This privacy notice outlines how and why the American University in Bulgaria (AUBG) collects, uses and stores your personal data, and your rights in relation to the personal data we hold. We may modify or amend this Privacy Notice. The most current version will always be available on our Website and, where appropriate, notified to you by e-mail. If you have any questions about such matters you can contact us at [email protected].
What personal data do we collect?
The personal information we collect from you is the following:
- personal data including your name, date of birth and gender;
- contact data including your home address, citizenship, email address and phone number;
profile data including your specific requests, preferences, feedback, survey responses and usernames on social media channels;
- usage data including your IP address, browser and technology, how you use our website, social media and services;
- academic history including your high school, your GPA, your activities and achievements in and outside of school, contact information of people recommending you, etc.;
- marketing data including your preferences in receiving marketing messages and materials from us;
- information about your family as part of the application process;
- in case you are applying for financial support, we will require information about your family’s financial situation. Please refer to the link for the specific information in the application for financial assistance;
- special categories personal data (origin), only in case you apply for scholarships designated for specific groups.
How do we collect your personal data?
We collect information about you when you:
- request information to be sent to you; attend or register for an event, an educational fair or high school visit;
- visit our campus;
- participate in an AUBG Competition;
- apply for admission to AUBG on our portal;
- submit your test scores to us as part of the application process;
- enter a competition, promotion or agree to participate in market research (such as surveys or questionnaires);
- interact with any AUBG page or account on a social media platform, or when you use your social media account or credentials to log in to the Website;
- provide your personal information to other parties such as Common application form, College Board, ETS, CIS (Council of International schools), official University representatives, educational consultants and others*.
Note:* When we obtain personal data from third party sources, we will look to ensure that the third party has lawful authority to provide us with your personal data.
The basis for processing your information and how we use it
Receiving and processing your personal data as a prospective student, as listed above, when you participate in school visits, educational fairs, when you visit AUBG and/or other AUBG-organized events in Bulgaria and abroad, is based on your consent – Art. 6 (1) (a), and is used in the recruitment and application cycle.
Receiving and processing your personal data as an applicant, as listed above, when you apply for admission to AUBG on our portal, or through our local representatives or partnering institutions, is based on Art. 6 (1) (b) – contractual obligation / pre-contractual obligation (steps at your request prior to entering into a contract with AUBG) and is used in the recruitment and application cycle.
Receiving and processing your special category personal data (if applicable) as part of your application package, is based on your consent – Art. 9 (2) (a), and is used in the recruitment and application cycle.
In this respect, we use your personal data for the following:
- to provide our core teaching, learning and research services to you, as outlined in AUBG Student Handbook, once you have enrolled at AUBG;
- to administer financial aid and scholarships, according to eligibility requirements;
- to provide library, bookstore, IT and information services;
- to provide student support services (Disability and additional learning support, Careers and Advising Services, Student Medical Centre and psychologist services);
- to ensure students’ safety and security;
- to manage student accommodation; to deal with any concerns or feedback you may have;
- to improve the application process and the student experience by gathering statistical data, conducting surveys etc.;
- to process personal data for other purposes for which you provide it to us.
We may also process your personal data because it is necessary for the performance of our tasks carried out in the public interest, as set out in our mission statement and values, which can be found at https://www.aubg.edu/about-us/ or because it is necessary for our legitimate interests. In this respect, we may use your personal data for the following:
- to provide you with educational services not listed in the AUBG Student Handbook but which are part of our academic and educational mission;
- to monitor and evaluate the performance and effectiveness of the university, including training and/or monitoring our staff performance;
- to maintain and improve the academic, corporate, financial, estate and human resource management of the university;
- to promote equality and diversity throughout the university;
- to promote our services (e.g. provide information about summer schools, student exchange programs, or other events happening on and off campus);
- to seek advice on our rights and obligations;
- to recover money you may owe to AUBG;
- to support our fundraising efforts.
We may also process your personal data in relation to compliance with our legal obligations. In this respect, we may use your personal data for the following:
- financial audits;
- compliance with our regulatory and legal obligations;
- compliance with anti-money laundering laws and safeguarding requirements;
- prevention and detection of crime;
- criminal investigations – assist with investigations (including criminal investigations) carried out by the police and other competent authorities.
We may also process your personal data where:
- it is necessary for medical purposes (e.g. medical diagnosis, provision of health or social care or treatment, or a contract with a health professional);
- it is necessary to protect your or another person’s vital interests; or we have your specific or, where necessary, explicit consent to do so.
Control and care over your data
We, as an institution with one of the highest rankings in Bulgaria, are striving to improve and upgrade our control systems – to include pseudonymisation of the collected and processed data, access controls, defined within the university, and most importantly – applied due care by our staff and faculty members. All measures are implemented against inadvertent or deliberate manipulation, loss, or destruction, and access by unauthorized persons
With whom we share your data?
Your data may be shared with public authorities, such as Bulgarian Ministry of Education, National Agency for Evaluation and Accreditation, Ministry of Foreign affairs (for visa purposes), etc. as part of our legal obligations. In cases we need to transfer your personal data to other third parties – donors, US loan institutions, internal and external auditors, insurance companies, etc., as part of our contractual obligations – you will be notified. In any case, we will share your personal data with high attention to the third parties’ level of technical and organizational ability to manage personal data as required by the GDPR standards.
How long we keep it?
Personal data collected through the application process is stored for a period of three years following the admissions’ cycle. If you enroll at AUBG, information and personal data will be retained according to the legal requirements of the local authorities for maintain your academic record (including archiving purposes).
The American University in Bulgaria (AUBG) can implement mandatory COVID-19 testing as part of its measures to prevent/limit the spreading of COVID-19 on the territory of the University and with the aim to protect the life and health of its students, employees and visitors. The mandatory COVID-19 testing is based on the legitimate interest of the controller AUBG – Art. 6, p. 1, (f) of the General Data Protection Regulation (GDPR). Please note that the actual testing is carried out in licensed laboratories by medical practitioners and AUBG does not process personal data at that stage. Once presented with information about the medical status of individuals, the processing of this data by the University is based on Art. 9, p. 2, (b) of the GDPR – processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject.
The AUBG has chosen tests that are most appropriate for the purposes of the testing and expenses for the tests are covered by the University. The AUBG will apply short retention periods by keeping the data related to the tests only for as long as it is necessary in order to make decisions connected with the purposes mentioned above: preventing/limiting the spreading of COVID-19 on the territory of the University and protecting the life and health of its students, employees and visitors. For your as a data subject in relation to the personal data we hold, please refer to the last section of this privacy notice.
Collection and use by third party vendors
We do not sell data or data-bases to third parties for any reasons.
You rights in relation to the personal data we hold
- to request an access to your personal data we hold;
- to rectify or erasure your personal data; to restrict or object to processing concerning your data;
- to request data transfer to other parties;
- to withdraw consent at any time, without affecting the lawfulness of processing based on consent before this withdrawal;
- to lodge a complaint with the supervisory authority – Commission for Personal Data Protection, address – 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592.
You may address your concerns or inquiries to our Data Protection Officer (DPO) – Gugushev and Partners Law Office, Yoanna Ivanova, e-mail: [email protected]; Address: 11A Aksakov Street, floor 5, Sofia 1000, Bulgaria, Telephone: +359 2 815 75 10
Please see AUBG Internal Rules for Data Protection for more information.