Privacy Policy

The Cavalier Institutions is committed to the responsible use of personal information and sensitive information collected from and about its students, faculty, staff, business partners and others who provide such information to the Institution. This commitment is in accordance with both state and federal regulations concerning the use of sensitive information. Such sensitive information includes information that could be used to cause financial harm or reputational harm to any individual. This policy applies to personally identifiable sensitive information and how it is collected.
Objective / Purpose
The purpose of this policy is to protect the privacy of individuals who have sensitive information stored (either in electronic or paper form) on assets owned by The Cavalier Institutions, while at the same time providing the Institution the ability to share this information with authorized entities as required by legitimate academic or business need or by law.
Scope
The Cavalier Institutions Privacy Policy applies to all faculty, staff, students, affiliates, and third-party service providers. This policy is not intended to replace or supersede other existing Institution policies and procedures.

Privacy Policy
Limits on Use of and Access to Sensitive Information
The responsible use of sensitive information requires that the Institution respect individual privacy, protect against unauthorized access to or use of information, and comply fully with all laws and government regulations in the collection, use, storage, display, distribution and disposal of such information. Authorized uses of sensitive information within the Institution are limited to uses which a) are necessary to meet legal and regulatory requirements; b) facilitate access to services, transactions, facilities and information; or c) support efficient academic and administrative processes.
Access to sensitive information is limited to:
The individual whose information is produced or displayed
A Institution official or agent of the Institution with authorized access based upon a legitimate academic or business interest and a need to know
An organization or person authorized by the individual to receive the information
A legally authorized government entity or representative
Other circumstances in which the Institution is legally compelled to provide access to information
Or other individuals or entities, as allowed by law, for purposes judged to be appropriate or necessary for the reasonable conduct of Institution business.
Aadhar Numbers
Aadhar numbers are always considered confidential and are therefore subject to the limits of use and access described above. In addition, the Institution will continue to collect and process Aadhar Numbers limited only to instances in which that number is required by law or contract or instances where there is a legitimate business or academic need authorized by Institution administration. This includes, but is not limited to, all enrolled students.
The Institution , its faculty, staff, and students must abide by all government legal regulations pertaining to UIDAI guidelines.
It is against both Government law and Institutions policy to:
Publicly post or display the Aadhar number in any manner
Require an individual to transmit his or her Aadhar number over the Internet unless the connection is secure or the number is encrypted
Require an individual to use his or her Aadhar number to access an Internet site unless a unique password or PIN is also required
Print the Aadhar number on any card required to access services
Establish a new process that requires the printing of a Aadhar number on any materials that are mailed unless required by other government agency.
Online Collection of Information
Institutions departments must post a link to the Cavalier Institution Privacy Policy on any website which collects data about website visitors.
Indian Government General Data Protection Regulation (GDPR) Privacy Notice
Lawful Basis for Collecting and Processing of Personal Data
The Institutions is an institute of higher education involved in education, research, and community development. In order for the Institution to educate its students both in class and on-line, engage in world-class research, and provide community services, it is essential, necessary, and the Institution has lawful bases to collect, process, use, and maintain data of its students, employees, applicants, research subjects, and others involved in its educational, research, and community programs. The lawful bases include, without limitation, admission, registration, delivery of classroom, on-line, and study abroad education, grades, communications, employment, research, development, program analysis for improvements, and records retention. Examples of data that the Institution may need to collect in connection with the lawful bases are: name, email address, IP address, physical address or other location identifier, photos, as well as some sensitive personal data obtained with prior consent.
For more information regarding the GDPR, please review the Institutions / University Indian General Data Protection Regulation Compliance Policy.
Most of the Institution’s collection and processing of personal data will fall under the following categories:
Processing is necessary for the purposes of the legitimate interests pursued by the Institution or third parties in providing education, employment, research and development, community programs.
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. This lawful basis pertains primarily but not exclusively to research contracts.
Processing is necessary for compliance with a legal obligation to which the Institution is subject. This lawful basis pertains primarily but not exclusively to compliance with law. Examples are providing enrollment data to the HRD and providing employment and payroll data as required by the Indian government.
The data subject has given consent to the processing of his or her personal data for one or more specific purposes.This lawful basis pertains primarily but not exclusively to the protection of research subjects, providing medical and mental health services.
There will be some instances where the collection and processing of personal data will be pursuant to other lawful bases.

