Privacy Notice for AUBG Alumni and Donors

Privacy Notice for AUBG Alumni  and Donors

Our alumni and supporters are extremely important to us, and this Privacy Statement explains how the American University in Bulgaria, as a data controller, collects, stores, manages and protects alumni, donor and stakeholder data. It outlines the types of data that the University holds and how it uses that information to provide services to our alumni and supporters. We aim to be clear when we collect your personal information, and not do anything you wouldn’t reasonably expect.

Who we are and what we do

The American University in Bulgaria (AUBG or University) is the data controller with respect to alumni, donor and stakeholder personal information. AUBG Data Protection Officer is Ms. Margarita Petkova.

Please find below our address and contact details:

AUBG postal address: 1 Georgi Izmirliev Square, Blagoevgrad 2700, Bulgaria

DPO phone number: +359 73 888 337

DPO email:  dpo@aubg.edu

The AUBG Administration is part of AUBG and supports the University’s objectives through engaging with students, alumni, supporters and stakeholders of the institution. We do this by offering a range of academic, social and networking events. We also fundraise to support the University’s students, teaching, and research and capital projects.

WE (the AUBG administration) value our relationship with YOU (our alumni, supporters and stakeholders) and we use your personal data to ensure we communicate with you in the most appropriate way, to improve our services and to ensure we work efficiently and effectively. In order to do this, we maintain a database that contains personal data collected by the University during the course of our relationship with you.

Purposes and legal basis for the processing

AUBG’s core mission is to educate students of outstanding potential in a community of academic excellence, diversity, and respect and to prepare them for democratic and ethical leadership. Thus our constituency groups have an expectation that AUBG will work in partnership with them to enable them not only to succeed academically, but also to champion social, cultural and economic growth and secure our future sustainability. The University does this through a variety of teaching, student, research, community and capital projects, which our alumni engagement and fundraising activities are designed to support. As such, we have a legitimate interest in engaging with our alumni, donors and potential supporters to enable us to achieve these goals.

Therefore, AUBG considers that the legal basis for processing your personal data for the purposes of alumni engagement and fundraising is legitimate interest under art. 6(1)(f) of the General Data Protection Regulation (Regulation 2016/679).

Nevertheless, we always ensure that we balance our objectives against your rights and freedoms as an individual (the so-called “balance test”), by reviewing our activities regularly for compliance with our ethical and legal obligations.

For alumni, donors and supporters, there are a number of purposes for which we process your data, including careers, mentoring, networking and fundraising. Generally, we will communicate with you about the following alumni engagement and fundraising activities, by post, email, telephone and social media:

  • Keeping your knowledge fresh, by sending university and departmental publications;
  • Offering you access to alumni and student careers, mentoring and networking services;
  • Letting you know about alumni and university events;
  • Asking you to participate in fundraising programs;
  • Offering you the chance to participate in academic projects and research;
  • Extending  greetings, appreciation for your engagement and recognition of your support.
How we collect your personal data

Initially, data about students is transferred into Registrar’s Office database from the records which students provide to their Admissions Counselor at enrollment. At graduation, our seniors complete a student data sheet at Registrar’s Office to update the information they have provided four years before.  Thus, the vast majority of the information we hold is obtained directly from our alumni; and if they interact with any other departments, divisions, schools or faculties within the University, we may receive data from these sources.

Since we aim to keep our records up to date, we strive to ensure that the contact details we have for all alumni, donors and other stakeholders are correct and update them on a regular basis. We also encourage our alumni to update their own details by visiting the Contact Info Update Form.

There is no statutory or contractual requirement for you to provide us with any personal information after graduation. However, should you decide not to provide additional data or update your previous student information, we may be less able to provide the services you request at a later date or engage you in our activities mentioned herein.

We also seek new contact details for alumni with whom we have not been in contact for some time, to ensure the University can remain in touch with as many of its alumni as possible. As a result, some of the data may also have been obtained from publicly available sources.

What personal data AUBG collects

We store and process personal data, the majority of which is given to us by our alumni and supporters, including:

  • Name, title, gender and date of birth;
  • Information about your time at the University and other academic institutions you have attended;
  • Contact details including postal address, email address, phone number and links to social media accounts;
  • Your occupation and professional activities;
  • Family and spouse/partner details and your relationships to other alumni, supporters and friends;
  • Records of pledges and donations;
  • Details of events you attended (formal, as a speaker, at career events, as an alumni ambassador) and when;
  • Information on your engagement in University meetings, events, groups or networks;

Any other personal information you provide to us in the course of communication with us may be stored in the form of notes for reference purposes. This may include sensitive personal data, but only where you have provided this data to us directly or it is already publicly available.

