Scope of the Privacy Notice
For the purposes of this Privacy Notice, "personally identifiable information" (PII) or Personal Data is simply any information that identifies a natural person. Data collected via this website or via any link therein is processed for its intended collection reason and controlled by Franklin University Switzerland (FUS). We understand the importance of your privacy, and thus employ measures to process and secure it in accordance with applicable laws and the General Data Protection Regulation. This privacy notice applies to the personal information you submit to us via applications, data we collect when you visit our websites, how and for what reasons we use it, with whom we share it, and how we protect it. It also informs you, the data subject, on what choices you have on how your information is used, and how you can access and update that information. While this notice primarily applies to the PII collected on the sites where it is posted, certain aspects also apply to the information we collect offline via non-electronic forms, postcards, and purchased lists. After reading the notice, if you do not agree, please do not use any of Franklin University Switzerland’s websites or submit your PII for processing.
Definition of terms used in this document
Data Subject
The natural person to whom the personally identifiable information belongs.
Data Controller
The person or organization who dictates the reasons, purpose, and way any Personal Data is processed on their behalf.
Data Processor
A “data processor” is a person or organization that processes Personal Data for the controller.
Data Processing
Any set of automated or manual operations performed on Personal Data including collection, using, altering, retrieving, consulting, sharing, recording, organizing, structuring, storing, adapting, aligning or combining, restricting, deleting or destroying, such as a set of operations performed upon Personal Data.
Personal Information We Collect and/or Process
The personal information you volunteer to Franklin University Switzerland is used solely for the purpose of providing you the advertised services related to the university’s mission. Personal information we collect includes but is not limited to:
- Name
- National ID/Passport number
- Financial account and payment information
- Birthdate
- Email address
- Phone number
- Mailing address
- IP address
- Mobile device ID
- School Records
- Written papers
- Test and Exam scores
The institution may also process sensitive personal data for contractual reasons. The sensitive PII we collect from students and employees may include, but is not limited to:
- data on religious, ideological, political or trade views or activities,
- data on health and medical needs, the intimate sphere, or racial or ethnic origin,
- biometric data which clearly identifies a natural person,
- data on administrative or criminal proceedings and sanctions,
- data on social security measures;
When we collect sensitive Personal Data directly, we will obtain consent with a clear declaration of purpose for its collection and processing. This collected data will not be disclosed to third parties or repurposed for use other than explicitly authorized by the data subject.
Purposes for Processing Personal Information
Franklin University Switzerland uses Personal Data as necessary to meet the legitimate needs of the data subject, the institution, and the US and Swiss authorities. Essentially your personally identifiable information is used to deliver the products and services that you request, enhance your experience with our services, provide you with informational and/or promotional materials that you might find interesting, internal business analysis and reporting, and other purposes consistent with this notice. Categorized as either relationship maintenance or promotional uses, these purposes include, but are not limited to, the following:
- Education and academic-related works and services
- Candidate selection for administrative and academic employment
- Residence and studies-related conveniences, accommodations, and support
- Invitations for visits to the school and campus, and seminars
- Promotions and discounts, and other services related to your interests, and FUS’s mission
- Payments and donations to the university
- Maintaining relationships with alumni and friends of the university
- Personal and remote or virtual meetings, tele and video conference conversations with applicants and guests
- Organizing campus tours
- Swiss study, residence, and work permits
Offices Using the Personal Information Collected
- Admissions
- Student Life
- Registrar and Academics
- Bursar: Finance, bank accounts, taxes
- IT Services
- Finance and Administration
- Advancement and Development
Again, if you do not wish for FUS to process your Personal Data for any reason related to the above purposes you will able to opt out. To do so, simply send an email to the FUS Data protection office at: dpo@fus.edu. In some specific cases, FUS may request explicit consent from the data subject to process their personal data.
How Does FUS Collect Your Personal Data?
FUS employs measures from simple postcards to third-party tools and service providers for automated data collection and processing purposes. By contractual agreement, these providers will not use or share your data for any purposes outside the agreement, and only hold the data in line with our policy on data retention.
There are many features on this website for which no registration is required, so we employ other methods to collect information that we use to improve our communications and services to you. We use different types of cookies and other technologies (such as “pixel tags,” “web beacons,” “clear GIFs,” links in emails, JavaScript, device IDs assigned by Google or Apple, or similar technologies) to collect this information. If you want to remove or block Cookies from your device at any time, you can update your browser settings (consult your browser's "help" menu to learn how to remove or block Cookies). See Cookie Use below for more information on how we use cookies to make our site more interesting, useful, and targeted to your interests.
With recruitment, employment, and engagement so essential to FUS’s survival, third parties also provide us with profiling using publicly-available information about you. For example, the Office of Advancement and Development may use this information to give us insight into your possible propensity and ability to give to our causes and initiatives.
In applying to becoming an active member of the Franklin family, obtaining information, subscribing to one of our lists, making an online payment, sponsoring a student, making an online donation, or participating in certain events, you may need to provide us with information about yourself. We may also use your personal information to detect fraud and credit risks.
