Additional Privacy Disclosures under Non-Uganda Law for Individuals Located Outside Uganda

BIT Centre for Professional Skills Development > Additional Privacy Disclosures under Non-Uganda Law for Individuals Located Outside Uganda

Introduction

These privacy disclosures (these “Disclosures”) provide information on collection and use of data about individuals located in a Relevant Country (as defined below).

In these Disclosures,

“Personal Data” means information relating to an identified or identifiable individual; an identifiable individual is one who can be identified, directly or indirectly, by use of any identifier or characteristic specific to that individual.
“Relevant Law” means any non-Uganda. jurisdiction’s personal data protection law that applies to the processing of Personal Data by a BIT Entity.
“Relevant Country” means a country which has enacted a Relevant Law.
“In-scope Processing” means the collection, use, handling, processing or sharing of Personal Data by a BIT Entity when those activities are within the scope of any Relevant Law.
“BIT Entity” means a Billbrain Institute of Technology entity, center, or other BIT unit or BIT-controlled entity.

These Disclosures apply only to In-scope Processing. Please note that, depending on the situation, some of the BIT activities described below may in the given case not constitute In-scope Processing as that term is used in these Disclosures.

Further, these Disclosures apply only to the BIT Entities that link to these Disclosures or expressly adopt them in writing. In these Disclosures the words “we,” “us” or “our” refer to any such BIT Entities. In some cases, a BIT Entity or other BIT unit may provide other information about its In-scope Processing in its own supplemental or separate disclosures.

These Disclosures concern In-scope Processing by any means, including hardcopy (such as paper applications or forms) and electronic means (such as websites and mobile applications).

A. How We Collect and Use Personal Data

We use the Personal Data that we collect to carry on various institutional and educational activities as described in more detail below. The ways in which we collect and use your data vary depending on the relationship between you and us. The following sections of these Disclosures describe in more detail how and why we collect and use Personal Data in various circumstances that may involve In-scope Processing.

1. Personal Data We Collect

Websites and Mobile Applications

As is true of most digital platforms, we obtain certain data automatically when you use one of our websites or mobile applications, such as your IP address, browser type and device type. Certain web-forms also collect Personal Data you provide, for example when you enter data into form fields. If we also process data through our websites or mobile applications for one of the activities described further below, those descriptions will provide additional information about how those data are collected and used. We and our third-party vendors use this Personal Data for the primary purposes of conducting analytics, improving our websites, responding to your requests and providing you with relevant information including program offerings that we believe may be of interest.

Admissions and Financial Aid

We collect and use various kinds of Personal Data when you apply for admission to BIT or to a program or course offered by us, and when you apply for financial aid, if available. The primary source of these data is your voluntary submissions. We may solicit additional data, for example, from interviewers as part of the admissions process, if applicable, or from other available sources when we are looking for potential candidates for admission in connection with recruiting activities. The Personal Data collected by us, or on our behalf, during the admissions process are used for the primary purposes of considering your candidacy for admission to the relevant School, program or course, evaluating your eligibility for financial aid, if applicable, and, if you are admitted and enroll, facilitating your education (such as by sharing Personal Data with registrars and others in order to enable your enrollment and participation in the School, program or course to which you have been admitted).

Alumni and Donors

We collect and use various kinds of Personal Data about alumni, donors and prospective donors from a number of sources, including data you provide to us, for example, when you update your alumni or donor profile, connect with us on social media, complete a donation form or register to attend BIT events. If you were a student or studied at BIT, some of your Personal Data are transferred from your student record into our alumni databases. We may also collect Personal Data from publicly available sources or third-party sources that support our operations. The Personal Data collected by us, or on our behalf, are used for the primary purpose of providing you opportunities to engage with BIT, alumni, donors, prospective donors and students through interactions, events and your gifts or donations. We may disclose your data to other BIT affiliated entities and individuals such as alumni clubs and shared interest groups or volunteers in connection with the purposes described below.

Online Education

We collect your Personal Data when you apply or register for online education offerings. We and they also collect Personal Data when you participate in online courses, programs and activities. In some cases, our collection of Personal Data from you in connection with online education activities takes place as part of a “hybrid” program in which you also may participate in person, or as part of remote learning occurring in a course or program that is ordinarily conducted in person.

The Personal Data collected by us, or on our behalf, are used for the primary purposes of providing you with online education, and, if applicable, evaluating your qualification for related certificates or credit.

In-Person or Hybrid Educational Programs Conducted in Relevant Countries

We conduct certain educational programs in Relevant Regions and Countries, including executive education offerings and summer school programs, among others, and collect Personal Data as part of our administration of these offerings.

The Personal Data collected by us, or on our behalf, are used for the primary purposes of providing educational offerings and, if applicable, evaluating qualification for certificates and credit.

Research

Our researchers, research collaborators and service providers may collect, use and share your Personal Data as part of a research study in which you have agreed to participate as a research subject, or in which your existing data are used. Most often, before any Personal Data are collected for research purposes, as a research subject you will be provided a consent and/or authorization form relating to the specific research project that explains the types of data collected and the purposes for which such data will be processed and shared. In such a case, the description of the collection and use of your Personal Data provided in the consent and/or authorization form will replace the information provided here. The Personal Data collected by our researchers, research collaborators and service providers, or on their behalf, are used for the primary purposes of furthering the particular research project and more generally for supporting research and understanding in fields of academic study.

Examples of Personal Data that may be collected for research purposes are listed below. Of course, a single research study will rarely collect all of these types of data. If you have questions about the processing of your data in connection with a research study, you should contact the BIT personnel who are conducting the research or the contact persons named in any consent form you signed when you joined the study.

Employees, Job Applicants and Service Providers

We collect your Personal Data when you apply to work for us in a Relevant Country. Further Personal Data collection occurs at hiring and throughout your relationship with us. We may also collect Personal Data about personnel of vendors providing services to us in a Relevant Country.

The Personal Data collected by us, or on our behalf, are used for the primary purposes of providing employment, engaging with service providers, legal compliance, and enabling employees and service providers to utilize our services and facilities.

2. Personal Data We Obtain from Third Party Sources

As part of our In-scope Processing, we may obtain certain Personal Data about you from third party sources, which we may use for the purposes and in the ways described in “How We Collect and Use Personal Data” above and in “Additional Uses of Personal Data” below. In some cases, we may obtain your consent for additional uses.

Partners and Service Providers

We use partners and service providers, such as admissions application facilitators (for example, the Common Application and the Institute Board), payment processors (for example, Flutterwave and Pesapal, MTN, Airtel), analytics providers (for example, Google and Qualtrics), and platform providers (for example, Salesforce and Instructure/Canvas) to provide services for us. Some of these partners have access to Personal Data about you that we may not otherwise have (for example, when you sign up directly with that provider) and may share some or all these data with us.

Single Sign-On

Some of our online offerings or research activities may allow you to register and login through a third-party platform. When you login to our offering or activity through a third-party platform, you allow us to access and collect any Personal Data from your third-party platform account permitted under the settings and privacy statement of that platform.

Supplemental Personal Data

We may receive Personal Data from third-party sources, such as public or private databases (for example, compilations of email or postal addresses) and publications (for example, news reports), or companies or institutions that may sponsor or facilitate your participation in one of our programs, which we may also add to existing Personal Data.

3. Additional Uses of Personal Data

In addition to the uses described above, including under “How We Collect and Use Information” and “Personal Data We Obtain from Third Party Sources,” we may use your Personal Data for the following purposes. These additional uses may under certain circumstances be based on your consent, or may be necessary to fulfill our contractual commitments to you, for legal compliance, or to pursue our legitimate interest in the following activities:

Conducting our operations and administering and developing our educational offerings;
Administering fellowships, grants and other programs in support of individual study and research projects;
Responding to your requests for research assistance;
Processing and responding to your requests or inquiries of any other kind;
Providing you with newsletters, articles, service alerts or announcements, event invitations, volunteer opportunities, and other information that we believe may be of interest to you;
Requesting gifts and donations;
At your request, processing and fulfilling transactions for merchandise or other BIT products;
Providing travel-related services to you at your request;
Alerting you about a safety or security announcement;
Conducting research, surveys and similar inquiries to help us understand trends and needs of our applicants, students and others;
Meeting the requirements of our accreditors;
Disclosing directory information;
Performing marketing, promotions and advertising, either directly or through third-parties. These activities may include interest-based advertising, targeted advertising and online behavioral advertising in order to increase the likelihood that the content will be of interest to you;
Ensuring the rights, safety and security of our students, faculty, fellows, employees and others;
Preventing, investigating, taking action regarding or providing notice of fraud, unlawful or criminal activity, other misconduct, security or technical issues, or unauthorized access to or use of Personal Data, our website or data systems; or
Responding to subpoenas, court orders, or other legal process; fulfilling and enforcing our agreements and legal rights; protecting the health, safety, rights or property of you, us or others; and meeting legal obligations.

4. Data Retention

We will retain your Personal Data for as long as is necessary for the purposes set out in these Disclosures, in accordance with Relevant Law and the legal bases for acquiring the data.

For example, we may generally retain Personal Data as follows:

For as long as may be required under applicable law;
As needed to resolve disputes or protect our legal rights;
Where processing is based on your consent, for the period of time necessary to carry out the processing activities to which you consented;
Where processing is based on contract, for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship;
Where processing is based on the public interest, for the period of time that continues to serve that underlying interest.
Where processing is based on our legitimate interests, for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of the data subjects. In some cases, where Personal Data was primarily processed and retained on the basis of consent, contract, the public interest, or other bases described in these Disclosures, we may continue thereafter to retain the data based on a legitimate interest.

Consistent with the foregoing guidance, some data may be retained indefinitely.

B. How We Share and Disclose Personal Data

We share your Personal Data with third parties in the ways described in these Disclosures, including the “How We Collect and Use Personal Data” section above, as well as between BIT Entities. Additionally, we may share information as described below:

Service Providers

We share your Personal Data with third-party service providers that complete transactions or perform services on our behalf or for your benefit, such as:

Payment and contribution processing;
Customer relationship management services;
Marketing and analytics;
Processing admissions applications and applications for financial aid;
Alumni and donor outreach and engagement;
Event registration and coordination;
Providing course platforms or tools that enable or enhance our offerings;
Course registration and administration;
Course evaluations and assessments;
Enrollment verification;
Research insights and analytics;
Research collaboration;
Educational operations and collaborations;
Performing workforce administration and operations;
System maintenance and security;
Facilitating other transactions with you; and
Assisting with our legal compliance.

Partners

We may share your Personal Data with other institutions for the purposes of delivering programs and services, such as:

Cross-registration for courses and events with other institutes and universities;
Course registration and administration;
Course evaluations and assessments;
Study at other institutes and universities including study abroad at foreign institutes and universities;
Online education offerings through online platforms;
Research arrangements with other institutes and universities or partners; and
Events and activities of BIT-affiliated clubs and shared interest groups.

Third-Party Mobile App Providers

If you use certain of our mobile applications, your mobile device may gather and transfer your Personal Data, including location information, to other applications, functions and tools within your mobile device.

Social Media Platforms

We may also use services provided by third parties (such as social media platforms) to serve targeted ads or sponsored content on third-party platforms.

Legal Process, Safety and Terms Enforcement

We may disclose your Personal Data to legal or government regulatory authorities as required by law. We may also disclose your Personal Data to third parties in connection with claims, disputes or litigation, when otherwise required by law, or if we determine that disclosure is necessary to protect the health, safety, rights or property of you, us or others, or to enforce our legal rights or contractual commitments that you have made.

C. International Data Transfers

Much of our Personal Data processing takes place in the United States, though sometimes we or third parties with whom we share data may process data in other countries. The data protection laws in the United States and other countries may provide less protection than such laws in your Relevant Country. In the event we transfer your Personal Data outside your Relevant Country as part of our In-scope Processing, we rely where required on appropriate or suitable safeguards or specific legal provisions permitting such transfers under the Relevant Law.

When transferring Personal Data from a country in the European Economic Area (EEA) or from the United Kingdom (UK) to a country outside the EEA and the UK, we may base such transfers on contracts containing legally authorized data protection clauses referred to as Standard Contractual Clauses. You may request a copy of the Standard Contractual Clauses relevant to any such transfer of your Personal Data by contacting us as set forth in the “Contact Us” section below.

