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NOTICE OF NONDISCRIMINATION

The College of the Holy Cross does not discriminate unlawfully in admission to,
access to, treatment in or employment in its programs and activities on the
basis of a person's race, religion, color, national origin, age, marital or
parental status, veteran status, sex, disability, genetic information, sexual
orientation, gender identity or any other legally protected status, including in
the administration of its educational policies, admissions policies, scholarship
and loan programs, and athletic and other school-administered programs.
Individuals who feel that they have been discriminated against based upon any of
these categories may contact the Director of the Office of Title IX and Equal
Opportunity. Read the College's full Nondiscrimination Statement.

College of the Holy Cross • 1 College Street, Worcester, MA 01610 • 508-793-2011


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© 2024 College of the Holy Cross. All rights reserved.

College of the Holy Cross Privacy Notice The College of the Holy Cross
(hereafter “College”) is committed to respecting the privacy of information and
data that may be used to identify you (your “personal information”). This
Privacy Notice describes our policies and practices regarding the most common
ways we collect and use personal information. Information We Collect and How We
Use Your Personal Information Applicants and Prospective Students Personal
Information We Collect The College collects and uses personal information about
applicants and other prospective students, including students interested in our
summer program (referred to collectively as “applicants”). If you are or have
been an applicant, we may collect and use the following types of personal
information about you: Information and supporting documentation that you provide
in your application, including through third parties, such as the Common
Application, the Coalition Application, and Questbridge. Related application
materials (e.g., recommendations, references, and test scores) Information that
you have permitted a third party, such as The College Board, to release (e.g.,
AP or PSAT scores, demographic information, academic information) Contact
information for prospective students that we receive from other institutions and
from vendors who conduct advertising activities for us Financial information,
including financial information about your family members (e.g., information
collected in connection with applications for financial aid, loans, and
scholarships) Survey responses (if you choose to respond to a survey sent by us
or on our behalf) How We Use Your Personal Information Your personal information
is used primarily to evaluate your application and related activities, such as
evaluating requests for financial aid, communicating with you about your
application, and other administrative functions related to the admissions and
enrollment process. We may also use or disclose your personal information for
the following purposes: To consider requests for accommodations For research and
statistical purposes To provide you with information about the College and
events that you might be interested in attending To send surveys for research
purposes For compliance with legal obligations, to respond to subpoenas, court
orders, or other legal process, and to enforce our agreements To prevent or
investigate fraud or other unlawful activity, and to protect the security of the
College's property, website, and other systems To meet the obligations of
private organizations with oversight over the College, such as accreditation
organizations To protect the health, safety, or rights of you, other students,
faculty, staff, and visitors How We Share Your Information We may share your
information with the following individuals and entities: Individuals who assist
in the application process, such as faculty and outside consultants Other
departments within College of the Holy Cross, in addition to the Admissions
office, including the Office of Advancement Your financial institutions and
funders (e.g., as necessary for obtaining loans, scholarships, or other funding)
Other educational institutions (e.g., in order to send you information about
jointly hosted informational events) Vendors who provide services to the College
Governmental bodies as necessary for compliance with law, with law enforcement
authorities when necessary, and other third parties to enforce our legal rights
Private organizations with oversight over the College, such as accreditation
organizations Legal Basis for Processing (for personal information subject to
the General Data Protection Regulation (“GDPR”)) With respect to personal
information subject to the GDPR, we rely on the following lawful bases for
processing: Our legitimate interests, such as conducting our admissions
activities To provide you with services or perform on contractual obligations,
such as processing your application for admission For compliance with our legal
obligations With your consent, when applicable Students, Faculty, and Staff
Personal Information We Collect When you are a student at the College, or a
member or prospective member of the faculty and staff, we maintain records
containing your personal information. We may collect and use the following types
of personal information about you, as applicable: Your contact information and
biographical data (e.g., name, address, date of birth, race, ethnicity)
Application materials and supporting documents (e.g., applications for admission
or employment) Copies of identification documents and other official documents
(e.g. driver’s license, I-9 form, passport/visa information) Employment and/or
educational records (e.g., job history, job reviews, transcript information)
Academic work product and related information (e.g., research and course-related
content) Records about your other activities (e.g., involvement in clubs,
disciplinary actions and similar incidents) Financial information (e.g., payroll
information, information related to tuition payments) The College collects and
maintains medical information as appropriate and necessary and subject to
relevant laws. Student Health Services, Student Counseling Services, and Sports
Medicine collect medical information for the purposes of providing treatment and
determining enrollment and participation eligibility. Other offices, such as
Disability Services, Human Resources, or Public Safety may request or maintain
medical information for business purposes (not for treatment purposes).
