Privacy Policy

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Privacy Policy – January 22, 2022

Jesuit Worldwide Learning – Higher Education at the Margins (JWL) is a registered non-
government Association in Geneva, Switzerland (registration CHE 334 930 55999); registered in
the United States of America as a 501 c(3) non-profit entity organized in the State of Washington
(#46-2795989) and registered in Germany as a support Association (Förderverein VR
Nr.207992). JWL is committed to protecting your privacy.

We endeavour to at all times respect any personal information You share with Us, or that We
receive from other organisations, and keep it safe. The provision of your personal information to
Us is voluntary. This Privacy Policy (henceforth referred to as ‘Policy’) contains important
information about your personal rights to privacy, sets out Our data processing practices and
your rights and options regarding the ways in which your personal information is collected
(through Our Website – www.jwl.org) and used. Please read it carefully to understand how We
use your personal information.

Interpretation
The words of which the initial letter is capitalized have meanings defined under the following
conditions. The following definitions shall have the same meaning regardless of whether they
appear in singular or in plural.

Definitions
For the purposes of this Privacy Policy:

Account means a unique account created for You to access Our Service or parts of it.
Organization / JWL (referred to as either "the Organization", "We", "Us" or "Our" in this Agreement)
refers to Jesuit Worldwide Learning.
Cookies are small files that are placed on Your computer, mobile Device or any other
Device by a Website, containing the details of Your browsing history on that website among its many uses.
Country refers to: Switzerland, United States or Germany, where JWL is legally registered.
Device means any Device that can access the Service/Website such as a computer, a cell phone
or a digital tablet.
Personal Data is any information that relates to an identified or identifiable individual.
Service refers to the Website.
Service Provider means any natural or legal person who processes the data on behalf of
the Organization. It refers to third-party companies or individuals employed by the
Organization to facilitate the Service, to provide the Service on behalf of the Organization,
to perform Services related to the Service or to assist the Organization in analyzing how
the Service is used.
Usage Data refers to data collected automatically, either generated by the use of the
Service or from the Service infrastructure itself (for example, duration of a page visit).
Website refers to the Jesuit Worldwide Learning “Website”, accessible at http://www.jwl.org
You means the individual accessing or using the Service, or the Organization, or other
legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Policy Content Index

1. How is your Personal Data protected?
2. When do We collect personal information about You?
3. What personal information do We use?
4. How and why will We use your personal information?
5. Lawful bases
6. Communications for marketing/ fundraising
7. Donations
8. How long do We keep your personal information?
9. Will We share your personal information?
10. Security/ storage of and access to your personal information
11. International data transfers
12. Exercising your rights
13. Changes to this Policy
14. Links and third parties
15. Cookies
16. How to contact Us

1. How is your Personal Data protected

Your Personal Data is protected by specific legislation, including:

The Privacy and Electronic Communications (EC Directive) Regulations 2003, as
amended by The Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011
Directive 2009/136/EC of 25 November 2009 (“The European Union Cookie Directive”).
European Union’s General Data Protection Regulation (EU) 2016/679, specifically Article 5 (GDPR).
United States of America Gramm-Leach-Bliley Act (GLBA).
United States of America Family Educational Rights and Privacy Act of 1974 as amended (FERPA).
United States of America Health Insurance Portability and Accountability Act (HIPPA)

2. When do We collect personal information about You

When You give it to Us directly
For example, personal information that You submit through Our Website by making a
donation, signing up for Our e-mail newsletter or filling in a form to register your interest
in Our activities (volunteering, becoming a professor, a tutor, a donor), or personal
information that You give to Us when You communicate with Us by email, phone, letter,
through Our Website and social media sites.
When it is available publicly
Your personal information may be available to Us from external publicly available
sources. For example, depending on your privacy settings for social media services, We
may access information from those accounts or services (for example when You choose
to interact with Us through platforms such as Facebook, You-Tube, Instagram or Twitter)

