GDPR Privacy Notice
The Principia Corporation in St. Louis (“Principia School/Principia College”) is committed to safeguarding the privacy of our students, employees, alumni, and other individuals interacting with Principia.
This Privacy Notice is specific to the processing of the personal data of individuals who are protected by the European Union’s General Data Protection Regulation (“GDPR”). Principia has adopted polices, practices, and procedures to govern the use of personal data collected through our varied operations. For example, the Privacy Policy describes the information collected and outlines policies regarding the use of that data. The Technical Use Policy provides students, faculty, and staff with direction regarding the use of Principia internet resources.
You can jump to topics by clicking the headings below:
What types of personal data does Principia collect?
How do we use your information?
With whom does Principia share information?
What rights do I have?
How long is my personal information retained?
How does Principia protect personal information?
In what countries does Principia process personal information?
Changes to Our GDPR Privacy Notice
Contact information
What types of personal data does Principia collect?
The following provides examples of the types of personal data that Principia collects:
Student application
Types of Data
If you apply to Principia or to one of our educational programs, such as Acorn, Daycare, or Principia Lifelong Learning, we may collect, among other things, your contact information, demographic information, educational history, test scores, reference letters, financial information, and other information necessary to process your application.
Primary Purpose for Collection and Use of Data
We have a legitimate interest in processing and evaluating student applications. For international applicants, certain required data will be shared with the United States Department of Homeland Security in order to process SEVIS I-20 forms.
Student enrollment
Types of Data
If you enroll in Principia, we may collect, among other things, your contact information, demographic information, preferences, educational history, and financial information.
Primary Purpose for Collection and Use of Data
We have a legitimate interest in collecting personal data to provide educational services and financial aid and in promoting student life initiatives, developing student activities, administering campus activities, and managing Principia programs.
Information about Principia
Types of Data
If you request information about Principia, we may collect your contact information and your demographic information.
Primary Purpose for Collection and Use of Data
We have a legitimate interest in communicating with individuals who are interested in Principia’s educational programs, employment opportunities, and other services and programs.
Employment (current)
Types of Data
If you become an employee, we collect information necessary to retain you as an employee. This may include, among other things, your Social Security number. Providing this information is required for employment.
Primary Purpose for Collection and Use of Data
We use information about current employees to perform our obligations as an employer. We may be required by law to collect information about our employees, and we have a legitimate interest in complying with those laws. We also have a legitimate interest in using your information to have efficient staffing and workforce operations.
Employment (applicants)
Types of Data
If you apply for a job posting, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security number and conducting criminal background checks. Providing this information is required to be considered for employment.
Primary Purpose for Collection and Use of Data
We use information about prospective employees in anticipation of an employee-employer relationship. We may also be required by law to collect information about our applicants. We also have a legitimate interest in using your information for operational and statistical purposes. For international applicants, certain data will be shared with the US Department of Homeland Security if a visa is required.
Reunions, Summer Session, and Other Events
Types of Data
We collect information from you when you register for a reunion, Summer Session, Principia Club Activity, or other event. For example, we may collect your contact information, billing information, and preferences. If you are a speaker, we may collect presentation materials, a biography, and other information.
Primary Purpose for Collection and Use of Data
We use this information to perform our contractual obligations in relation to an event. We also have a legitimate interest in using your information to create directories of attendees.
Donations
Types of Data
We collect information from you when you make donations or gifts. For example, we collect contact and billing information.
Primary Purpose for Collection and Use of Data
As a nonprofit organization, we have a legitimate interest in collecting donations to fund our programs, operations, and facilities.
Third-Party Vendors
Types of Data
We may need to collect your information to enable our vendors to provide goods and services to Principia, employees, students, and the Principia community—or to support Principia operations.
Primary Purpose for Collection and Use of Data
We have a legitimate interest in assuring Principia operates efficiently.
Cookies and first-party tracking
Types of Data
We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. We may use both session cookies (which expire once a web browser is closed) and persistent cookies (which stay on a device until deleted). Among other things, cookies allow us to provide a more personal and interactive experience. Persistent cookies may be removed by following instructions provided by your browser. If you choose to disable cookies, some areas or features of our websites may not work properly.
Primary Purpose for Collection and Use of Data
We have a legitimate interest in making our website operate efficiently.
Cookies and third-party tracking
Types of Data
We use cookies to collect information about your use of our website. This includes obtaining analytics from third parties regarding the total numbers of users to our sites. The third parties that deploy cookies on our behalf may be able to track you across time and across websites.
