGU community. Therefore, unless otherwise required by applicable law, we will normally maintain a record for you. To opt out you must request it verbally or in writing to FGU.
Sharing information with third parties
FGU does not sell personal information to third parties for their commercial use. However, we may share information with third parties, including our service providers, partners and affiliates, as indicated below:
- We sometimes use third-party service providers to perform services on our behalf.
- We may share your personal information with affiliated legal entities and among FGU units and departments for purposes and uses that are consistent with this Privacy Policy.
- Partners
- We may share your personal information with our workplace, community and education partners for the purpose of administering programs and services, such as:
- Shared enrollment in courses with other institutions
- Studies at universities abroad
- Online education offerings through virtual platforms
- Partner-sponsored training and events
- Joint research agreements with other universities or entities
- Events with clubs and special interest groups
- Member-sponsored tuition reimbursement or discount programs
- We may share your personal information with our workplace, community and education partners for the purpose of administering programs and services, such as:
- Directory information
- We may also share student directory information as permitted by applicable law. You can find more information about students’ rights with respect to directory information in our FERPA Student Right to Privacy Policy.
How we protect your personal information
To protect personal information from unauthorized access, use and disclosure, FGU maintains an information security program and employs appropriate physical, administrative and technical security measures. FGU periodically performs risk assessments of its information security program and prioritizes remediation of identified security vulnerabilities. However, we cannot guarantee that unauthorized access, use or loss will never occur.
Legally required disclosure
We may disclose personal information we hold about you (for example, to government legal or regulatory authorities or third parties) when we believe disclosure is appropriate to comply with the law; to enforce or apply our Privacy Policy and/or other agreements; or to protect the rights, property or safety of us, users of our Sites or others.
Links to other sites
This Privacy Policy does not apply to third party applications or software that integrate with our services through our Sites, or to any other third party products, services or websites. Please note that once you leave our Sites and enter another website, our Privacy Policy will no longer be in effect. We are not responsible for the privacy practices employed by these sites, or the information or content contained therein.
User-generated content
Some of our Sites and services may allow users to submit their own content for courses, assignments, contests, blogs, videos, chat programs and other features. Unless otherwise noted, please remember that any information you submit or post as user-generated content on the services becomes public information. Please do not disclose your personal, financial or other information in such submissions or postings. We cannot prevent others from using such information in a manner that may violate this Privacy Policy, the law or your personal privacy and security. We are not responsible for the results of such postings.
Accessing our sites from outside the U.S.
If you access our Sites from other countries, including the European Economic Area and Switzerland (collectively the “EEA/CH”) or other foreign countries, and use our Sites or provide us with personal information through our Sites or through your communications with FGU representatives, your information will be treated in accordance with this Privacy Policy. By using our Sites or providing us with your personal information, you acknowledge that your information will be transferred to and processed on servers located in the United States and potentially in other jurisdictions that may not have the same level of data protection as your jurisdiction.
Privacy Policy Updates
As technology, data management and privacy standards continue to change, we may update this Privacy Policy from time to time. Updates, including the revision date, will be posted on this page.
Cancellation and questions
If you no longer wish to receive information by email from FGU, please write to us at: info@floridaglobal.university
DISCLOSURE OF PERSONALLY IDENTIFIABLE INFORMATION
It is FGU’s policy to limit disclosure without the student’s prior written consent, subject to the following limitations and exceptions:
- Directory Information
- This information may be disclosed and may appear in public documents unless a student submits a written notice stating that none or all of the information is to be disclosed (i.e., opted out). Such notice must be filed with the Registrar’s Office.
- No Prior Consent Required
Prior consent is not required for disclosure of education records in a number of circumstances. These circumstances include disclosure:
- To the student.
- To anyone, if FGU has obtained the student’s prior written consent.
- To anyone, in response to a request for directory information, unless the student has opted out.
- To FGU school officials who have been determined to have a legitimate educational interest. They may access the educational records of students within the scope of their job duties.
A school official has a legitimate educational interest if the official:
- Performs a task that has been assigned to him/her as part of his/her duties or job description or contract.
