PRIVACY POLICY
This policy governs the collection of personally
identifiable information through the Greenland Technical University website and
all its web-based information management systems including the Moodle.
POLICY STATEMENT
Greenland
Technical School is committed to protecting your privacy in accordance with
this privacy policy, which applies to the Greenland Technical School website,
its related websites, and content therein ("Website")
as well as the services available through this Website ("Services"),
and governs collection of personally identifiable information through the
website.
PLEASE READ THIS PRIVACY
POLICY CAREFULLY. By using the website, you give your consent to Greenland
Technical School data practices and understand that all personally
identifiable information that you submit may be processed by Greenland
Technical School in the manner and for the purposes described herein.
If you do not agree to the
terms and conditions set forth herein, do not use the website.
Collection of Personal Information
To apply for admission to Greenland
Technical School (“GTSZambia”, or the “School”), you must submit
personally identifiable information to the Greenland Technical University
website (“Website”).
“Personally identifiable information” ("PII") refers to data that
allows Greenland Technical University to identify you, such as your name,
gender, mailing address, telephone number, date and country of birth,
government-issued identification number, e-mail address, and other personal
information. If you submit personally identifiable information through any of Greenland
Technical University’s Communications Services (as described in the
University’s Terms of Use), that information may be collected and used in
accordance with this Privacy Policy.
Information and How We Use It
By
submitting your Personal Identification
Information (PII) to the Website, you understand and agree that Greenland
Technical University may collect, use, transfer, and disclose your personally
identifiable information as described in this Privacy Policy. The Website may
collect, process and use the data which includes PII, the legal basis of which
is your consent, which you give when you use the Services. Types of PII that
may be used include the following, without limitation:
• We may
process data about your use of our Website and Services ("User
Data"). User Data may include your IP address, location, type of browser
and version, operating system, referral source, visit length, page views and
website navigation paths, as well as information about the frequency and timing
of your use of the Service. The source of the User Data is an analytics
tracking system. User Data may be processed for the purposes of analyzing the use
of the Website and Services, operating our Website, improving and customizing
the Services, ensuring the security of our Services, maintaining back-ups of
our databases and communicating with you.
• When
registering or inquiring on our Website you may be asked to enter your name,
email address, mailing address, telephone number, email address, gender, date
of birth, or other details ("Entered Data"). You are the source of
such account data, and such data may be processed for the purposes of operating
the Website, providing the Services, ensuring the security of the Website and
Services, maintaining back-ups of our databases and communicating with you. The
Greenland Technical University will use your Entered Data for internal purposes
including, but not limited to, academic and financial advising, record-keeping
and tracking.
•
We may process information contained in any enquiry you submit to us
regarding Services ("Enquiry Data").
• We may
process information relating to transactions that you enter into with us and/or
through our Website, such as the purchasing of goods ("Transaction
Data"). The Transaction Data may include your contact details, your card
details and the transaction details. The Transaction Data may be processed for
supplying the purchased goods and Services and keeping records of transactions.
• We may
process information that you provide to us for the purpose of subscribing to
our email notifications, offering you services, or promotions which may
interest you ("Notification Data"). The Notification Data may be
processed for the purposes of sending you relevant Notification Data.
• We may
process information contained in or relating to any communication that you send
to us ("Correspondence Data"), for example, when you sign up for our
newsletter or respond to a survey or remarketing communication. The
Correspondence Data may include communication content and/or metadata
associated such communication. The Correspondence Data may be processed for
communicating with you and record-keeping.
• We may
process any of the types of data described in this Privacy Policy if we are
required to do so by court-order, any legal obligation to which we are subject,
or when necessary, for the establishment, exercise or defense of legal claims.
The legal basis for this processing is our legitimate interests, namely of the
Website's legal rights, your legal rights and the legal rights of others.
• Please do
not supply any other person's PII to us without the specific and explicit
consent of all parties, including the owner of such PII.
International transfers of your PII
In
this Section, we provide information about the circumstances in which your PII
may be transferred to countries inside and outside Zambia.
You
acknowledge that PII submitted by you for publication through the Services may
be available around the world via the internet. We cannot prevent the use or
misuse of published PII by others once you submit it for publication, nor are
we liable for such third-party use or misuse.
Such
use may involve transfer of personally identifiable information to servers
located outside the country from which you access the Website.