Primary Purpose for Collection and Use of Data
We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services are most frequently used.
Dispute Resolution
Types of Data
We collect information when individuals engage us in adjudicatory or regulatory proceedings.
Primary Purpose for Collection and Use of Data
We have a legitimate interest in facilitating dispute resolution involving Principia, our employees, and our students.
Email Interconnectivity
Types of Data
If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains, and make purchases.
Primary Purpose for Collection and Use of Data
We have a legitimate interest in understanding how you interact with our communications.
Feedback/Support
Types of Data
If you provide us feedback or contact us for support, we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply.
Primary Purpose for Collection and Use of Data
We have a legitimate interest in receiving, and acting upon, your feedback or issues.
Health-related information
Types of Data
We may collect health information about you for various reasons, such as making accommodations for a physical or mental disability.
Primary Purpose for Collection and Use of Data
We have a legitimate interest in assisting our students, employees, and visitors with health-related requests and services. We may need to retain a service provider to assist in providing an accommodation.
Mailing List
Types of Data
When you sign up for one of our mailing lists, we collect your email and/or postal address.
Primary Purpose for Collection and Use of Data
We have a legitimate interest in sharing information about our products or services and providing you with information that you request.
Publications
Types of Data
We collect information about the authors who submit material for publications, the people who appear in our publications, and subscribers of our materials.
Primary Purpose for Collection and Use of Data
We have a legitimate interest in keeping a record of submissions for publication and in understanding the background and experience of authors and prospective authors accepted for publication as well as subscriber contact information. We also have a legitimate interest in recording information about those who appear in our publications including, for example, maintaining waivers and releases where appropriate for use of photographs.
Surveys
Types of Data
When you participate in a survey, we collect information that you provide through the survey. If the survey is provided by a third-party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information.
Primary Purpose for Collection and Use of Data
We have a legitimate interest in understanding your opinions and collecting information relevant to our organization.
Web logs
Types of Data
We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.
Primary Purpose for Collection and Use of Data
We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is most popular.
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.
How do we use your information?
In addition to the purposes and uses described above, we use information in the following ways:
- To identify you when you visit our websites
- To provide products and services, including educational instruction
- To improve our services and product offerings
- To conduct analytics
- To respond to inquiries or requests
- To send marketing and promotional materials, including information relating to our institution and our educational programs
- For internal administrative purposes, as well as to manage our relationships with our students, employees, vendors, and others with whom we do business
Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in operating Principia.
With whom does Principia share information?
In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:
- Affiliates. We may share information with our affiliates (e.g., subsidiaries, joint ventures, or other organizations under common control).
- Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
- Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.
- Public. We offer student and staff directories. If you decide to submit information to our directory, or allow your information to be posted in our directory, that information will be publicly available.
- Service Providers. We may share your information with service providers. Among other things, service providers help us operate our business, provide education and research services, administer our website, conduct surveys, provide technical support, process payments, and assist in the fulfillment of orders.
What rights do I have?
Under the GDPR, you have the right to:
- Request access to, rectification of, and with some exceptions, erasure of your personal information
- Request restriction of processing concerning your information or object to processing
- Request a copy of your personal information
- Withdraw your consent if the processing of your personal information was based on your consent
- Lodge a complaint with the appropriate supervisory authority in the European Union
To exercise one of your rights you may contact Principia using the information in the “Contact” section below.
How long is my personal information retained?
Your information is retained by Principia in accordance with state and federal laws and Principia policy. Principia will destroy your personal information on your request unless it is necessary to retain it or there are legal grounds for continued processing. Principia may retain information on its backup systems.
How does Principia protect personal information?
Principia employs reasonable physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, and availability of personal information; however, we cannot guarantee that our safeguards will be effective or sufficient. In the event that we are required by law to inform you of any unauthorized access to your personal information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
In what countries does Principia process personal information?
Principia is located within the United States. As a result, if you reside outside of the United States and provide information to us your information may be processed in the United States where privacy laws may be less stringent than the laws in your country. For example, the United States government may have a greater ability to access your personal information than might your local government.
Changes to Our GDPR Privacy Notice
We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy.
Contact Information
If you have questions about this GDPR Privacy Notice, you can contact Principia General Counsel Lee Barron at lee.barron@principia.edu.
*Note: Principia’s policy has been adapted from Washington University’s GDPR Privacy Notice.
Last updated: September 2020