- Performs a task related to the education of a student.
- Performs a task related to a student’s discipline.
- Provides a service or benefit related to the student’s family, such as medical care, counseling, job placement or financial aid.
- To officials of another postsecondary educational institution where the student seeks or intends to enroll, or where the student is already enrolled, if the disclosure is for purposes related to the student’s enrollment or transfer. A copy of the records that have been transferred will be provided to the student upon request and payment of the copying fees described above.
- To authorized representatives of the following governmental entities, if the disclosure is made in connection with the audit or evaluation of federally or state funded education programs, or for compliance with federal legal requirements related to those programs: the U.S. Comptroller General, the U.S. Secretary of Education, the U.S. Attorney General, or state and local education authorities, such as the Florida Commission on Education (CIE), the authority responsible for overseeing FGU education programs.
Subject to applicable federal law, these officials will protect the information received from allowing personally identifiable information about students to third parties.
- To authorized persons and organizations, such as the Department of Veterans Affairs or an employer, in connection with financial aid for which the student has applied or which the student has received, if the information is necessary to determine eligibility for the aid, determine the amount of the aid, determine the conditions of the aid, or enforce the terms and conditions of the aid.
- To state and local officials to whom such information is required to be reported by applicable state law adopted prior to November 19, 1974.
- To organizations conducting educational studies for FGU, or on behalf of FGU, for the purpose of developing, validating, or administering predictive tests; administering student programs; and improving instruction. The studies will be conducted in a manner that does not permit personal identification of students to third parties, and the information will be destroyed when it is no longer needed for these purposes.
- To accreditation organizations to carry out their accreditation functions.
- To either parent of a student who is claimed as a dependent for income tax purposes by at least one parent.
- To parents when their student (under the age of 21) is found to have violated FGU’s alcohol or drug policies.
- To appropriate parties when FGU determines that the disclosure is necessary to protect the health or safety of the student or others and the information will help resolve the emergency.
- In response to a court order or subpoena, including ex parte orders under the USA Patriot Act. Unless the issuing entity directs FGU not to provide prior notice, FGU will make reasonable efforts to notify the student before complying with the court order or subpoena.
- To an alleged victim of a crime of violence where the disclosure is the result of a disciplinary hearing on the alleged perpetrator in respect of that crime.
- To any person requesting the final results of a disciplinary hearing against an alleged perpetrator who has been found guilty of violating FGU’s Student Code of Conduct or FGU’s Sexual Conduct Policies and Procedures related to a crime of violence or a non-forcible sex offense.
3. Prior Consent Required in All Other Cases
- FGU will not disclose in educational records or allow access to those records without the student’s prior consent.
- The consent must be in writing, signed by the student and dated. The consent will remain in effect until the student rescinds it or its purpose is achieved.
- The student must specify the records to be disclosed, the identity of the recipient, and the purpose of the disclosure.
- A copy of the disclosed record will be provided to the student upon request and payment of the copying fees described above.
4. Record of Disclosures
- List Maintenance: FGU will maintain a list of each application and each PII disclosure with each student’s educational records. The list will include:
- the parties that have requested and/or received the information; and
- the legitimate interest that the parties had in requesting and/or receiving the information.
- Inspection of the List: The list of disclosures may be inspected by:
- the student;
- the official custodian of the registry; and
- other FGU and government officials.
- Exceptions
- List Maintenance: FGU will maintain a list of each application and each PII disclosure with each student’s educational records. The list will include:
Disclosures need not be recorded in the following circumstances:
- disclosures to the student;
- disclosures pursuant to written consent;
- disclosures to school officials, including FGU instructional or administrative officials;
- disclosures of directory information; and
- disclosures related to court orders or lawfully issued subpoenas.
RIGHT TO FILE A COMPLAINT
- Students have the right to file a complaint with the U.S. Department of Education concerning alleged failures by FGU to comply with the requirements of FERPA. The name and address of the office that administers FERPA are:
Family Policy Compliance Office U.S. Department of Education U.S. Department of Education 400 Independence Avenue, S.W. Washington, D.C. 20202