Transfers
to countries inside and outside Zambia will be protected by appropriate
safeguards, namely the provisions of applicable law which relate to the
protection of individuals with regards to the processing of PII to which a
party may be subject including, without limitation, the Cyber Security and Cyber Crimes Act
2021,
The
hosting facilities for our Website are provided by Servedez which is outside Zambia. The Zambian Commission has made an "adequacy decision" with
respect to the data protection laws of each of her citizen, which shall apply to you as a user of our sites. If you have
opted-in and knowingly subscribe to our newsletter or other forms of
correspondence, we may also use your information to inform you of new services Greenland
Technical University will be providing, inform you of scholarship applications
and academic programs provided by third parties, and send you requested
information and promotional materials for marketing purposes and research.
Collection and Use of Non-Personal Information
The University automatically collects non-personal
information about your computer hardware and software for the purpose of
improving the administration and content of the Website, facilitating use of
the University’s Website by its users, and to properly diagnose server problems
and other issues.
The
University may contract with third party providers to assist in better
understanding visitors to the Website. Third party providers are prohibited
from using any information they collect on behalf of Greenland Technical
University for any purpose other than helping the University conduct and
improve its services to you.
Information Sharing
The
University does not sell, rent or lease your personally identifiable
information to third parties without your prior written consent. Personally
identifiable information collected in connection with applications for
admission is, however, collected by a third-party service provider that hosts
the Website, and that information is released to application reviewers who may
include University employees, contractors, volunteers and other parties. These
individuals are prohibited from using your personally identifiable information
except in connection with Greenland Technical University services and any other
products and/or services you have requested, and they are required to maintain
the confidentiality of your information.
Greenland
Technical University may disclose your personally identifiable information,
without notice, (i) if required to do so by law, or (ii) in the good faith
belief that disclosure is necessary to protect or defend the rights, system,
network, property or personal safety of the University, its personnel or its
students. Greenland Technical University may disclose your personally
identifiable information, with prior notice, subject to your consent, to a
potential or actual partner or buyer in connection with a merger, acquisition,
or any form of sale of some or all of the University’s assets.
The
University requires opt-in consent (meaning, your express permission) to share
any sensitive personally identifiable information, such as medical information
or information concerning race or ethnicity, political or religious beliefs,
and sexuality.
Your Rights
In this
Section, we have done our best to summarize the rights that you have under data
protection law. These are complex, and not all of the details have been
included herein. In light of this, you should read the relevant laws and
guidance from the regulatory authorities for a full explanation of these
rights.
Your principal rights under data protection law are:
You have
the right to confirmation as to whether or not we process your personal data
and, where we do, access to the personal data, together with certain additional
information. That additional information includes details of the purposes of
the processing, the categories of personal data concerned and the recipients of
the personal data. Providing the rights and freedoms of others are not
affected, we will supply to you a copy of your personal data. The first copy
will be provided free of charge, but additional copies may be subject to a
reasonable fee. You can access your personal data by visiting the CRM Self-Service Portal when
logged into the website.
You have
the right to have any inaccurate personal data about you rectified and, taking
into account the purposes of the processing, to have any incomplete personal
data about you completed. Greenland
Technical University will also correct, amend or delete any personal
information that is inaccurate and notify any third-party recipients of the
necessary changes. Greenland Technical University may decline to process
requests that are unreasonably repetitive or systematic, require
disproportionate technical effort, jeopardize the privacy of others, are
extremely impractical, or for which access is not otherwise required by local
law or GDPR.
In
some circumstances you have the right to the erasure of your personal data [by
providing adequate evidence attesting to your identity] without undue delay.
Those circumstances include: the personal data is no longer necessary in
relation to the purposes for which they were collected or otherwise processed;
you withdraw consent to consent-based processing; the processing is for direct
marketing purposes; and the personal data have been unlawfully processed. There
are certain general exclusions of the right to erasure. Those general
exclusions include where processing is necessary: [for exercising the right of
freedom of expression and information; for compliance with a legal obligation;
or for the establishment, exercise or defense of legal claims].
In some
circumstances you have the right to restrict the processing of your personal
data. Those circumstances are: you contest the accuracy of the personal data;
processing is unlawful but you oppose erasure; we no longer need the personal
data for the purposes of our processing, but you require personal data for the
establishment, exercise or defense of legal claims; and you have objected to
processing, pending the verification of that objection. Where processing has
been restricted on this basis, we may continue to store your personal data.
However, we will only otherwise process it: with your consent; for the
establishment, exercise or defense of legal claims; for the protection of the
rights of another natural or legal person; or for reasons of important public
interest.