Personal Data Transfers
At Franklin University Switzerland, we take our responsibility to maintain your privacy with respect to your personally identifiable information very seriously. Therefore, we do not sell or rent your personal information to third parties. Where our third-party processors are located outside of FUS and Switzerland, those in the US fall under the “Privacy Shield” while those in the EU under the GDPR. These participating processors have been deemed to employ adequate protection protocols. The following entities below are allowed to process your information in the manner according to your consent and our agreements for the aforementioned listed purposes. The extent of the Personal Data you submit to these entities for processing on FUS’s behalf is determined and controlled by you at your sole discretion. You have the right to update the details in your record.
Here is a short list of processors, the data they process on our behalf and links to the privacy statement for each entity. Note that FUS, being the controller, remains the first point of contact regarding the processing of your data via the entities below.
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Technolutions - Privacy statement
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Data processed relates to the following purposes: outreach, recruitment, application, admissions-related administration
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Blackbaud LLC - Privacy statement
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Data processed relates to the following purposes: alumni engagement; donations, gifts and purchases; event registration and participation; parent engagement; Advancement-related administration
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PowerFAIDS-Server in hosted environment by eApps - Privacy statement
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Data processed relates to the following purpose: student financial aid information
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Safey Early Warning Application - Privacy statement
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Data processed relates to the following purposes: location, personal contact details
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Microsoft Office 365 for Education - Privacy statement
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Data processed relates to the following purposes: location, personal contact details
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OOHlala Mobile Application - Privacy statement
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Data processed relates to the following purposes: location, personal contact details for communication and engagement
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Moodle LMS hosted by Ethink - Privacy statement
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Data processed relates to the following purposes: academic work, personal contact details
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EvaluationKit - Terms of Use
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Data processed relates to the following purpose: personal contact details
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Turnitin - Privacy and security statement
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Data processed relates to the following purposes: academic work, personal contact details
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FlyWire - Privacy policy
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Data processed relates to the following purposes:personal contact details, payment processing
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EVERFI - Privacy policy
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Data processed relates to the following purposes: personal contact details, platform login details
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THANKVIEW - Privacy policy
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Data processed relates to the following purposes: personal contact details, platform login details
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Where is Your Personal Data Stored?
FUS retains your PII in various formats and on systems physically located in Switzerland, The Netherlands, and the United States.
Protection and Storage of Your Personal Data
FUS continues to work on implementing reasonable technical and administrative measures to safeguard and prevent any unauthorized processing of your personal data. This includes but is not limited to the combined use of physical and technical access controls, encryption, secure transmission, data minimization, and consolidation on our systems. We assure you that third-party entities that process your personal data on our behalf are in full accord with privacy regulations. FUS will store your data for as long as necessary for the purpose it was collected as this aligns with our recruitment, studies, employment, alumni and parent engagement practices, and regulatory requirements. Obsolete and useless data will be securely destroyed. However, while we use all reasonable efforts to protect your personal information, no method of transmitting or storing electronic data is ever completely secure, and therefore we cannot warrant or guarantee that such information will never be accessed, used, or released in a manner that is inconsistent with this policy.
Links to Other Sites
We may provide links on our website to other sites we think you will enjoy. We are not responsible for such external content; these sites operate independently of Franklin University Switzerland and have established their own privacy and security policies. We encourage you to be very aware when you leave our site and to read these policies at any site you visit.
Children's Privacy
Our website is a general audience site, and we do not knowingly collect information about children. Should a child whom we know to be under 13 make known to us his or her personally identifiable information, we will use that information only to respond directly to that child to inform him or her that we must have parental consent before receiving his or her personally identifiable information.
Access to Your Information, Update, and Deletion
It is your right to receive a copy of all or some of the PII that we currently retain on you. To do so, simply reach out to the Franklin University Switzerland Data Protection Office at the information in the Contact Us section below. We will respond to your request within 72 hours and do our best to accurately accommodate the request within 30 days of receipt. As your information is more useful to both of us when it’s accurate and up to date, you may provide us the correct information or request a removal of information you think is inaccurate by emailing the appropriate office or FUS Data Protection office at the contact details below.
It is your right to lodge an objection to the processing of your Personal Data if you feel the “grounds relating to your particular situation” apply. You may also execute your right to be forgotten by contacting us at the details below. We will honor and respect all reasonable requests and comply within regulations.
Data Portability
Aside from your right to receive the Personal Data in a structured, commonly used, and machine-readable format, you also have the right to request that we securely transmit that data to another controller without extended delay as long as the processing was based on consent or on a contract, and processing is executed by automated means.
Changes in this Privacy Notice
We may amend this Privacy Notice at any time as our needs to process Personal Data change in alignment with new processes. If we make any material changes in the way we collect, use, and/or share your personally identifiable information, we will notify you by sending you an email at the last email address that you provided us and/or by prominently posting notice of the changes on the websites covered by this Privacy Notice. In any event, changes to this Privacy Notice may affect your consented use of personally identifiable information that you provided us prior to our notification to you of the changes. This is considered enough grounds to withdraw your consent.
