Privacy & Security Notice

This privacy notice describes how Howard University, 2400 Sixth Street NW, Washington, DC 20059 (“Howard” or the “University”), collects, uses, discloses, and otherwise processes personal information about you from Howard University websites and mobile applications (the “Services”) included within the list maintained by the Office of University Communications, and it describes your rights relative to this personal information.

Personally identifiable information is information, or a combination of pieces of information, that could reasonably allow you to be identified or be associated with you.

This notice describes the following:

• Information the University Collects and Uses
• How the University Uses Your Information
• Cookies
• Who Has Access to Your Information
• How To Exercise Your Rights
• How Your Information is Protected
• International Transfers of Information
• How to Contact The University
• Changes to The Privacy Notice

Information the University Collects and Uses

Howard University collects personal information about you from a variety of sources, including information the University collects directly from you when you enter a search term or submit information using a form on the Services; information the University generates about you in the course of its relationship with you (e.g., data collected from cookies and similar technologies); and information the University may collect about you from other sources, including commercially available sources, such as public databases, where permitted by law.

Please note that the University may be required by law to collect certain personal information about you, or as a consequence of any contractual relationship the University has with you. Failure to provide this information may prevent or delay the fulfillment of contractual obligations.

Information the University Collects Directly From You

The categories of personal information that Howard could collect directly from you include:

1. (a) Personal details (e.g., name, age, gender, date of birth).
2. (b) Contact details (e.g., phone number, email address, postal address).
3. (c) Authenticating information (e.g., username, password, security questions, and answers).
4. (d) Transaction details (e.g., when you make purchases or donations, or when you respond to offers).
5. (e) Financial information (e.g., your payment card or payment account information used for purchases, donations, or other payments).
6. (f) Communications (e.g., when you participate in polls or surveys, write a review or contact the University with a question, comment or request).
7. (g) Photographs of you.
8. (h) Content you submit (e.g., your posts and comments including text, links, images, and videos).
9. (i) Information about your family/guests (e.g., names of relatives or guests who may be attending an event or tour).
10. (j) Information about your interests and preferences (e.g., those related to housing, academic and extracurricular activities, and philanthropic interests).
11. (k) Information collected for application to Howard-sponsored programs or opportunities.

Information Generated by the University

In some cases, Howard generates the following categories of personal information about you in connection with your use of the Services:

1. (a) Records of Howard’s interactions with you.
2. (b) Internal notes (e.g., notes about your inquiry into Howard’s programs and services).

Information the University Automatically Collects

When you visit or interact with the Services, Howard automatically collects certain personal information about you over time and across different websites, including through the use of “cookies” and similar tracking technologies. Cookies are small text files that the Services save on your computer, using your web browser, and access when you return to the site. Howard automatically collects the following categories of information in this context:

1. (a) Technical data collected from your computer or mobile device (e.g., your IP address, browser type, operating system).
2. (b) Information about your usage of the Services (e.g., the pages you visit, the search terms you enter on the Services, how often you visit the Services, and the pages you access before and after accessing the Services).
3. (c) Information that Howard generates about you as a result of your use of the Services (e.g. the University’s understanding of your interests as a result of your use of the Services, whether you are a regular or occasional user of the Services)

For more information about cookies and how the University uses them on the Services, please refer to the Cookies section below.

Information the University Obtains From Other Sources

Howard may receive information about you from other sources, including from third parties, and combine that information with other information the University has about you. The following are examples of the categories of personal information Howard collects from other sources:

1. (a) Personal details (e.g., name, date of birth).
2. (b) Contact details (e.g., phone number, email address, postal address).
3. (c) Details about advertising preferences (e.g., products purchased, interaction with online advertisements).

Sensitive Information

Some of the categories of personal information that the University may collect are considered “special categories of personal data” under European Union law, and they are considered particularly sensitive. Specifically, Howard may process the following types of sensitive information:

1. (a) Information about your racial or ethnic origin.
2. (b) Information about your religious or philosophical beliefs.
3. (c) Information about your sexual orientation or gender identity.
4. (d) Health and medical information (e.g., information about disabilities and related accommodations and food allergies or other dietary restrictions, for purposes of event planning and participation).

How the University Uses Your Information

Howard uses your personal information for the following purposes:

• Identification and Authentication: Howard uses your identification information to verify your identity when you access and use the Services and to ensure the security of your personal information. This is so the University can comply with its contractual obligations to you.
• Operating the Services: Howard processes your personal information to provide the Services. This is so the University can comply with its contractual obligations to you.
• Improving the Services: Howard analyzes information about how you use the Services to provide an improved experience for users of all Howard’s Services, including product testing and site analytics. It is in the University’s legitimate business interests to use the data provided for this purpose, so the University can understand any issues with the Services and make improvements.
• Communicating With You: Howard uses your personal information when it communicates with you, for example, if you contact the University with questions during the application process; or for sending you Howard newsletters and publications. It is in Howard’s legitimate interests that it is able to provide you with appropriate responses and provide you with notices about the Services.
• Marketing: Howard uses your personal information to build a profile about you and place you into particular marketing segments in order to understand your preferences better and to appropriately personalize the marketing messages Howard sends to you. This may include sending you information about the University, or information about fundraising campaigns, events, and volunteer opportunities that may be of interest to you. It is in Howard’s legitimate interest to provide more relevant and interesting advertising messages. Where necessary and in compliance with regulatory requirements, Howard will obtain your consent before sending such marketing messages.
• Conducting Surveys: Howard may conduct surveys to learn more about prospective or current students, alumni, and other supporters. This is necessary to serve Howard’s legitimate interests in its admissions and recruiting efforts and its interests in fundraising, alumni relations, and donor outreach.
• Exercising Howard’s Rights: Howard uses your personal information to exercise its legal rights where it is necessary to do so, for example, to detect, prevent and respond to claims of fraud, claims of intellectual property infringement, or violations of law, Howard’s standards of ethical conduct, University Policies, or Terms of Use.
• Complying With Howard’s Obligations: Howard processes your personal information to, for example, carry out fraud prevention checks or comply with other legal or regulatory requirements, as required by law.
• Customizing Your Experience: When you use the Services, Howard uses your personal information to improve your experience with the Services, such as by providing interactive or personalized elements on the Services with content based on your interests. It is in Howard’s legitimate interests to provide you with a customized experience.
• For Purposes of Program Planning and Development: This is necessary to serve Howard’s legitimate interests in the efficient management and administration of Howard’s academic programs and extracurricular activities.
• Keeping Howard’s Records Accurate and Current: This is necessary to comply with legal obligations and to serve Howard’s legitimate interests in efficient management and administration.

Howard may also anonymize your personal information in such a way that you may not reasonably be re- identified by Howard or other parties, and Howard uses this anonymized information for any purpose.

How the University Uses Sensitive Information

• Information revealing an individual’s racial or ethnic origin, religious or philosophical beliefs, or sexual orientation. To the extent Howard processes this type of sensitive information, such information is voluntarily disclosed for purposes of statistical reporting related to diversity or for purposes described at the time you provide consent. Howard relies on your express consent for such processing.
• Health and medical information. Howard processes health and medical information to comply with obligations under social protection laws, for example to provide disability accommodations; or where not required by law, in reliance on your express consent, for example to accommodate the dietary or other needs of Howard’s alumni and other supporters.

Cookies

When you use or access the Services, Howard automatically collects certain information about your device and use of the website. To do so, Howard uses “cookies” and other device-identifying technologies, such as text files, that may be saved onto your computer and allow an analysis of your use of the website. You can read more about the types of cookies Howard uses, why it uses them, and how you can exercise your choices related to Cookies below.

What are cookies?

The term “cookies'” refers to all technologies that store and access information on the device that you use to access the Services, such as your computer, tablet, or mobile phone. For example, Howard uses http cookies, which are small data files, typically made up of numbers and letters, that are downloaded when you access the Services and allow Howard to recognize your device. Howard also uses technology like pixel tags and software kits embedded in the Services.

Howard and third parties will also use cookies that allow Howard to analyze trends, administer the Services, understand how visitors are using the Services, collect demographic information about site visitors as a group, and optimize Howard’s marketing efforts to provide ads that are relevant to your interests. Howard may report on this information at the aggregate or individual level.

There are different types of cookies, for example:

• Cookies served directly by Howard, “first party cookies,” and cookies served on its behalf, for example, by advertisers and data analytics companies, “third party cookies.”
• Cookies that endure for different periods of time, including those that only last as long as your browser is open, referred to as “session cookies”. These are deleted automatically once you close your browser. Other cookies are “permanent cookies,” meaning they survive after your browser is closed. For example, these cookies recognize your device when you open your browser and browse the internet again.

 

Information the University Collects via Cookies

Generally speaking, most of the personal information Howard collects about you as an individual is provided through form submissions. But there are some cases where the University obtains certain information from cookies. This includes information such as:

• Unique identification tokens to enable live chat sessions across pages and other features.
• Information about your current browsing session, for example the IP address, browser type, internet service provider, referring/exit pages, operating system, data/time stamp, and/or clickstream data.

Our Services use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies to help Google and Howard analyze how visitors use the Services. Information generated by the cookies about your use of the Services, including your IP address, is transmitted to and stored by Google on servers in the United States. Google uses this information for the purposes of evaluating your use of the Services and compiling reports on user activity for Howard and other Google customers. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Per our agreement with Google, it will not associate your IP address with any other data held by Google.

The Services may engage third party advertising platforms that collect information about users across networks in order to serve advertisements of particular relevance to you.

Howard or third parties operating the ad-serving technology may use demographic and geo-location information as well as information logged from your hardware or device to ensure that relevant advertising is presented via the Services. Howard or third parties may collect and use information from you for such purposes, including but not limited to your IP address, Device ID, MAC address, installed software, application usage data, hardware type, operating system information, browser information, unique identifiers in browser cookies, Flash cookies, HTML5 local storage, internet and online usage information and in-app information.