You have
the right to object to our processing of your personal data on grounds relating
to your particular situation, but only to the extent that the legal basis for
the processing is that the processing is necessary for: the performance of a
task carried out in the public interest or in the exercise of any official
authority vested in us; or the purposes of the legitimate interests pursued by
us or by a third party. If you make such an objection, we will cease to process
the personal information unless we can demonstrate compelling legitimate grounds
for the processing which override your interests, rights and
freedoms, or the processing is for the establishment, exercise or defense of
legal claims.
To
the extent that the legal basis for our processing of your personal data is
consent, and such processing is carried out by automated means, you have the
right to receive your personal data from us in a structured, commonly used and
machine-readable format. However, this right does not apply where it would
adversely affect the rights and freedoms of others.
If
you consider that our processing of your personal information infringes data
protection laws, you have a legal right to file complaint with a supervisory
authority responsible for data protection. You may do so in your habitual residence, your place of work or the place of the alleged
infringement, in harmony with the Zambian Cyber Security and Cyber Crime Act.
To the extent
that the legal basis for our processing of your personal information is
consent, you have the right to withdraw that consent at any time. Withdrawal
will not affect the lawfulness of processing before the withdrawal.
You
may exercise any of your rights in relation to your personal data by written
notice to us in addition to the other methods specified in this Section 5.
Opt-in
When
you provide us with PII for a secondary reason, like marketing or other
secondary reasons which we will convey to you from time to time if applicable,
we will ask for your consent. After you opt-in, you may withdraw your consent
anytime, by contacting us at info@greenlandzambia.tk
or registrar@greenlandzambia.tk
to
withdraw your consent to processing.
Security of your Personal Information
The
University maintains reasonable measures to protect your personally
identifiable information from unauthorized access, use or disclosure. The
University stores the personally identifiable information you provide on
computer servers in a controlled environment that has implemented protections
against unauthorized access, use or disclosure. Greenland Technical University
has implemented procedures to safeguard the integrity of its information
technology assets, including, but not limited to, authentication, monitoring,
auditing, and encryption. These security procedures have been integrated into
the design, implementation, and day-to-day operations of the Website as part of
University’s continuing commitment to the security of electronic content as
well as the electronic transmission of information.
For
website security purposes and to maintain the availability of the Website for
all users, the University employs software to monitor traffic and identify
unauthorized attempts to upload or change information or otherwise damage the
Website. When personally identifiable information (such as a credit card
number) is transmitted to other websites, it is protected through the use of
encryption, such as the Secure Socket Layer (SSL) protocol.
The University,
however, cannot guarantee that unauthorized third parties will never be able to
defeat the measures described in this section or use your personally
identifiable information for improper purposes. Nothing in this Privacy Policy
or in the University's Terms of Use shall be deemed a guarantee,
contract, or warranty of any kind, whether express or implied, regarding the
security of your personally identifiable information.
Educational Records
The
Family Educational Rights and Privacy Act (FERPA) of 1974 was designed to
protect the privacy of educational records, establish the rights of students to
inspect and review their educational records, and provide guidelines for the
correction of inaccurate or misleading information through informal and formal
hearings. While FERPA does not apply to the University, since it is not a federally-funded
institution, the University nonetheless strives to meet FERPA’s provisions to
the extent reasonably feasible.
The
University will not disclose a student's educational record without obtaining
the student's prior written consent, except that a student's educational record
may be disclosed (i) to other school officials, including teachers with a
legitimate educational interest and contractors, consultants, volunteers, or
other parties to whom Greenland Technical University has outsourced educational
or institutional services or functions; (ii) to parents of a dependent student.
The
University depends on the accuracy of the records submitted by its students.
False information on an application, or any other act to intentionally mislead
or misinform instructional personnel or administrators, is grounds for
disciplinary action, including dismissal from the University. Students seeking
access or amendment of their educational records should contact the Office of
Student Services at registrar@greenlandzambia.tk.
Children's Online Privacy Protection Act
Although
neither this website nor any of the University’s services are intended for
children under 13 years of age, the University complies with the Children’s
Online Privacy Protection Act of 1998 (“COPPA”) and does not knowingly collect
any personal information online from children under the age of 13.
