Privacy Policy - Sorbonne University Abu Dhabi

Last update: 8 May 2024

The website https://www.sorbone.apps.plana.ae/ (the “Website”), published by Sorbonne University Abu Dhabi (“the University”, “we”, “us”, “our”), is a website presenting the programs of the University and all the related information useful to its current of future students as well as jobs offers to hire its personnel.

While you are accessing, consult, browsing, and using the Website and its services, you communicate your personal data to the University.

Please read this privacy policy (the “Policy”) carefully as it explains how the University uses your personal data and to how exercise your rights. This Policy completes any documents or notices that may refer to this Policy.

Should you have any questions, you may directly contact the University by sending an email at privacy@sorbone.apps.plana.ae.

1. WHO IS THE DATA CONTROLLER OF YOUR PERSONAL DATA?

As a website publisher, the University is the data controller of the personal data collected for the administrative, operational and commercial management of the Website and its services.

As an educational institution, the University is the data controller of the personal data collected for students’ enrollment and all related services.

2. WHAT KIND OF PERSONAL DATA IS PROCESSED BY THE UNIVERSITY?

All personal data provided by you through the Website or when you directly communicate with the University, namely:

Types of Data	Examples of Data
Data related to your online request	Surname, phone number, email address, date and hour of your request, subject and content of your request, CAPTCHA test to ensure that you are not a computer, your exchanges with the University’ services concerned by your request, follow-up to your request
Data related to your enrolment application	Personal information: First name, last name, date of birth, email address, marital status, mobile phone, nationality, gender, country of residence, area code, mother nationality, passport number, passport date of issue, passport expiry date, issuing authority, country of birth, address, city. Student of Determination (SOD): whether you are a SOD, i.e., a student with special needs. Program information: degree of interest, program applying for, secondary program of interest, whether it is the first time you apply, term. School records: secondary school name, secondary school country, secondary school system, final grade, graduation date, high school equivalency indicator, high cool equivalency number. University Records: university name, university country, university grading system, dates of the degree, whether you were a major, GPA/final grade, graduation date, transcript received date. Languages & scores: proficiency exam, native language, exam score, exam date. Personal statement: any relevant information provided by you in your personal statement. Work experience: organization name, job title, country, city, dates, years of experience, experience details. Address & Contact information: full residential address in home country, country code, any other email or phone number. Additional information: sponsor, relatives at the University, requirement for a visa, military service. Document & Attachments: passport copy, personal photo, CV, undergraduate transcript, high school diploma, bachelor diploma, language proficiency, equivalency, personal statement, birth certificate, experience letter, health report, personal information form. Banking / payment details
Data related to application for accommodation	Application Form: Banner Number, Name Sex, Nationality, date of birth, UAE mobile number, Personal email, Study details (Major and Level), Health problems, Emergency contact details (relationship with students,name, phone number and email adress), having family in UAE (adress, relationship and mobile), Expected arrival date and departure date. Image Authorization, Signature and date. Document to attach : copy of passport or ID, Photo. To complete the student file, additional forms are to be filled: Inventory form: student name, building, room number ,check in date & signature, checkout date &signature. Key form, Student Name, banner ID, Room number, student signature and date. Rules and regulations to sign with student full name and date.
Data related to scholarship / financial aid request	Scholarship-personal information: Banner ID, type, student name, major, year, residence, current scholarship, personal statement. Financial Aid: Banner ID, type, student name, major, year, residence, current scholarship, employment certificate, loan agreement, Bank and expense statement. Sponsorship agreement: Payment terms and conditions, Student name. Banner ID, major accepted for, sponsorship duration, sponsorship type, Scholarship Value
Data related to events organized by the University	Title, name, surname, mobile number, email address, photographs of you.
Data relating to our mailing list	Title, name, surname, mobile number, email address, profession, company.

The provision of certain types of personal data may be necessary or optional. Mandatory data will be marked as such at the moment of collection of your personal data. If you refuse to provide mandatory data and/or provide for non-relevant data, the University may not be able to process your request.