D. Cookies and Similar Technologies

Whenever you visit or use our websites or online services, we may deploy cookies and related technologies (“Cookies”) to collect certain personal information about you. We use the information in order to enhance and personalize the experience, to help provide our services, to analyze website and service usage, and to help improve the websites and our related services. To find out more about cookies, visit https://www.internetcookies.org/.

Third parties may also use Cookies embedded in our sites to collect information about your online activities over time and across different websites you visit. This information may be used by third parties to provide advertising tailored to your interests on other websites, apps and services you visit.

You can review your Internet browser settings, typically under the sections “Help” or “Internet Options,” to exercise choices you have for certain Cookies, or you can opt out of the collection and use of some Cookies through tools like the Network Advertising Initiative opt-out page. If you disable or delete certain Cookies in your settings, you may not be able to use features of our websites.

We may use third party analytics such as Google Analytics or similar analytics services. For information on how Google processes and collects information using Google Analytics, please see www.google.com/policies/privacy/partners/, and for how to opt out, please see https://tools.google.com/dlpage/gaoptout.

The opt-outs described above may not work for all browsers or devices.

If you have any questions regarding our use of cookies and other similar technologies, please contact us as set forth in the “Contact Us” section below.

E. Rights You May Have

To the extent required by Relevant Law, upon your reasonable and good faith request, we will inform you whether we hold any of your Personal Data as part of our In-scope Processing. With respect to your Personal Data collected and used in our In-scope Processing, under the Relevant Law you may also be able to:

obtain a copy of your Personal Data in an easily accessible format;
request that we correct or update any of your Personal Data that is inaccurate;
restrict or limit the ways in which we use your Personal Data;
object to the processing of your Personal Data;
request the deletion of your Personal Data; and
request that we transmit your Personal Data to another party.

To submit a request, please send an email message to cpsd@bit.ac.ug. Because we want to avoid taking action regarding your Personal Data at the direction of someone other than you, we may need to ask you for information verifying your identity. We will respond to your request within a reasonable timeframe.

If our In-scope Processing as to your Personal Data is solely based on your consent, in certain cases you may also have the right under a Relevant Law to withdraw your consent to our processing. If you withdraw your consent to the use or sharing of your Personal Data for the purposes set out in these Disclosures, or otherwise limit our use of your Personal Data or request its deletion, we may no longer be able to provide you some or all of the related services.

Please note that, in certain cases, we may continue to process your Personal Data after you have withdrawn consent or requested that we delete your Personal Data, if we have a legal basis to do so. For example, we may need to retain certain data to comply with an independent legal obligation, for achieving the lawful purposes for which we obtained the data, or for such reasons as keeping our services and operations safe and secure or safeguarding our rights or the rights or safety of others.

If you have any complaints regarding our privacy practices, you may be able to make a complaint to your national data protection authority, supervisory authority, or other legal authority.

F. User Generated Content

Some of our online activities, such as course websites, listservs, chat rooms and bulletin boards, enable users to submit their own content. Please remember that any Personal Data you submit or post as user-generated content in these circumstances could in some cases be seen by others or become public. You should exercise caution when deciding to disclose your personal, financial or other information in such submissions or posts. We cannot prevent others from using that information in a manner that may violate these Disclosures, the law or your personal privacy and safety. We are not responsible for the results of such postings.

G. Updates to the Disclosures

We may update these Disclosures from time to time without prior notice by posting revised Disclosures. You can determine when these Disclosures were last revised by checking the Last Updated date at the beginning of these Disclosures.

H. Representatives

Whereas we might have with time approved representatives who can act on our behalf, we do not have any officially approved representatives outside Uganda as of the date when this policy is published.

I. Contact Us

If you have any questions, comments, requests or concerns about these Disclosures or other privacy-related matters, you may contact us in the following ways:

Email: cpsd@bit.ac.ug
Address: Billbrain Institute of Technology
Attention: Communications & Public Relations Officer
P.O.Box 22149, Kampala,
Plot 86, Bukoto Road,
Bukoto, Kampala, Uganda