Use of Cookies
The
Greenland Technical University Website may use "cookies", subject to your
consent if you are a resident of the European Union or are subject to GDPR, to
help you personalize your online experience. A cookie is a small data file that
is placed on your hard disk by a web page server. The purpose of a cookie is to
tell the web server that you have returned to a specific page. For example, if
you personalize Website pages, or apply for admission to Greenland Technical
University, a cookie helps the University recall your specific information on
subsequent visits. This simplifies the process of recording your personal
information, such as your name and mailing address. When you return to the
Website, the information you previously provided can be retrieved, so you can
more easily use the Greenland Technical University features.
Cookies cannot be used to run programs or deliver viruses to your
computer. Cookies are uniquely assigned to you, and can only be read by a web
server in the domain that issued the cookie to you.
By
using the Website, its related websites and other services, you hereby agree to
the use of cookies as described herein. Note that most web browsers automatically
accept cookies, but you can usually modify your browser settings to decline
cookies if you prefer. If you choose to decline cookies, you may not be able to
fully experience the interactive features of the Website.
Google Analytics
The
University uses Google Analytics to collect information about use of the
Website. The University uses the data it receives from Google Analytics to
improve the Website, and does not combine the IP address collected by Google
Analytics with your name or other identifying information that you may enter on
the Website. Greenland Technical University cannot control Google’s use of the
information it gathers; however, Google's right to use and share information
collected by Google Analytics about your visits to the Greenland Technical
University Website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google
Analytics from recognizing you on return visits to this site by deleting its
cookie or disabling cookies on your browser.
Your California Privacy Rights and Do Not Track Notices
California
Civil Code Section 1798.83 permits customers of a company who are California
residents to request certain information regarding its disclosure of personally
identifiable information to third parties for their direct marketing purposes.
To make such a request, please send an email to info@greenlandzambia.tk.
Please note that the University is only required to respond to one request per
customer each year.
Note that the University
does not respond to “Do Not Track” signals.
The
University’s Customer Relationship Management System (CRM) & AIMS. There is a
seamless transition from the University’s main website to the AIMS. You enter
the CRM & AIMS Portal every time you work on your application to the University or otherwise
log in to the Student Portal. The CRM & AIMS processes and maintains all Greenland
Technical University applications, student records such as course registration
history and grades, and data related to payment history such as invoices and
tracking numbers. Note that the AIMS does not store any of your personal bank
account or PayPal information.
We
are not allowed to use your personally identifiable information other than for
the provision of services to the University or as otherwise permitted by law.
For more information about the AIMS, you can review the terms of use.
All
of the University’s eLearning courses, classroom discussions, assignments, testing, the
academic advising messages system, and student and faculty forums are conducted
through Moodle, an open-source learning platform.
There is a seamless
transition from Greenland Technical University’s main website to the
University’s Moodle platform.
No
one outside the Greenland Technical University community is permitted to access
the Greenland Technical University Moodle platform. However, the Greenland
Technical University Moodle site administrators have access to nearly
everything in the system and certain private information is also accessible by
other Greenland Technical University students, faculty and staff:
1. Greenland
Technical University profile page. Every Greenland Technical University student
has a profile page in Moodle, which contains their first and last name, email
address (optional), profile picture (optional) and description (optional). This
information is visible to classmates for each course in which a student is
enrolled, and to all students, faculty and staff through the Academic Advising
Virtual Office. Greenland Technical University profile pages are NOT available
to the general public.
2. Greenland
Technical University discussion forums. Since Greenland Technical University is
based on the peer-learning model, the University makes great use of discussion
forums in its courses. Anything posted in a discussion forum is visible to the
instructor and to all students enrolled in that course. For large classes that
are divided into groups, only members of your group can see your posts. Your posts
will include your full name and profile picture if you have chosen to upload it
to the system.
3. Greenland
Technical University peer-assessed assignments. All assignments assessed by
other students in a particular course are submitted anonymously. Unless you put
your name on your peer-assessed assignment, which is not a requirement, only
instructors and administrators will be able to see who has evaluated your
assignment.
4. Private
messaging system. Only the sender and receiver can view the content of messages
sent through the Moodle privacy messaging system.
If you withdraw
from the University, your account will be disabled and will no longer visible
to students and instructors. Old and inactive accounts are usually deleted
after four years of nonuse.
Note
that if you choose to create a public profile on the moodle.org or moodle.net
sites, which are outside the Greenland Technical University Moodle platform,
your information may become public and the Moodle Privacy Policy shall apply.
The Greenland Technical University Yammer Enterprise
Network
Greenland
Technical University's Yammer Enterprise Network provides a collaborative
environment for Greenland Technical University students, faculty, alumni, staff
and volunteers from throughout the globe (“Greenland Technical University Community”)
to connect and share meaningful information. Note that there is a seamless
transition from Greenland Technical University’s main website to the
University’s Yammer Network.