The University does not store any credit/debit card details.

Who can access your data

Unless you have requested otherwise, your data is accessible to AUBG Alumni Office, Development Office and Registrar’s Office which need to see the data to carry out their duties at the University. The rights of these individuals are also restricted so that only the data that is necessary and required to complete their role is accessible. All access is reviewed on a regular basis.

Upon request and based on the discretion of the offices stated above, information might be shared internally with the Admissions Office, Office of Communications and Marketing, the Accreditation Department and Events Office to facilitate particular duties that arise in the course of work.

We will NEVER sell your data or pass it on to 3rd parties for marketing purposes. We will only transfer data to the AUBG Alumni Association (AAA), Mailing Platforms (Mail chimp etc.) and any Marketing and Communications Agency with which the University has a contractual relationship. All three are acting as our agents (data processors) with data sharing agreements in place. Sharing data with AAA is strictly for the promotion of alumni engagement and fundraising purposes. Whereas data release to Mailing Platforms and MC Agencies is strictly used for mailing purposes and personalizing messages to AUBG alumni, donors and friends.

Please note that your information may be transferred to, stored or processed in the United States of America, since Mail chimp servers and offices are located there. The relevant GDPR article permitting the transfer and the corresponding mechanism are an adequacy decision under Article 45, in particular, the so-called EU-U.S. Privacy Shield Framework. For more information about this mechanism and Mailchimp’s certification to it, please refer to Section E. International Transfers, (ii) Data transfers from Switzerland or the EU to the United States here

How long we keep your data

When it comes to alumni, donors and supporters of the University, we see our relationship with you as a lifelong one, which includes keeping in touch with us and those that you attended school with, and engaging in a continual mutually beneficial relationship. Therefore, information that is kept can be held indefinitely. This means that we will maintain a stakeholder record for you until such time as you notify us that you no longer wish us to keep in touch. In this instance the AUBG Development Office will delete the majority of your personal data it holds, but will maintain basic personal data to ensure we do not inadvertently create a new record in the future.

Any 3rd party to which AUBG provides personal data according to a contractual agreement is obliged to destroy/delete all information within six months after termination of the respective contract.

Your rights and how to exercise them
  • Your right of access: you have the right to obtain from us confirmation as to whether or not your personal data are being processed, and, where that is the case, a copy of your personal data. 
  • Your right to rectification: you have the right to obtain from us without undue delay the rectification of inaccurate data and/or the completion of incomplete data concerning you.
  • Your right to erasure ("right to be forgotten"): have the right to obtain from us the erasure of personal data concerning yourself without undue delay and AUBG shall have the obligation to erase it where you can prove that one of the grounds referenced in Art.17 from the GDPR Policy applies to you.
  • Your right to restriction of processing: you have the right to obtain from us restriction of processing of your personal data in any of the circumstances provided in Art.18 from the GDPR Policy.
  • Your right to object to processing: you have the right to object to any processing we carry out if we carry it out on the basis that it forms part of our public task or is in our legitimate interests. You also have the right to object to your personal information being used for direct marketing purposes.
  • Your right to data portability: you have the right to ask that we transfer the information you gave us from one organization to another or give it to you. The right only applies if we are processing information because we have your consent or because it is necessary for your pursuit of further academic or professional development.

If you wish to exercise any of the above rights or contact us about how we have handled your personal data, please email AUBG Data Protection Officer Ms. Margarita Petkova at dpo@aubg.edu or telephone her at +359 73 888 337.

If you wish to contact us to unsubscribe from our emails or update your details, email development@aubg.edu or visit the Contact Info Update Form.

If you would like to launch a complaint with respect to your data protection, you have the right to do so by contacting the Bulgarian Data Protection Supervisory Authority also known as (Bulgarian CPDP). Please find below address and contact details:

Bulgarian CPDP
www.cpdp.bg
2 Prof. Tsvetan Lazarov Blvd, Sofia 1592, Bulgaria
sofia2018@cpdp.bg

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