Information about technology usage (e.g., IP addresses, software downloads,
network and services use) How We Use Your Personal Information We use this
information for the following purposes as applicable: To provide educational,
employment and/or related services (e.g., maintaining relevant records of your
studies or employment, providing you with access to facilities and support
services, such as counseling and IT services) To administer the financial
aspects of the relationship (e.g., payroll, collecting tuition, coordinating
with lenders or other funders) To enable your participation at events and in
other opportunities (e.g., graduation, study abroad programs, internships) To
protect the educational integrity of the school (e.g. disciplinary actions) To
accommodate special needs (e.g., disability accommodations) For research and
statistical purposes related to our educational and/or other services To provide
basic contact information in student, faculty, and/or staff directories For the
general operations of the College and related administrative functions For
compliance with legal obligations, to respond to subpoenas, court orders, or
other legal process, and to enforce our agreements To prevent or investigate
fraud or other unlawful activity, and to protect the security of the College’s
property, website, and other systems To meet the obligations of private
organizations with oversight over the College, such as accreditation
organizations To protect the health, safety, or rights of you, other students,
faculty, staff, and visitors How We Share Your Personal Information We may share
your personal information with the following: Faculty and staff at the College
in order to fulfill their responsibilities Your lenders, funders, and/or other
sponsors Providers of any external program, such as study abroad programs,
internships, and other collaborations Your host institution and host family (in
connection with study abroad or faculty or student exchange programs) Student
clubs and related organizations Individuals or entities inquiring about your
attendance or employment history Vendors who provide services to the College
Governmental bodies as necessary for compliance with law, with law enforcement
authorities when necessary, and other third parties to enforce our legal rights
Private organizations with oversight over the College, such as accreditation
organizations Legal Basis for Processing (for personal information subject to
the GDPR) With respect to personal information subject to the GDPR, we rely on
the following lawful bases for processing: Our legitimate interests, such as
fulfilling our educational mission To provide you with services or perform on
contractual obligations, such as providing you with educational services or
managing your employment relationship For compliance with our legal obligations
With your consent, when applicable Alumni and Other Supporters Personal
Information We Collect The College holds personal information related to its
alumni and other supporters (such as donors, prospective donors, volunteers, and
family members of students). If you are an alumni or other supporter, we may
collect and use the following types of personal information about you: Academic
information (e.g., major, transcript, degree) Biographical information (e.g.,
name, date of birth, ethnicity, religious affiliation) Contact information
(e.g., email address, phone number) Your activities at the College (e.g., club
memberships) Your involvement with the College and other interests (e.g.,
attendance at events, philanthropic interests) Family information (e.g., marital
status, name of spouse) Health information (e.g., disability, food allergies)
Financial information (e.g., history of donations, wealth information)
Employment information We collect data about alumni and other supporters from
various sources, including directly from the individual (for example, by filling
out a form on our website). We also retain information from your student records
if you studied here. We also collect information from publicly available
sources, such as social media, and from third parties, such as companies that
conduct wealth screening or other people that might know you and your
philanthropic interests. How We Use Your Personal Information Your personal
information is used for the following purposes: Sending you informational
publications (e.g., Holy Cross Magazine, newsletters from departments and clubs
you may have interest in) Conducting surveys so that we can learn more about our
alumni and other supporters Providing services (e.g., networking, ongoing career
services) Sending you information about fundraising campaigns, events, and
volunteer opportunities that may be of interest to you Conducting wealth
analysis and research to understand your philanthropic interests and ability to
give in order to ensure that our fundraising efforts are tailored to your
interests For administrative purposes (e.g., processing donations and issuing a
tax receipt, managing events, such as reunions) For research and statistical
purposes To publicly acknowledge gifts (with consent of the donor) For
compliance with legal obligations, to respond to subpoenas, court orders, or
other legal process, and to enforce our agreements To prevent or investigate
fraud or other unlawful activity, and to protect the security of the College’s
property, website, and other systems To meet the obligations of private
organizations with oversight over the College, such as accreditation
organizations To protect the health, safety, or rights of you, other students,
faculty, staff, and visitors How We Share Your Personal Information We share
your personal information with the following: College departments, clubs, and
interest groups College volunteers, Holy Cross Alumni Association, specific
alumni clubs and organizations and similar affiliates Other individuals or
entities with a legitimate interest in your personal information, such as
scholarship supporters Vendors who provide services to the College Governmental
bodies as necessary for compliance with law, with law enforcement authorities
when necessary, and other third parties to enforce our legal rights Private
organizations with oversight over the College, such as accreditation
organizations. Legal Basis for Processing (for personal information subject to
the GDPR) With respect to personal information subject to the GDPR, we rely on
the following lawful bases for processing: Our legitimate interests, such as
maintaining alumni relationships and conducting fundraising activities To
provide you with services or perform on contractual obligations, such as
providing certain alumnae services For compliance with our legal obligations
With your consent, when applicable Website Visitors (www.holycross.edu and other
associated Holy Cross web properties, including all at holycross.edu) Personal
Information We Collect The College of the Holy Cross website (defined as the
collection of all web pages, multimedia content, documents published to