Types of Personal Data collected and why
The Institution collects a variety of personal and sensitive data to meet one of its lawful bases, as referenced above. Most often, the data is used for academic admissions, enrollment, educational programs, job hiring, provision of medical services, and participation in research, development and community outreach. Data typically includes name, address, transcripts, work history, information for payroll, research subject information, medical and health information (for student health services, or travel), and donations. If you have specific questions regarding the collection and use of your personal data, please contact the Office of Information Security at info@cavalierinstitutions.com
If a data subject refuses to provide personal data that is required by the Institution in connection with one of the Institution’s lawful bases to collect such personal data, such refusal may make it impossible for the Institution to provide education, employment, research or other requested services.
Where the Institutions gets Personal and Sensitive Personal Data
The Institutions receives personal and sensitive data from multiple sources. Most often, the Institution gets this data directly from the data subject or under the direction of the data subject who has provided it to a third party (for example, application for admission to the Institution through use of the Common App).
Individual Rights of the Data Subject under the GDPR
Individual data subjects whose information is collected under the Institution’s General Data Protection Regulation Compliance Policy will be provided the following information at the time the information is collected from them:
Information about the controller collecting the personal data
Contact details for the data protection officer (if assigned)
The purposes and lawful basis of the data collection/processing, including the legitimate interest for the processing (if applicable)
Who the recipients or categories of recipients of the personal data are Whether the Institution intends to transfer personal data to another country or international organization
The period for which the personal data will be stored
The existence of the right to access, make corrections to, or erase personal data, the right to restrict or object to processing, and the right to data portability
The existence of the right to withdraw consent at any time (if applicable)
The right to lodge a complaint with a competent authority
Justification for why the personal data are required, and possible consequences of the failure to provide the personal data
The existence of automated decision-making, including profiling
If the collected personal data are going to be further processed for a purpose other than that for which it was collected.
Individual data subjects whose information is collected under the Institution’s General Data Protection Regulation Compliance Policy will be provided the following rights (as applicable), provided that the Institution determines that the exercise of the right is permitted and/or required by the GDPR:
The right to receive confirmation from the as to whether the data subject’s personal data is being processed by the Institution, and if so, the right to access such personal data and the right to receive information regarding, among other things, the categories of personal data collected and how such personal data is being used
The right to correct inaccurate personal data concerning the data subject

The right to obtain erasure of personal data concerning the data subject
The right to restrict or object to the processing of the data subject’s personal data
The right to request a copy of personal data concerning the data subject.
Any data subject who wishes to exercise any of the above-mentioned rights may do so by filling such request with the Office of Information Security at Info@cavalierinstitutions.com Cookies
Cookies are files that many websites transfer to users’ web browsers to enable the site to deliver personalized services or to provide persistent authentication. The information contained in a cookie typically includes information collected automatically by the web server and/or information provided voluntarily by the user. Our website uses persistent cookies in conjunction with a third-party technology partner to analyze search engine usage and web traffic patterns. This information is used in the aggregate to monitor and enhance our web pages. It is not used to track the usage patterns of individual users.
Security of Personal Data subject to the GDPR
All personal data and sensitive data collected or processed by the Institution under the scope of the Indian Government General Data Protection Regulation Compliance Policy must comply with the security controls, systems, and process requirements and standards set forth in the Institution’d Data Classification and Protection Standard.
We will not share your information with third parties except:
As necessary to meet one of its lawful purposes, including but not limited to,
its legitimate interest,
Contract compliance,
Pursuant to consent provided by you,
As required by law
As necessary to protect the Institution interests
With service providers acting on our behalf who have agreed to protect the confidentiality of the data.
Enforcement and Implementation
Roles and Responsibilities
Each Institutions department/unit is responsible for implementing, reviewing and monitoring internal policies, practices, etc. to assure compliance with this policy.
The Department of Information Technology is responsible for enforcing this policy.
Consequences and Sanctions
Violation of this policy may incur the same types of disciplinary measures and consequences as violations of other Institution policies, including progressive discipline up to and including termination of employment or, in the cases where students are involved, reporting of a Student Code of Conduct violation.