When You visit Our Website

We do not collect any personal information when You browse Our Website. We only collect
personal information if You choose to do so by subscribing to Our newsletter, communicate an
interest in becoming a professor and tutor via the online application process or volunteer by
emailing jwlinfo@jwl.org, and wish to donate). In general, We may combine your personal
information from these different sources for the purposes set out in this Policy.
JWL Newsletter
Via Our Website You can also register for Our Newsletter. In this case, You are giving your
consent to processing your email address for the purpose of sending a Newsletter with
information about JWL. We will not transfer the email address We have received for newsletters
to any third party, except for the purpose of sending out the newsletter, where We may work with
a specialised provider contracted by Us:

Mailchimp: https://mailchimp.com/legal/privacy/, The Rocket Science Group LLC d/b/a
MailChimp, 675 Ponce de Leon Ave NE, Suite 5000 Atlanta, GA 30308 USA. You can, of
course, unsubscribe from the newsletter at any time via email jwlinfo@jwl.org, or better
by following the instructions provided at the bottom of each newsletter. After
unsubscribing, your email address will be removed from the system handling the
newsletter.

Social Plugins

Facebook Like Button: https://de-de.facebook.com/full_data_use_policy by Facebook Inc.,
1601 S. California Avenue, Palo Alto, CA 94304, USA; Facebook, 4 Grand Canal Square, Dublin 2, Ireland
Twitter Tweets: http://twitter.com/privacy by Twitter Inc., 1355 Market St, Suite 900,
San Francisco, CA 94103, USA; Twitter, 1 Cumberland Place, Dublin 2, Ireland
Instagram integration, https://help.instagram.com/155833707900388, by Instagram LLC,
1601 Willow Rd, Menlo Park CA 94025, USA
LinkedIn Share Button, https://www.linkedin.com/legal/privacy-policy by LinkedIn Ireland
Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland
YouTube: https://support.google.com/youtube/answer/2801895?hl=en, YouTube LLC, 901
Cheery Ave., San Bruno, CA 94066, USA

Most of those services will not be contacted unless You specifically click on the respective
buttons, but they may also establish a direct connection, which will allow the services to combine
the information that you are accessing Our Service with your Account information, if You are
logged in to the respective service. Upon clicking the respective logo, the information will then
be made publicly available, according to the specific policies of the service as well as your
preferences within that service.

Becoming a JWL Professor or Tutor
Should You be interested in applying and registering to become a JWL Professor or Tutor, You
will have to agree to the following data application processing. In order to register as a JWL
Professor or Tutor, You must successfully apply first. The application process meets two more
goals:

To ensure that You are eligible to become a Professor or Tutor.
To ensure that You meet Our eligibility criteria as a JWL Professor or Tutor, according to
your qualifications and motivation.

The following pieces of data are collected and used to create your JWL Professor or Tutor
Account as an applicant:

first name
last name
email
gender
country
city
date of birth
phone number
languages spoken
country You went to school
your education level
your previous educational degrees
name of university
resume
Your current position
Your current employer and employer location
Previous experience and skills

The respective documents uploaded or emailed to Us by You are stored separately from your
Account information.

When your application is successful You may be provided an email Account with an address
having either your first and last names or two letters, representing the first initial of your first and
last names, and a number. This Account will be maintained either by Microsoft 365 or Google
Inc., and administered by Us as part of their Microsoft and/or Google-for-Nonprofits programme
respectively.

The Data is transferred to Microsoft or Google Inc., under an agreement, which includes the
standard-clauses predefined by the European Commission, as a possible legal basis for such
transferal.

To use Our Service You will need to agree to Microsoft’s terms of Service and Privacy Policy:
https://privacy.microsoft.com/de-de
https://www.microsoft.com/en-ie/eucompliancedoc/default.aspx
https://privacy.microsoft.com/de-de/privacystatement
To use Our Service You will need to agree to Google’s terms of Service and Privacy Policy:
https://www.google.com/intl/en/policies/terms/
https://www.google.com/policies/privacy/
Effectively, the Account entails a number of functions. A core functionality, besides Email, is the
use of the login-mechanism, i.e. You will need to login via this Account, when wanting to access
Our Services.