.holycross.edu) is the College’s public information and communications system
and serves as the digital embodiment of the College for all audiences including
students, employees, alumni, families, future employees, prospective students,
and friends. If you visit this site to view or download information, or submit
information to us, we or our third-party vendors may automatically collect the
following types of personal information: the name of the domain from which you
access the Internet your approximate geographic region from which you access the
Internet the date and time of your visit the page(s) you visit, and engagement
with them your computing platform (browser, operating system, etc.) Some of this
information may be collected through the use of cookies, which are text files
that are placed on your hard disk by a web server, or similar technologies, such
as web beacons. Some of these cookies are managed by third parties that we do
not control, such as Google Analytics. You have the ability to accept or decline
cookies by changing your browser settings. If you choose to decline cookies,
some features on this website may not work properly. If you use our website to
complete forms, use our applications, or submit information to us (such as
through form registrations, requesting information or making a donation), we
will collect the information that you provide to us, as well as related
information such as your login ID. How We Use Your Personal Information The data
collected with cookies and similar technologies are used in the aggregate for
purposes of analyzing site traffic, managing the site, and providing
accountability regarding the usefulness of our work. If you provide us with
information (such as through registration pages), we will use that information
for the purposes described on the form or registration pages. We may also use
your personal information for the following purposes: For compliance with legal
obligations, to respond to subpoenas, court orders, or other legal process, and
to enforce our agreements To prevent or investigate fraud or other unlawful
activity, and to protect the security of College property, website, and other
systems. To meet the obligations of private organizations with oversight over
the College, such as accreditation organizations To protect the health, safety,
or rights of you, other students, faculty, staff, and visitors We may also share
your email address and/or your browsing behavior with third-parties for use in
targeted advertising campaigns. How We Share Your Personal Information Personal
information collected automatically on this website is not disclosed to third
parties unless the third party is an institutionally authorized provider of
services to the College. Information collected through website forms is used as
specified on the form or as otherwise described in this notice. This web site
contains links to many sites that are beyond our control. The College is not
responsible for the privacy practices or content of these other sites. Users of
these services are subject to the privacy policies established by the
third-party provider. Legal Basis for Processing (for personal information
subject to the GDPR) With respect to personal information subject to the GDPR,
we rely on the following lawful bases for processing: Our legitimate interests,
such as monitoring our website usage To provide you with services or perform on
contractual obligations, such as managing our relationships with our suppliers
and alumnae For compliance with our legal obligations With your consent, when
applicable Transfer of Information to the United States The College of the Holy
Cross is located in the United States. Information we collect from you will be
processed by the College in the United States. The College may also transfer
your personal information to third parties, including our vendors, as described
in this notice that may be located outside of the European Economic Area
(“EEA”). The United States has not sought nor received a finding of “adequacy”
from the EEA, which means that the data protection laws in the United States may
not offer you the same protections as in the country in which you are residing
when the personal information is collected. With respect to transfers outside
the EEA, the College generally relies on derogations for specific situations. In
some circumstances, the College may enter into standard contractual clauses
governing the import or export of personal information, or rely on your consent.
In all cases, the College endeavors to apply suitable safeguards to protect the
privacy and security of your personal information, particularly sensitive data,
and to use it in a manner that is consistent with this Privacy Notice. Retention
of Data The College retains personal information about students and alumni
indefinitely for the purpose of alumni relationships, academic record-keeping,
and archiving purposes. Other personal information will be retained in
accordance with applicable College data retention policies or for audit or
system integrity purposes. Communications from College of the Holy Cross The
College of the Holy Cross and the Holy Cross Alumni Association periodically
send marketing communications to alumni, supporters, and other members of the
College community, such as newsletters, event invitations, and fundraising
information. If you would like to request that College or the Holy Cross Alumni
Association limit or stop these marketing communications with you, please
contact us at privacy@holycross.edu . If you request to be removed from our
mailing lists, we will retain your contact information to ensure that we do not
continue to contact you for these purposes. If applicable, we will also continue
to process your personal information for other purposes consistent with this
Privacy Notice. Individual Rights If you are located in the EEA, you may have
the following legal rights under applicable law with respect to the personal
information processed by the College: To withdraw consent at any time, if we are
processing your personal information on the basis of consent To access the
information that the College has about you To request that the College rectify
or erase your information To request that the College restrict the way it uses
your information To object to the way the College uses your information To ask
the College to transfer your information to someone else To lodge a complaint
with a data protection authority in the EEA The College’s ability or obligation
to comply with your requests may be limited by applicable law. To request to
exercise one of these rights, please contact us at privacy@holycross.edu.l
Changes to this Privacy Notice The College reserves the right to amend this
Privacy Notice at any time, for any reason, without notice to you. Any changes
will be published here and you should check our website to access our current
Privacy Notice. This Privacy Notice was last updated on November 1, 2018.
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