Contact Us
If you have questions or wish to send us comments about this Privacy Notice, please write us at:
Franklin University Switzerland
ATTN: Data Protection Office
Via Ponte Tresa 29
6924 Sorengo (Lugano)
Switzerland
Tel: +41 91 985 2260
Email: dpo@fus.edu
FUS appointed SZA Studio Legale as its EU Representative pursuant to article 27 of the GDPR. Email: eurepresentative@fus.edu
Cookie Use
What are cookies?
Cookies are small text files that are placed on your computer or device when you visit our websites.
Why we use cookies?
We use cookies to make your visits to our websites efficient and personalized. We also use cookies to improve the content and navigability of our websites based on how our visitors use them.
How we use cookies?
We use cookies to:
- Remember your log in details.
- Identify you when you log into our website.
- Gather analytical information such as counting the number of visitors to our websites and the pages of our website that are most frequently visited. We use the analytical information we gather to understand our visitors’ needs and adapt our websites accordingly.
- Understand how our visitors respond to changes we may make to our websites.
- Gather information that can help us to send you content and advertisements that are relevant to your interests.
- Associate browsing behavior with specific applicants to our institution.
Information we collect from cookies
Cookies help us to collect information about how you use our websites, but we do not store personally identifiable information in them. We only store a unique session ID that allows our websites to recognize your browser on your next visit to our website. Cookies help us to identify you personally only if you have provided us with your personal information, such as by applying for admission or if you have already attended the University.
Types of cookies
Session cookies – These types of cookies are temporarily stored on your computer or device during a browsing session and are deleted from your computer or device at the end of a browsing session.
Persistent cookies – These types of cookies stay on your computer until they expire or until you delete them. Persistent cookies are used when our websites need to store information or preferences that will be used for more than one browsing session.
Managing Cookies
Most browsers give you options of how to manage your cookies by adjusting or configuring your cookie settings. Typically the browser will give you the option to:
- view your cookies
- allow cookies
- disable all or specific cookies
- disable all cookies when you close your browser
- block cookies
- receive notifications when you receive a cookie
If you use your browser settings to block our cookies, some parts of our websites may not work or may not allow you access. Online application services, order management and other kinds of personalization functions cannot be provided without cookies. In some cases, your general browsing experience may also be impacted. If you set your browser options to delete all cookies at the end of a session, you will not be able to save preferences or login information for your next session. Please note that unless you have adjusted your browser settings to refuse cookies, our systems will issue cookies as soon as you visit one of our websites.
FERPA Privacy Policy
FERPA for Students
The Family Educational Rights and Privacy Act (FERPA) guarantees students certain rights with respect to their education records. These rights include:
1. The right to provide written consent before the University discloses personally identifiable information from the student's education records, except to the extent that FERPA authorizes disclosure without consent.
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The University discloses education records without a student's prior written consent to school officials with legitimate educational interests. A school official is a person employed by the University in an administrative, supervisory, academic or research, or support staff position (including law enforcement unit personnel and health staff); a person or company with whom the University has contracted as its agent to provide a service instead of using University employees or officials (such as an attorney, auditor, or collection agent); a person serving on the Board of Trustees; or a student assisting another school official in performing his or her tasks. A school official has a legitimate educational interest if the official needs to review an education record in order to fulfill his or her professional responsibilities for the University.The University may disclose records to official personnel in connection with the receipt of financial aid. |
2. The right to inspect and review the student's education records within 45 days of the day the University receives a request for access.
| A student should submit to the Registrar, appropriate academic or student dean, head of the academic department, or other appropriate official, a written request that identifies the record(s) the student wishes to inspect. The University official will make arrangements for access and notify the student of the time and place where the records may be inspected. If the records are not maintained by the University official to whom the request was submitted, that official shall advise the student of the correct official to whom the request should be addressed. |
3. The right to request an amendment of the student's education records that the student believes are inaccurate, misleading, or otherwise in violation of the student's privacy rights under FERPA.
| A student who wishes to ask the University to amend a record should write the University official responsible for the record, clearly identify the part of the record the student wants changed, and specify why it should be changed. If the University decides not to amend the record as requested, the student will be notified in writing of the decision and of his/her right to a hearing regarding the request for amendment. Additional information regarding the hearing procedures will be provided to the student. |
4. The right to file a complaint with the U.S. Department of Education concerning alleged failures by the University to comply with the requirements of FERPA.
| The name and address of the Office that administers FERPA is: Family Policy Compliance Office U.S. Department of Education 400 Maryland Avenue, SW Washington, DC 20202-5901 |
This policy serves to notify students of their rights regarding their education records in accordance with the FERPA, and provides a general framework for the University’s compliance with FERPA. This policy does not cover all aspects and exceptions under FERPA and other laws