The foregoing categories of data may be used and disclosed in accordance with this Privacy Notice and the privacy notice of the company providing the ad-serving technology.

Howard may display to you behaviorally targeted advertising. Some services may include the use of in- app advertisements or brand placement. Such ads or sponsorships will be noted as such within the services. Please note that if you opt out of receiving behaviorally targeted advertising, it does not mean you will no longer receive advertising of any kind. Instead, the advertising you see displayed will not be customized to you and your interests and may be less relevant to you.

How Do I Restrict Cookies?

You have the right to choose whether or not to accept cookies. However, they are an important part of how the Services work, so you should be aware that if you opt to refuse or remove cookies, it could affect the availability and functionality of the Services. If you do not want the Services to use cookies, please follow the instructions provided in the following sections.

For further information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, please visit www.allaboutcookies.org and www.youronlinechoices.eu.

Website (Browser) Opt-out

Most browsers accept cookies by default. You may be able to change the settings to have your browser refuse certain cookies or notify you before accepting cookies. To do so, please follow the instructions provided by your browser which are usually located within the "Help", "Tools", or "Edit" facility. Some third parties also provide the ability to refuse their cookies directly by clicking on an opt-out link. If you wish to opt out of certain third party marketing cookies on Howard’s site and on the rest of the web, you can opt out by clicking here, or, if you are based in the European Union, click here.

Mobile App Opt-out

To limit interest-based advertising on your mobile device, you can review and adjust the settings provided by your device manufacturer, such as "Limit Ad Tracking" for iOS or "Opt out of interest-based ads" for Android.

Who Has Access to Your Information?

Howard shares your personal information under the following circumstances:

• Service Providers and Business Partners: Howard shares your personal information with its service providers and business partners that perform services and other business operations for Howard for the purposes set forth above. For example, Howard partners with companies to process secure payments and donations, fulfill orders, optimize services, send newsletters and marketing messages, serve online behavioral advertising, support email and messaging services, and analyze information. These service providers and business partners include advertising agencies and fraud prevention agencies that will use your personal information only in the ways described in this policy.
• Within Howard University: Howard shares personal information within the University, including in the US and elsewhere for the purposes set out in previous sections. To the extent Howard collects information in person in the European Economic Area, Howard may share personal information about you with other Howard personnel located at its campus in the United States or elsewhere.
• Law Enforcement Agencies, Courts, Regulators, Government Authorities or Other Third Parties: Howard may share your personal information with these parties where the University believes this is necessary to comply with a legal or regulatory obligation, or otherwise to protect its rights or the rights of any third party.

How to Exercise Your Rights

Where applicable under local law, you may have the following rights regarding your personal information: the right to access personal information Howard holds, and in some situations, the right to have that personal information corrected or updated, erased, restricted, or delivered to you or a third party in a usable electronic format (the right to data portability).

Where applicable, you may also object to how Howard uses your personal information if the legal basis for processing that information is Howard’s legitimate interest. Where you have provided consent and where applicable under local law, you have the right to withdraw any consent you have given at any time. You also have the right to register a complaint to the appropriate data protection authority, where applicable.

Please note that Howard may require additional information from you in order to honor your requests.

If you wish to exercise these rights, or to notify Howard of a change in your details, or if you have any questions on the content of this notice, please contact the University at webservices@howard.edu.

How Your Information is Protected

Howard implements technical and organizational measures designed to ensure a level of security appropriate to the risk to the personal information Howard processes. These measures are aimed at ensuring the ongoing integrity and confidentiality of personal information.

Howard will retain your personal information for as long as it has a relationship with you. Once Howard’s relationship with you has come to an end, Howard will retain your personal information for a period of time that enables it to:

• Maintain its records (including academic records, if applicable).
• Comply with record retention requirements under applicable law.
• Defend or bring any existing or potential legal claims.
• Resolve or otherwise address any complaints or queries relating to Howard’s programs.

Howard will delete your personal information when it is no longer required for these purposes. If there is any information that Howard is unable to delete entirely from its systems for technical reasons, it will put in place appropriate measures to prevent any further processing or use of the information.

International Transfers of Information

Your personal information may be transferred to, stored, and processed in a country, such as the United States, that is not regarded as ensuring an adequate level of protection for personal information under the laws of your country.

Howard has put in place appropriate safeguards, such as contractual commitments, in accordance with applicable legal requirements to ensure that your personal information is adequately protected. For more information on the appropriate safeguards in place, please contact the University, per the following section.

How to Contact the University

If you have questions or concerns regarding the way in which your personal information has been used, please contact the University at webservices@howard.edu.

Howard is committed to working with you to obtain a fair resolution of complaints or concerns about your privacy. If, however, you believe that Howard has not been able to assist with your complaint or concern, you have the right (where applicable) to make a complaint to the appropriate data protection authority. Contact information for the EU data protection authorities can be found at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

Changes to the Online Privacy Notice

You may request a copy of this privacy notice from the University using the contact details set out above. Howard may modify or update this privacy notice from time to time.

Any changes to the Online Privacy Notice will be noted at the bottom of the page; please check periodically.