By
enrolling in Greenland Technical University’s Yammer Network, you understand
and agree that your personal profile and any content you post will be visible
to other members of the Greenland Technical University Community and to anyone
outside the community who manages to log in to the Greenland Technical
University Yammer Network.
Confidential
student information and other sensitive or private content should not be posted
on the Yammer Network.
Although
Greenland Technical University administrators monitor all posts and comments to
the Greenland Technical University Yammer Network, you are ultimately
responsible for the content you post and Greenland Technical University has a
right and obligation to report any user who posts illegal content and threats
of violence to the authorities.
Prior
to enrollment in the Greenland Technical University Yammer Enterprise Network,
users should review Microsoft’s Yammer Privacy Statement and Greenland
Technical University’s Yammer Terms of Use.
Third Party Websites, Cookies and Privacy Policies
Certain
pages of the Website may contain links to websites that are not controlled by
the University. Third-party cookies may be set by websites such as Facebook,
Twitter, YouTube, Google Plus and other social media outlets or websites for
which Greenland Technical University may implement plugins. Greenland Technical
University may permit other companies to place cookies and use cookies
according to the university policies and in accordance with this Privacy
Policy.
Third-party Providers
In general,
the third-party providers used by us will only collect, use and disclose your
information to the extent necessary to allow them to perform the services they
provide to us. However, certain third-party service providers, such as payment
gateways and other payment transaction processors, have their own privacy
policies in respect to the information we are required to provide to them for
your purchase-related transactions.
For
these providers, we recommend that you read their privacy policies so you can
understand the manner in which your personal information will be handled by
these providers. In particular, remember that certain providers may be located
in or have facilities that are located a different jurisdiction than either you
or us. So, if you elect to proceed with a transaction that involves the
services of a third-party service provider, then your information may become
subject to the laws of the jurisdiction(s) in which that service provider or
its facilities are located. For example, if you are located in Canada and your
transaction is processed by a payment gateway located in the United States,
then your PII used in completing that transaction may be subject to disclosure
under United States legislation, including the Patriot Act.
Once
you leave our Website or are redirected to a third-party website or
application, you are no longer governed by this Privacy Policy or our Website’s
Terms of Service.
Third-party Links
Occasionally,
at our discretion, we may include or offer third-party products or Services on
our Website. These third-party sites have separate and independent privacy
policies. We therefore have no responsibility or liability for the content and
activities of these linked sites. Nonetheless, we seek to protect the integrity
of our site and welcome any feedback about these sites.
By
using this site, you represent that you are at least the age of majority in
your state, province or country of residence, or that you are the age of
majority in your state, province or country of residence and you have given us
your consent to allow any of your minor dependents to use this site.
Retaining and Deleting PII
This
Section 4 sets out our data retention policies and procedures, which are
designed to help ensure that we comply with our legal obligations in relation
to the retention and deletion of personal data.
We will retain and delete
your personal data as follows:
PII
will be retained for 25 years following the point of first contact with the
University at the end of which period it will be deleted from our systems.
Notwithstanding
the other provisions of this Privacy Policy, we may retain your PII where such
retention is necessary for compliance with a legal obligation to which we are
subject, or in order to protect your vital interests or the vital interests of
another natural person.
Third-party
cookies are not governed by this Privacy Policy. The University does not
control and is not responsible for the privacy policies or other content on
websites other than the Website, including websites linked to from the Website,
or for the use of personally identifiable information that you may submit to
any of those websites. The University encourages you to review the privacy
policies of those third-party websites directly so that you can understand how
those websites collect, use and share your information.
Changes to this Policy
This
Privacy Policy may be updated from time to time. Modifications will be denoted
by the “updated” notice at the top of this page. Your submission of personally
identifiable information to the Website following the posting of any changes to
this Privacy Policy constitutes acceptance of those changes. The University
encourages you to periodically review this Privacy Policy to be informed of its
policies respecting your personally identifiable information. By continuing to
access the Website after notice of modifications have been published, you
signify your agreement to be bound by the updated terms.
Compliance with this Policy
The University
regularly reviews its compliance with this Privacy Policy. If you have any
questions regarding this Privacy Policy, or believe that the University has not
adhered to any of its terms, please contact the University at info@greenlandzambia.tk.
This
Privacy Policy was last updated on 8th January, 2020.
Effective date: 8th June 2021.