Services
As a JWL Professor or Tutor, You are given access to a number of Services and functionalities
of the platform, for which Personal Data needs to be collected. Specifically:

to provide recommendations for supporting which online courses
to provide further information about Our recent developments at JWL
to deliver a possibility for exchange through Our online learning forum

JWL may collect, process and use the content and other information Users provide when using
the Services, including the data submitted for signing up for a Service, creating or sharing
content, and messaging or communicating with others on the Website. Such information may
include:

first name
last name
email
gender
country location
city
date of birth
phone number
etc.

Additional Information via phone, email and other means. JWL may send You updated
information via email or other messaging Services for which the respective contact details are
used.

These Services include:

WhatsApp: for certain services We may also ask You to communicate through
WhatsApp Messenger service ( https://www.whatsapp.com/legal/#privacy-policy)
Microsoft 365 (https://www.microsoft.com/en-us/microsoft-365) and its Teams App
(https://www.microsoft.com/en-us/microsoft-teams/group-chat-software)
Google Hangouts: may be used for phone conversations with students and video calls
within JWL -organized group tutorial sessions (https://www.google.com/+/policy/call-phones-terms.html)
Facebook Groups: May be used for recruiting purposes and for the Organisation
of student events. (https://www.facebook.com/legal/FB_Work_Privacy)

Such messages may include information about Our Organization and recent developments. We
may also contact You in case of questions in connection with the JWL Website, as well as to
inform You on changes with regard to this Data Privacy Policy or any other Terms of Services.

Other disclosures
Other than in the aforementioned cases, JWL will not transmit your Personal Data to any third
parties, unless We are obliged to do so because of legal regulations (e.g. disclosure to courts or
law enforcement authorities), You have given Us your explicit consent, or the disclosure is
permitted by law. A disclosure may for example be permitted when such disclosure is required
for Us to be able to render Our Services to the user on the JWL Website.

3. What personal information do We use?

We may collect, store and otherwise process the following kinds of personal information:

your name and contact details including postal address, telephone number, email
address and, where applicable, social media identity;
your financial information, such as bank details and/ or credit/ debit card details, Account
holder name, sort code and Account number;
personal descriptions and photographs;
details of your qualifications/ experience;
any other personal information which You choose to share with Us.

Do We process special categories of data?
The EU General Data Protection Regulation (GDPR) recognizes certain categories of personal
information as sensitive and therefore requiring more protection, for example information about
your health, ethnicity and political opinions.

In certain situations, the JWL may collect and/or use these special categories of data. We will
only process these special categories of data if there is a valid reason for doing so and where
the GDPR allows us to do so.'

4. How and why will We use your personal information?

Your personal information, however provided to Us, will be used for the purposes specified in
this Policy. In particular, We may use your personal information:

to provide You with information You have requested;
to provide Services to Our beneficiaries (students);
to provide further information about Our work, Services or activities (where necessary,
and only where You have provided your consent to receive such information);
to process your donations;
to answer your questions/ requests and communicate with You in general;
to manage relationships with Our supporters and beneficiaries;
to further Our charitable aims in general, including for fundraising activities;
to analyse and improve Our work, Services, activities or information (including Our
Website), or for Our internal records;
to report on the impact and effectiveness of Our work;
to run/ administer Our Website, keep them safe and secure and ensure that content is
presented in the most effective manner for You and for your Device;
to register, administer and personalise online accounts;
to register and administer your participation in events;
to process your application for a job or volunteer role with Us when You apply through
Our Becoming a professor, Becoming a tutor or Get involved pages;
to administer your employment/contracting/voluntee agreement relationship with Us;
to audit and/ or administer Our accounts;
to satisfy legal obligations which are binding on Us, for example in relation to regulatory,
government and/ or law enforcement bodies with whom We may work (for example
requirements relating to the payment of tax or anti-money laundering);
for the prevention of fraud or misuse of Services; and/or
for the establishment, defense and/ or enforcement of legal claims.