Furthermore, the Website also automatically collects the following data through cookies and other trackers:

Type of Data	Examples of Data	Purposes
Internet or other electronic network activity information	Date and time of the visit, IP address, location (city), device, browser, operating system, system configuration data, pages viewed, downloads	Such data is necessary for the proper functioning of the Website, as well as for audience measurement. This Policy does not cover the use of cookies. For more information on the use of cookies or to change your preferences regarding such cookies, please visit our Cookies Policy

3. FOR WHAT PURPOSES DOES THE UNIVERSITY USE YOUR PERSONAL DATA?

The University processes your personal data for the following purposes only:

Purposes	Examples of use of your personal data	Legal bases
	Online request
Managing your online request	to manage your online request (contact request) to recontact you	Legitimate interest of the University to manage its online requests
	Online Application
Enrolment request	to determine your eligibility to a program to answer to the questions you may have more generally, to process your enrolment request	To take steps prior to entering into a contract
Application for accommodation	to process your accommodation request	To take steps prior to entering into a contract
Application for a scholarship / financial aid request	to determine your eligibility to a scholarship / financial aid to answer to the questions you may have more generally, to process your scholarship request	To take steps prior to entering into a contract
	Communication
Direct marketing communications	to send you electronic communications about the University’s activities that might interest you (e.g., if you have subscribed to our mailing list)	Your consent
Communications with students (other than direct marketing)	to inform you about partnership initiatives developed by the University to communicate about the free events we organize for professionals / students	Legitimate interest of the University to communicate with its students about student life, news & events regarding the University
Public release on events organized by the University	As part of its face-to-face or online events: photographs of participants and/or; recordings of online events to publish them on its Website for non-commercial use.	Consent Please note that the University would do so, only if you have given your consent. If you do not wish the University to use your image anymore, you have the right to request for its erasure by contacting us at the following address: privacy@sorbone.apps.plana.ae
	Website management
Improving the Website, its services, and your user experience	to evaluate and improve the Website and its services to facilitate your navigation on the Website to take steps designed to protect the security of the Website	Legitimate interest of the University to improve the Website, its services, and your user experience
	Litigation and compliance with regulatory / legal obligations
Pre-litigation or litigation management	to take action against any identified breach to manage any dispute or litigation	Legitimate interest of the University in defending its rights and interests
Compliance with legal and regulatory obligations	to comply with applicable legal and regulatory obligations to manage your requests when you exercise your rights	Legal and regulatory obligations to which the University is subject

4. WHO CAN ACCESS YOUR PERSONAL DATA?

Your personal data may be transmitted to the following recipients when you access, consult, browse, and use the Website and its services:

Recipients	Purposes
The University and its duly authorized employees	For the purposes indicated in the Section 3 of this Policy.
Service providers (hosting provider, IT solutions and services providers (e.g., CAPTCHA test, online forms, email newsletter, etc.), social media/platforms)	For operational and technical purposes related to the Website and related services, as well as to satisfy purposes of Section 3.
Administrative or judiciary authorities	Exclusively in case of an express and justified request from them or in case of an alleged violation of legal or regulatory provisions.
Lawyers and all interested parties	Exclusively in the case of the management of possible disputes and other legal matters where appropriate.
Other third parties	Following or during a restructuring, reconstitution, acquisition, debt financing, merger, sale of assets of the University or a similar transaction, as well as in case of insolvency, bankruptcy or receivership where personal data are transferred to one or more third parties as assets of the University

Name of the recipient	Third country	Adopted safeguards
Meta	United States	Standards contractual clauses
Google	United States	Standards contractual clauses

8. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?

