Privacy Statement for
Front Gate Online - TCD Alumni Community
1.1 Front Gate Online is operated independently of the University of Dublin (hereafter referred to as "Trinity College Dublin") website at www.tcd.ie and this Privacy Statement only governs activity on the Front Gate Online site. References to "we" or "us" in this Privacy Statement refer to TCD Alumni, Trinity Foundation (hereafter referred to as "TCD Alumni")and references to "you" or "members" refer to those who register for or use any of the features available on Front Gate Online.
1.2 We at TCD Alumni respect your right to privacy and comply with our obligations under the Data Protection Acts, 1988 and 2003. The purpose of this Website Privacy Statement is to:
(a) outline how we deal with any personal data you provide to us while visiting this website or participating in Front Gate Online; and
(b) to notify you of your own responsibilities with regard to your disclosure and use of personal data while communicating within Front Gate Online.
If you do not accept the terms of this Website Privacy Statement you should not use this website or any Front Gate Online services which are available on the site. This Privacy Statement is in addition to our Terms and Conditions and non-compliance by Members with this Privacy Statement shall be treated as a breach of the Terms and Conditions.
1.3 Any external links to other websites are clearly identifiable as such, and we are not responsible for the content or the privacy policies of these other websites.
2. Materials Posted by you in Front Gate Online
2.1 Members control the content and availability of information and material they post in Front Gate Online. It is up to you as a Member to take all appropriate care to ensure that you are happy with the privacy settings and other individual preferences you choose while participating in Front Gate Online.
2.2 You are not permitted to post personal information about third parties in Front Gate Online without their prior consent. This includes any names, personal contact data, photographs or other identifying characteristics.
2.3 As a general rule, any Materials that you transmit to, or post on, Front Gate Online is, and will be treated as, non-confidential and non-proprietary information. Accordingly, you should not use Front Gate Online as a depository of any confidential or sensitive information.
3. Types of Information Collected by TCD Alumni
3.1 We retain two types of information:
(a) "Personal Data"
This is data that identifies you or can be used to identify or contact you and may include your name, student number, degree details, contact details and relevant alumni relations information. Personal data includes user IP addresses in circumstances where they have not been deleted, clipped or anonymised and billing and credit card information. Such information is only collected from you if you post it on the Front Gate Online site or if you voluntarily submit it to us or if you consent to the disclosure of such information to us (e.g. by Trinity College Dublin's Student Graduates Records Services Office).
(b) "Non-Personal Data"
Like most websites, we gather statistical and other analytical information collected on an aggregate basis of all visitors to our website. This Non-Personal Data comprises information that cannot be used to identify or contact you, such as demographic information regarding, for example, user IP addresses where they have been clipped or anonymised, browser types and other anonymous statistical data involving the use of our website.
4. Purposes for which TCD Alumni holds your Information.
4.1 Non-Personal Data:
We use the Non-Personal Data gathered from visitors to our website in an aggregate form to get a better understanding of where our visitors come from and to help us better design and organise our website.
4.2 Personal Data:
We will hold and process any Personal Data you provide to us for the following purposes:
(a) to contact you if required in connection with your Membership Account or to respond to any communications you might send to us;
(b) to administer your Registration Application and Membership Account;
(c) to keep you updated about Trinity College Dublin and TCD Alumni's alumni relations and development activities (unless you have indicated a preference not to receive such information in which case we will remove you from applicable mailing lists);
(d) subject to paragraph 6.3 below, to make available your information to regional branches, affinity groups, clubs, societies and other groups who may wish to contact you about Trinity College Dublin related activities; and
(e) for other purposes that are ancillary to the operation of the Front Gate Online where those purposes are consistent with this Privacy Statement and our Terms and Conditions
6. Disclosure of Information to Third Parties
6.1 The Front Gate Online site is hosted by TCD Alumni's web services partner, Harris Connect (www.harrisconnect.com) which is based in the United States. In accordance with applicable data protection laws, TCD Alumni has taken the requisite contractual and other steps to ensure the secure hosting of the services. Harris Connect pledges to conduct its business according to the Safe Harbor Privacy Principles agreed upon by the U.S. Department of Commerce and the European Union, which regulations are defined more thoroughly on the U.S. Department of Commerce Web site www.export.gov/safeharbor.
6.2 We may provide Non-Personal Data to third parties, where such information is combined with similar information of other users of our website. For example, we might inform third parties regarding the number of unique users who visit our website, the demographic breakdown of our community users of our website, or the activities that visitors to our website engage in while on our website
6.3 We make relevant contact information of alumni available to some of our regional branches, affinity groups, clubs and societies for the purposes of sending College and alumni-related communications to their members. For example:
(a) our overseas alumni branch representatives may be provided with email addresses of their local alumni to enable them to contact alumni about an upcoming event in that region; or
(b) a College graduate may be provided with email and postal addresses for alumni in their class to enable them to organise a reunion.
In each case, TCD Alumni will require the requester of the contact details to sign a data protection form to ensure that the data provided is only used for the stated purpose and that its security is maintained. If you would prefer not to receive further communications from such representatives, you can simply notify the sender who will be obliged to respect your preference.
6.4 Other than as stated in paragraphs 6.1 and 6.3 above, we will not disclose your Personal Data to third parties unless you have put the data into the public domain within Front Gate Online or you have consented to the disclosure. In some cases, for example on alumni donor pages, you will be provided with the opportunity to anonymise Personal Data relating to your donation. We will disclose your Personal Data if we believe in good faith that we are required to disclose it in order to comply with any applicable law, a summons, a search warrant, a court or regulatory order, or other statutory requirement.
7.1 Your Personal Data is held on secure servers hosted by TCD Alumni, Harris Connect or our Internet service providers. The nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the Internet. No data transmission over the Internet can be guaranteed to be 100% secure. However, we will take all reasonable steps (including appropriate technical and organisational measures) to protect your Personal Data.
8. Updating, Verifying and Deleting Personal Data
8.1 The "Update My Profile" section of the Front Gate Online site enables you to control, manage and update the particulars of your own personal data. In addition, you may inform us of any changes in your Personal Data, and in accordance with our obligations under the Data Protection Acts 1988 and 2003 we will update or delete your Personal Data accordingly. To find out what Personal Data we hold on you or to have your Personal Data updated, amended or removed from our database, please review your profile at Front Gate Online or contact us at firstname.lastname@example.org.
8.2 If you feel your personal data has been used in breach of our Terms and Conditions, please email us at email@example.com. While we cannot accept liability for the acts of our Members, material breaches of data protection or privacy laws will be investigated by us.