5. Lawful bases

The GDPR requires Us to rely on one or more lawful bases to use your personal information. We
consider the grounds listed below to be relevant:

Where You have provided your consent for Us to use your personal information in a
certain way (for example, You have subscribed to receive Our newsletter or e-mailed Us
asking for further information about or programmes).
Where necessary so that We can comply with a legal obligation to which We are subject
(for example, where We are obliged to share your personal information with regulatory
bodies which govern Our work and Services).
Where necessary for the performance of a contract to which You are a party or to take
steps at your request prior to entering a contract (for example, if You apply to work for/ volunteer with Us).
Where there is a legitimate interest in Us doing so.

The GDPR allows Us to collect and process your personal information if it is reasonably
necessary to achieve Our or others’ legitimate interests (as long as that processing is fair,
balanced and does not unduly impact your rights).

In broad terms, Our “legitimate interests” means the interests of running JWL as a charitable
entity and pursuing Our aims and ideals; for example providing information about current
humanitarian crises, processing donations, administering events and taking applications for
volunteers.

When We process your personal information to achieve such legitimate interests, We consider
and balance any potential impact on You (both positive and negative), and your rights under data
protection laws. We will not use your personal information for activities where Our interests are
overridden by the impact on You, for example where use would be excessively intrusive (unless,
for instance, We are otherwise required or permitted to by law).

6. Communications for marketing/ fundraising

We may use your contact details to provide You with information about Our work, events,
Services and/ or products which We consider may be of interest to You (for example, about
Services You previously used, or updates about fundraising appeals and/or volunteering
opportunities via Our newsletter).

Where We do this via email or telephone, We will not do so without your prior consent (unless
allowed to do so via applicable law). Where You have provided Us with your consent previously
but do not wish to be contacted by Us about Our projects in the future, please let Us know by
email at jwlinfo@jwl.org. You can opt out of receiving emails from the JWL at any time by clicking
the “unsubscribe from this list” link at the bottom of Our emails.

7. Donations

When You use Our secure online donation function You will be directed to a specialist payment
Services provider who will receive your financial information to process the transaction. We will
provide your personal information to the payment Services provider only to the extent necessary
for the purpose of processing your donation.

8. How long do We keep your Personal Information?

In general, unless still required in connection with the purpose(s) for which it was collected
and/or processed (for example for employment, contracting or volunteering), We remove your
personal information from Our records six years after the date it was collected. However, if
before that date (i) your personal information is no longer required in connection with such
purpose(s), (ii) We are no longer lawfully entitled to process it or (iii) You validly exercise your
right of erasure (please see Section 11 below), We will remove it from Our records at the relevant
time. Please note where legally required, We will maintain your Data accordingly and as required
by law as it relates to employment, contracting or volunteering.

If You request to receive no further contact from Us, We will keep some basic information about
You on Our suppression list in order to comply with your request and avoid sending You
unwanted materials in the future.

9. Will We share your personal information?

We do not sell or rent your personal information to third parties for marketing purposes.
However, in general We may disclose your personal information to selected third parties in order
to achieve the purposes set out in this Policy:

JWL USA;
JWL Förderverein Germany;
JWL Association Switzerland;
Suppliers, partners and sub-contractors for the performance of any contract We enter
into with them, for example IT service providers such as website hosts or cloud storage
providers (Seitwerk GmbH);
financial companies such as Paypal that collect or process donations on Our behalf;
professional service providers such as accountants and lawyers;
news media outlets;
social media platforms (certain online identifiers, such as IP address, only);
regulatory authorities, such as tax authorities;

In particular, We reserve the right to disclose your personal information to third parties:

if We are under any legal or regulatory duty to do so; and/or
to protect the rights, property or safety of JWL, its personnel, users, visitors or others

10. Security/ storage of and access to your personal information

JWL is committed to keeping your personal information safe and secure. We have appropriate
and proportionate security policies as well as organisational and technical measures in place to
help protect your information. Your personal information is only accessible by appropriately
trained staff, volunteers and contractors, and stored on secure servers with features enacted to
prevent unauthorised access.

IT Security

For the purpose of handling security incidents and to help diagnosing problems with Our servers,
We automatically store log files of the data which your browser sends when visiting the page.
Additionally We collect diagnostic data which may include personally identifiable information,
such as:

Name (as You enter it to a form on Our Website)
Email address (which You use to Login or enter on Our Website)
Username (which You use on Our Website)
Mobile Device ID (of your mobile Device)
IP Address (the number that is automatically assigned to your computer when You use the Internet)
Browser type and -version
Operating System
Referrer URL (the page, from which this page was linked, including the search term, in
case of a search engine)
Time and date of the request.

11. International Data Transfers

Given that We are part of an international organisation and because We use agencies and/ or
suppliers to process personal information on Our behalf, it is possible that personal information
We collect from You will be transferred to and stored in a location outside the European
Economic Area (“EEA”), for example the United States.

Please note that some countries outside of the EEA have a lower standard of protection for
personal information, including lower security requirements and fewer rights for individuals.
Where your personal information is transferred, stored and/or otherwise processed outside the
EEA in a country that does not offer an equivalent standard of protection to the EEA, We will take
all reasonable steps necessary to ensure that the recipient implements appropriate safeguards
(such as by entering into standard contractual clauses) designed to protect your personal
information and to ensure that your personal information is treated securely and in accordance
with this Policy. If You have any questions about the transfer of your personal information, please
contact Us using the details noted under section #16.

Unfortunately, no transmission of your personal information over the internet can be guaranteed
to be 100% secure – however, once We have received your personal information, We will use
strict procedures and security features to try and prevent unauthorised access.

12. Exercising your Rights

Where We rely on your consent to use your personal information, You have the right to withdraw
that consent at any time. You also have the following rights:

Right of access – You can write to Us to ask for confirmation of what personal
information We hold on You and to request a copy of that personal information. Provided
We are satisfied that You are entitled to see the personal information requested and We
have successfully confirmed your identity, We will provide You with your personal
information subject to any exemptions that apply.
Right of erasure – at your request We will delete your personal information from Our
records as far as We are required to do so. In many cases We would propose to suppress
further communications with You, rather than delete it.
Right of rectification – if You believe Our records of your personal information are
inaccurate, You have the right to ask for those records to be updated. You can also ask
Us to check the personal information We hold about You if You are unsure whether it is
accurate/up to date.
Right to restrict processing – You have the right to ask for processing of your personal
information to be restricted if there is disagreement about its accuracy or legitimate
usage.
Right to object – You have the right to object to processing where We are (i) processing
your personal information on the basis of the legitimate interests ground, (ii) using your
personal information for direct marketing or (iii) using your information for statistical
purposes.
Right to data portability – to the extent required by the GDPR, where We are processing
your personal information (that You have provided to Us) either (i) by relying on your
consent or (ii) because such processing is necessary for the performance of a contract
to which You are party or to take steps at your request prior to entering into a contact,
and in either case We are processing using automated means (i.e. with no human
involvement), You may ask Us to provide the personal information to You – or another
service provider – in a machine-readable format.
Rights related to automated decision-making – You have the right not to be subject to a
decision based solely on automated processing of your personal information which
produces legal or similarly significant effects on You, unless such a decision (i) is
necessary to enter into/perform a contract between You and Us/another organisation; (ii)
is authorised by EU or Member State law to which JWL is subject (as long as that law
offers you sufficient protection); or (iii) is based on your explicit consent.

We may ask You for additional information to confirm your identity and for security purposes,
before disclosing personal information requested to You. Please note that some of these rights
only apply in limited circumstances. For more information, We suggest that You contact Us using
the details below.

You are further entitled to make a complaint about Us or the way We have processed your
personal information to the data protection supervisory authority in your home country. In the
Switzerland, the data protection authority is the Federal Data Protection and Information
Commissioner (EDÖB/FDPIC) (http://www.privatim.ch/de/privatim/ or
https://www.edoeb.admin.ch/edoeb/de/home.html). In Germany, it is Die Bundesbeauftragte
für den Datenschutz und die Informationsfreiheit (http://www.bfdi.bund.de/).

