This Notice describes the practices of University of Dallas (“UD”) with respect to
the collection, use, storage, and disclosure (“processing”) of Personal Information
of students while at our Rome campus. This Notice applies to UD, with headquarters
at 1845 East Northgate Drive, Irving, Texas 75062, including our affiliated colleges,
schools and campuses (collectively “UD,” “us” or “our”). All students studying at
our Rome campus (referred to below as “you” or “your”) should carefully read the provisions
of this Privacy Notice.
“Personal Information,” as used in this Notice, means any information that can be
used to identify you, whether directly or indirectly, including by reference to an
identifier such as a name, an identification number, location data, an online identifier
or to one or more factors specific to your physical, physiological, genetic, mental,
economic, cultural or social identity.
You can contact UD’s Data Protection Officer (DPO) with any questions about this notice,
our data collection practices, or your rights. You can reach the DPO, Elizabeth Klunder,
c/o Data Protection Officer’s Office
This general notice may be supplemented by additional notices at the point of any
data collection. If you have specific questions about any of the data processing activities
described in this or any other notice, please contact the DPO.
The Information We Process About You
We process the information we collect from you directly, including when you apply
to study abroad, during our communications with you, when you sign up for classes
or other services, when you take classes, when you apply for financial aid, and when
you make use of UD equipment, facilities, and resources. This includes information
about you created by our faculty and staff, like your grades, scores, records of attendance
and participation, and recorded observations about you. It also includes information
about your payments made to us for tuition and other expenses.
In some cases, we will require that certain information be provided in order for us
to provide you with a service or take an action you request. We will indicate when
such information is required, and failure to provide required information may result
in our being unable to provide you with a service or take a requested action.
We use automated decision-making processes to process your data in certain contexts.
For example, we may automatically evaluate your grades or test scores to determine
your eligibility for enrollment in certain programs, receipt of certain honors, or
to provide you with offers of academic support. Similarly, the information in your
financial aid application may be used to generate a profile of your financial circumstances
that is used to make decisions about your eligibility for scholarships, loans, and
other financial assistance throughout your enrollment at UD. You can find out more
about the logic we use in our automated decision-making processes by contacting the
In addition, we collect the following kinds of information about you from third parties:
- Information we collect from other students or UD staff: Other students may provide
us with information about you, whether in the process of reporting an incident or
complaint on campus or alerting us to an emergency situation involving you. This information
can include your name, information about your behavior or activities, and other information
about the situation being reported to us.
- Information about your prior or concurrent educational history, which we collect from
other educational institutions (or from our own records in the event of a re-enrollment
or enrollment for a different degree).
- Health, wellness, and insurance information about you that we receive from healthcare
providers and/or insurance companies.
- Any criminal convictions or offenses, which we collect from third parties who provide
us with such information.
UD maintains video surveillance systems for the security of our premises. UD or our
contracted service operator may process images and video of you in connection with
the operation of these systems.
Purposes and Legal Basis for Processing Your Data
We process your Personal Information to operate UD and the programs you are enrolled
in, to provide you with financial aid, and to provide you with additional related
services (like housing, internet access, and health services). These uses include
- manage university billing, collecting, refunding and cashiering functions,
- provide desktop and software support services,
- administer programs and make decisions about course offerings,
- facilitate class diversity,
- monitor trends within our student body and individual courses,
- verify identity,
- ensure that the university is prepared for emergencies,
- enforce UD policies and applicable laws,
- file required reports with applicable governmental authorities,
- provide immigration and mobility services for you when you travel abroad to study,
- facilitate student directory and promotional activities.
We combine the data that we collect in order to provide these functions.
We have the following legal bases for processing the information you provide us or
that we collect about you:
- We have a legitimate interest in retaining and educating qualified students, complying
with laws and regulations that govern our conduct in the countries where we operate,
and administering UD and its programs in an efficient, ethical, and appropriate manner.
We process all the information we collect from or about you to meet these purposes.
- During the period of your enrollment, we may be required to process your Personal
Information to complete a contract that you have entered into with us, including to
be admitted to a program or receive financial aid, housing, or another service from
- We may be required to process your Personal Information to comply with laws applicable
in the European Union or its member states, such as immigration laws.
In the case of Sensitive Personal Information (which includes (i) information revealing
racial or ethnic origin, political opinions, religious or philosophical beliefs, or
trade union membership; (ii) genetic and biometric data, and (iii) data concerning
health, sex life, or sexual orientation), we process this information only where (i)
we have your explicit consent to do so, (ii) it is necessary to provide health care
services to you, or (iii) we are required to process the information to comply with
When we process your Sensitive Personal Information on the basis of your consent,
you may withdraw that consent at any time by contacting the DPO. If you withdraw your
consent, we may still be required to process your Sensitive Personal Information to
comply with applicable law, but we will explain to you at the time your consent is
withdrawn what processing activities will continue for legal compliance purposes.
Finally, we process your Personal Information for additional purposes that are compatible
with those already described, including for the purposes of conducting scientific,
statistical, or historical research or for the purpose of creating archives in the
public interest. Where possible, we do not use identifiable information for these
purposes, or we take steps, including making use of pseudonymous data, to limit the
amount of Personal Information we use in our research or archives.
Recipients of Your Personal Information
Your Personal Information will be received and processed by UD employees and personnel,
including third parties who provide services to UD in connection with the purposes
of processing described above. For example, we may disclose your information to service
providers who help us make travel arrangements, support our information technology
systems, or provide services to our students. We share your Personal Information with
our service providers only when they have agreed to process your Personal Information
only to provide services to us and have agreed to protect your Personal Information
from unauthorized use, access, or disclosure.
We also disclose your information to government authorities as required by laws that
regulate immigration, tax, compliance reporting, national security, and criminal activity.
Transfers to Third Countries
UD is an international university headquartered in the United States, and we may transfer
your Personal Information to the United States. UD has executed Standard Contractual
Clauses, as approved by the European Commission. These clauses permit UD to transfer
Personal Information from the EU to third countries, including the United States.
If you would like to receive a copy of UD’s Standard Contractual Clauses, you can
contact the DPO.
You can find more information about how long we retain Personal Information by consulting
our Retention and Disposal Policy, available here: https://udallas.edu/about/university-policies/_documents/approved-records-retention-policy_9-18.pdf. In some cases, we may be required by law to retain your information for a longer
You have the right to the following information regarding UD’s processing of your
- the purposes of the processing,
- the categories of Personal Information concerned,
- the recipients or categories of recipients to whom the Personal Information have been
or will be disclosed,
- where possible, the envisaged period for which the Personal Information will be stored,
or, if not possible, the criteria used to determine that period.
This Privacy Statement is intended to provide this information. Any questions about
these details may be directed to the DPO.
You also have the following additional rights with respect to your Personal Information
processed while a student at our Rome campus:
- The right to request access to the Personal Information that UD has about you, as
well as the right to request rectification of any data that is inaccurate or incomplete.
- The right to request a copy of your Personal Information in electronic format so that
you can transmit the data to third parties, or to request that UD directly transfer
your Personal Information to one or more third parties.
- The right to object to the processing of your Personal Information for marketing and
- The right to erasure of your Personal Information when it is no longer needed for
the purposes for which you provided it, as well as the right to restriction of processing
of your Personal Information to certain limited purposes where erasure is not possible.
- The right to lodge a complaint with the Italian data protection authority: