Use of Cookies and Similar Technologies
Like many websites, our Site uses the Google Analytics tool. Google Analytics uses “cookies,” which are small text files placed on your computer, to collect anonymous, non-personal data, including browser type, domain names, referring website, landing page, web pages viewed, time spent on a web page, and links clicked. This data is used for such purposes as identifying web pages visited most often to improve our Site and providing you a better experience on our Site. Please review Google Analytics’ terms of use and privacy policy to learn more about how Google Analytics may collect and use information. If we ever combine non-personal data with personally-identifiable information, the combined information will be treated as personally-identifiable information. We may also use cookies to enhance the functionality of our Site such as storing your preferences. Cookies also may be served in connection with social media links embedded on our Site.
 
If you do not want to use cookies, you can remove them from your computer’s hard drive or set your browser to block them or to send an alert before a cookie is stored on your computer. If you block cookies, certain features may not function as intended.  Our Site is not currently configured to respond to “do not track” signals or similar mechanisms.
 
Data Subject Rights
Data subjects in the European Economic Area and other jurisdictions may have rights in relation to their Personal Data which include:
 
• Right to rectification. Data subjects may request that we rectify any inaccurate or incomplete Personal Data. 
• Right to withdraw consent. Data subjects may at any time withdraw their consent to the processing of their Personal Data carried out by us on the basis of their previous consent. Such withdrawal will not affect the lawfulness of processing based on such previous consent.
• Right to make a subject access request (SAR). Data subjects may request in writing copies of their Personal Data. However, compliance with such requests is subject to certain limitations and exemptions and the rights of other individuals. Each request should make clear that a SAR is being made. You may also be required to submit a proof of your identity and any payment permitted by law, where applicable. 
• Right to object to processing including automated processing and profiling. We do not make automated decisions about data subjects. However, we may rely on information provided by third parties such as credit reference agencies which may score data subjects on the basis of automated decisions. Profiling may be carried out for business administration purposes, such as monitoring trends in user visits of our website and in order to deliver relevant ads to users’ devices. We will comply with valid objection requests unless we have a compelling overriding legitimate ground for the continuation of our processing or we have another lawful reason to refuse such request. We will comply with each valid opt-out request in relation to marketing communications.
• Right to erasure. Data subjects may request that we erase their Personal Data. We will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping the Personal Data, such as, our business record retention obligations that we have to comply with. 
• Restriction. Data subjects may request that we restrict our processing of their Personal Data in various circumstances. We will comply, unless there is a lawful reason for not doing so, such as, a legal obligation to continue processing your Personal Data in a certain way.
• Right to data portability. In certain circumstances, data subjects may request the controller to provide a copy of their Personal Data in a structured, commonly used and machine-readable format and have it transferred to another provider of the same or similar services. We do not consider that this right applies to our services. However, to the extent it does, we will comply with such transfer request. Please note that a transfer to another provider does not imply erasure of the data subject’s Personal Data which may still be retained for legitimate and lawful purposes.
• Right to lodge a complaint with the supervisory authority. We suggest that data subjects contact us about any questions or complaints in relation to how we process their Personal Data. However, each data subject has the right to contact the relevant supervisory authority directly.
 
Legal Basis for Processing Personal Data
The legal basis for processing your Personal Data typically include: (i) our own or third parties’ legitimate business interests (e.g., in maintain and promoting our alumni services); (ii) performing a contract with you; (iii) your consent where appropriate; (iv) to protect your vital interests; or (v) to comply with our legal obligations. 
Please contact us at info@bocconiusa.com if you have any concerns or questions about this Privacy Statement or you wish to ask us not to process your Personal Data for particular purposes. Where you have specific requests relating to how we manage your data, we will endeavour to resolve these, but please note that there may be circumstances where we cannot comply with specific requests.
If you have any concerns about your Personal Data held by the University or your College, you will need to contact them separately.
 
Third-Party Sites
Our Site may contain links to third-party sites including our Service Providers and social media sites (“Third-Party Sites”). We encourage you to review the privacy statements and terms of use of Third-Party Sites so you will understand how they collect, use, and share personally-identifiable information.
 
Security
We will take reasonable measures (e.g., firewalls and authentication procedures) to protect your Personal Data from unauthorized access, loss, corruption, and alteration. Of course, even protected sites can be subject to hacking, technologic glitches, user misconduct, and administrative errors, and we assume no liability for any of these actions or occurrences or their results.
You provide your Personal Data at your own risk.
 
Location of Servers
Our servers are located in the United States. If you are located outside the United States, be aware that the information you provide us will be transferred to the United States and that the law applicable to the protection of User Information in the United States may be different from the laws of your jurisdiction. By using our Site or providing Personal Data to us, you consent to this transfer and to the collection, storage, processing, and use of your information in the United States as described in this Privacy Statement.
 
Records Retention
We will retain your data indefinitely in accordance with applicable law in support of your lifelong relationship with Cambridge or until you request us to do otherwise.
 
Children under Age Thirteen
Our site is not intended for use by children under age thirteen. We do not knowingly collect Personal Data from children under age thirteen. If we learn that we have inadvertently collected any Personal Data from a child under age thirteen, we will delete it. If you are a parent or guardian and you believe that your child under age thirteen may have provided Personal Data through our Site, please contact us at info@bocconiusa.com.
 
Questions
If you have any questions about our Site or this Privacy Statement, please contact us by email at info@bocconiusa.com or by mail at Friends of Bocconi University, 555 Madison Avenue, 11th floor, c/o Pavia & Harcourt LLP, New York, NY 10022. 

Last Updated: October 5, 2018