13. Changes to this Policy

We may update this Policy from time to time. We will notify You of significant changes by
contacting You directly where reasonably possible for Us to do so and by placing an update
Policy on Our Website. This Policy was last updated on 25 January 2022. You are advised to
review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are
effective when they are posted on this page.

14. Links and third parties websites

We link Our Website directly to other sites. This Policy does not cover external websites and We
are not responsible for the privacy practices or content of those sites. We encourage You to read
the privacy policies of any external websites You visit via links on Our Website.
Our Website may contain links to other websites that are not operated by Us. If You click on a
third party link, You will be directed to that third party's site. We strongly advise You to review the
Privacy Policy of every site You visit. We have no control over and assume no responsibility for
the content, privacy policies or practices of any third party sites or services.

15. Cookies

In order to optimize Our Services, We use Cookies on different pages of the JWL platform.
Cookies are small text files that are stored on your Device. We use Cookies and similar tracking
technologies to track the activity on Our Website and store certain information. Some of the
Cookies will be deleted at the end of your browser session (so-called session Cookies). Other
Cookies may remain on your Device and allow Us to identify your browser the next time You visit
the JWL platform (so-called persistent Cookies).
If any of the Cookies which are implemented on Our Website process personal information, then
only for the purpose of improving the usability of the Website and within Our legitimate interest
in accordance with Art. 6 para. 1 lit. f EU GDPR.
Tracking technologies used are beacons, tags, and scripts to collect and track information and
to improve and analyze Our Website. The technologies We use may include:

Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can
instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent.
However, if You do not accept Cookies, You may not be able to use some parts of our
Service. Unless You have adjusted Your browser setting so that it will refuse Cookies, our
Service may use Cookies.
Web Beacons. Certain sections of Our Service and Our emails may contain small
electronic files known as web beacons (also referred to as clear gifs, pixel tags, and
single-pixel gifs) that permit the Company, for example, to count users who have visited
those pages or opened an email and for other related website statistics (for example,
recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal
computer or mobile Device when You go offline, while Session Cookies are deleted as soon as
You close Your web browser. We use both Session and Persistent Cookies for the purposes set
out below:

Necessary / Essential Cookies
Type: Session Cookies / Administered by: Us
Purpose: These Cookies are essential to provide You with Services available through the Website
and to enable You to use some of its features. They help to authenticate users and prevent
fraudulent use of user accounts. Without these Cookies, the Services that You have asked for
cannot be provided, and We only use these Cookies to provide You with those Services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies / Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies
Type: Persistent Cookies / Administered by: Us
Purpose: These Cookies allow Us to remember choices You make when You use the Website,
such as remembering your login details or language preference. The purpose of these Cookies
is to provide You with a more personal experience and to avoid You having to re-enter your
preferences every time You use the Website.

You can set your browser so that it enables You to decide in each case whether or not to accept
or reject all Cookies or specific Cookies being installed by a webpage. In case of non-acceptance
of Cookies, the functionality of the JWL platform may be limited. More information about the
Cookie settings for your browser can be found under following links:

Google Chrome:
https://support.google.com/accounts/answer/61416?hl=en&co=GENIE.Platform%3DDesktop
Mozilla Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-
your-computer
Microsoft Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-
internet-explorer-delete-manage-cookies
Apple Safari: https://support.apple.com/kb/ph21411
Opera: http://help.opera.com/Windows/10.20/en/cookies.html

16. How to contact Us

Please let Us know if You have any questions or concerns about this Policy or about the way in
which JWL processes your personal information by contacting Us at the following channels:

Email: jwlinfo@jwl.org
Telephone: +41 (0)22 525 3833
Post: Jesuit Worldwide Learning, 18 Rue Jacques-Dalphin, 1227 Carouge, Geneva, Switzerland