If you are based in the EU/EEA/UK, you have the following rights over your personal data:

Your rights	Scope of you rights
Right to access	You have the right to request: the confirmation on whether the University processes your personal data or not; a copy of such personal data; and information on the use of your personal data by the University in a clear, transparent and understandable way (as provided in this Policy).
Right to rectification	You have the right to request the rectification of your personal data, in order to obtain the modification of your personal data if your personal data is obsolete, inaccurate or incomplete.
Right to delete	You have the right to request the deletion of your personal data (or right to be forgotten), when one of the following conditions applies: you object to the processing of your personal data and there are no overriding legitimate reasons justifying to maintain the processing of your personal data (e.g., legal obligation); you object to marketing activities; you decide to withdraw your consent on which the processing is based; your personal data are no longer useful for the original purposes for which it was collected or for any other type of processing; the use that is made of your data does not comply with the applicable legal or regulatory provisions.
Right to restriction of processing	You have the right to request the restriction of the processing during a limited period of time, in particular in order to carry out some verifications, where one of the following conditions applies: you contest the accuracy of your personal data, the processing of which is thus restricted for the period necessary for the University to verify the accuracy of such personal data; the processing is unlawful and, rather than requesting their deletion, you prefer to restrict their use; the University no longer needs your personal data for the purposes of the processing, but you need them for the establishment, exercise or defense of legal claims; you have objected to the processing, which is thus restricted pending the verification of whether the compelling legitimate grounds of the University may override your interests, rights and freedoms.
Right to data portability	You have the right to request a copy of your personal data in a structured, commonly used and machine-readable format and also request their transmission to another data controller where technically feasible. This right is not exercised in all circumstances, it applies only if it fulfils all the following conditions: your request is only related to your personal data (excluding anonymous or third-party data); your request does not adversely affect the rights or freedoms of others, in particular those of the University (e.g., trade secrets) those of third-parties (e.g,. intellectual property right); the processing is carried out by automated means (paper files are therefore not included); the processing is based on consent or the performance of a contract (to check if it is the case, you can see the Section 3 of this Policy).
Right to object	You have the right to object to our processing of your personal data at any time if the processing is based on our legitimate interest. The University will no longer process your personal data, unless they demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, such as the respect of a legal obligation or for the establishment, exercise or defense of legal claims.
Right to withdraw your consent	You have the right to withdraw your consent when it has been obtained, without this withdrawal affecting the lawfulness of the personal data processing operations previously carried out
Other righs	Depending on your country of residence, you may have additional local rights with respect to our processing of your personal data. For example, if you are based in France you can define either general or specific guidelines regarding your personal data in the event of your death (e.g., their deletion or transmission to any person of your choice). You may revoke your instructions at any time.

It is specified that the exercise of these rights is based on the legal basis of the processing as indicated in Section 3 of this Policy, as follows:

	Access	Rectification	Erasure	Restriction	Data Portability	Data Portability
Consent	Yes	Yes	Yes	Yes	Yes	Withdrawal of consent
Steps prior to entering into a contract	Yes	Yes	Yes	Yes	Yes	No
Contract	Yes	Yes	Yes	Yes	Yes	No
Legitimate interest	Yes	Yes	Yes	Yes	No	Yes
Legal obligation	Yes	Yes	No	Yes	No	No

Under certain circumstances, the University may ask you for specific information in order to confirm your identity and ensure the exercise of your rights. This is another appropriate security measure to ensure that personal data is not disclosed to an individual who does not have the right to receive it.

If you have any questions or wish to exercise your rights, you may directly contact the University by sending an email at privacy@sorbone.apps.plana.ae.

If needed, you may also lodge a complaint with your national data protection authority. This right may be exercised at any time and free of charge, at the exclusion of potential postal fees or expenses related to legal representation or assistance should you choose to engage third party assistance for the procedure.

سياسة الخصوصية

3. FOR WHAT PURPOSES DOES THE UNIVERSITY USE YOUR PERSONAL DATA?

4. WHO CAN ACCESS YOUR PERSONAL DATA?

5. WILL YOUR PERSONAL DATA BE TRANSFERRED OUTSIDE OF THE EUROPEAN UNION/EUROPEAN ECONOMIC AREA?

6. HOW DOES THE UNIVERSITY PROTECT YOUR PERSONAL DATA?

7. FOR HOW LONG ARE YOUR PERSONAL DATA STORED?

8. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?

9. CHANGES TO THIS POLICY

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