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Privacy Policy

DATE OF ISSUE: 21/09/2020

 

Welcome to the SchoolApply’s privacy policy.

 

SchoolApply respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

 

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

 

  1. INTRODUCTION
  2. THE INFORMATION WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED?
  4. HOW WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS
  10. GLOSSARY
  11. HOW TO CONTACT US

 

  1. INTRODUCTION

 

This privacy policy aims to give you information on how SchoolApply collects and processes your personal data through your use of this website, including any data you may provide through this website when you create an account, update your profile, apply to Universities, or receive and interact through our various marketing emails.

 

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you to be fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

 

In this privacy policy, the terms “we”, “our”, and “us” refer to SchoolApply AG of Bahnhofstrasse 7, 6300, Zug, Switzerland.

 

We are a controller of your information which means that we are responsible for looking after it. We will use your personal data fairly, lawfully and in a transparent manner, and in accordance with data protection laws.

 

 

 

 

We have appointed a data protection officer (DPO) who is responsible for handling questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the contact details set out below.

 

Full name of legal entity: SchoolApply AG

Email address: raghav.thakur@schoolapply.com

Postal address: Bahnhofstrasse 7, 6300, Zug, Switzerland

 

Changes to this Privacy Policy and Your Duty to Inform Us of Changes  

 

We keep our privacy policy under regular review and reserve the right to update this policy at any time as it applies to your use of our services.

 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

THIRD-PARTY LINKS  

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

  1. THE INFORMATION WE COLLECT ABOUT YOU

 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

 

  • Identity Information includes first name, last name, username or similar identifier, title, date of birth, gender, citizenship and country of residence.
  • Contact Information includes residence address, email address, telephone numbers, Facebook and Skype ID, next of kin and emergency contact information.
  • Education Information includes your educational history, qualifications, certifications, English language test and other relevant academic test scores, further study plans.
  • Compliance Information includes details regarding any visas you may need or any other previous visa applications.
  • Financial Information includes means of financing and budget available for studies abroad, bank account and payment card details.
  • Transaction Information includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Information includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Information includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Information includes information about how you use our website, products and services.
  • Marketing and Communications Information includes your preferences in receiving marketing from us and our third parties and your communication preferences and your source of enquiry.
  • Special Categories of Personal Information includes details about your ethnic origin and your health or disabilities. In certain circumstances, we may also receive information from you about any criminal convictions you may have.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Information to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

 

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

 

We use different methods to collect data from and about you including through:

 

  • Information you provide. You may give us information including your Identity, Contact, Education and Financial Information by filling in application forms online or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • shortlist and apply for a place on a course or make an enquiry with us;
  • create an account on our website;
  • accept a place to study on a course;
  • interact with any marketing or automated emails/messages sent to you;
  • enter a competition or take part in a survey; or
  • give us some feedback or get in contact with us.
  • From websites and apps that use our services. As you interact with our website, we will automatically collect Technical Information about your equipment, browsing actions and patterns. We collect this personal information by using cookies and other similar technologies. To find out more about the way we use cookies and other technologies, please read our Cookies Policy for further details.
  • Third parties or publicly available sources. We may receive personal information about you from various third parties including Technical Information as set out below:

Technical Information from the following:

  • analytics providers - Google, Heap and Lucky Orange
  • search information providers - Swift Type, Elastic Cloud;

Financial and Transaction Information from payment provider EPG [within EU];

Contact and Education Information from universities we work with and to whom you are applying to study with.

 

  1. HOW WE USE YOUR PERSONAL DATA

 

We use the information we have to provide, improve, and develop our services for you, and we need to have a valid reason to use your personal data - this is called the “lawful basis for processing”. Sometimes we might ask your permission for us to do something with your personal data: for example, when you give us your consent to contact you by email about a service we are providing. At other times, we don’t need your explicit permission because we have another lawful basis for processing your personal data, and you might reasonably expect us to use your personal data.

 

Most commonly, we will use your personal data in the following circumstances:

  • where we need to perform the Contract we are about to enter into or have entered into with you;
  • where it is necessary for our Legitimate Interests (or those of a third party) and your interests and fundamental rights do not override those interests;
  • where we need to comply with a Legal Obligation.

Please look at the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

 

Purposes for which We Will Use Your Personal Data  

 

We use the information we have to deliver and improve the services we offer to you. Examples of the services offered, and how we use your personal data, include the following:

  1. to register you as a new customer when you submit an enquiry to us in order that we can respond to you where such processing is necessary for the purposes of our legitimate interests;
  2. to process your application to study on a particular course, including arranging interviews with you, completing any statutory checks, and processing your acceptance forms as part of our contract with you;
  3. to manage our relationship with you, including notifying you about changes to our terms of service, and asking you to leave a review or take a survey where such processing is necessary for our legitimate interests to keep our records updated and to show how students use our services;
  4. to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) as is necessary for our legitimate interests in running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of any business reorganisation or group restructuring exercise necessary to comply with a legal obligation;
  5. to deliver relevant website content to you and measure or understand the effectiveness of the services we deliver to you that it necessary for our legitimate interests to analyse and show customers use our services, to develop them, to grow our business and to inform our marketing strategy;
  6. to use data analytics to improve our website, services, marketing, customer relationships and experiences for the purposes of our legitimate interests, defining types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy;
  7. to make suggestions and recommendations to you about courses, programmes or services that may be of interest to you where such processing is necessary for our legitimate interests to develop our products, services and grow our business.

 

Marketing  

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

 

Promotional Offers from Us  

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

 

You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.

 

Third-Party Marketing  

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting Out  

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out (unsubscribe) links on any marketing message sent to you or by contacting us at any time.

 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of you creating a student account or other ongoing transactions you may with us relating to an application to study with one of the Universities we work with.

 

Cookies  

For more information about the cookies we use, please read our Cookies Policy.

 

Change of Purpose  

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

  1. DISCLOSURES OF YOUR PERSONAL DATA

 

We may share your personal data with  selected external third parties including:

  • The schools or universities to which you apply to study or may have an interest in to ensure sure you can make an informed decision about your choice of education;
  • Suppliers or service providers who perform any services for us: for example, payment processing companies who process your payments on our behalf; technology companies whose systems we use; or companies who provide services to carry out marketing campaigns on our behalf;
  • Competent authorities for law enforcement purposes, and governmental authorities as required by law;
  • Third parties to whom we may choose to sell, transfer or merge part of our business to or with. Alternatively, we may seek to acquire other businesses or merge with them.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

  1. INTERNATIONAL TRANSFERS

 

Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

 

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring we use specific contractual clauses approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us if you want further information about when and how we transfer your personal data out of the EEA.

 

  1. DATA SECURITY

 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

  1. DATA RETENTION

 

How Long Will You Use My Personal Data For?  

 

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

 

We consider a number of factors in deciding how long to keep your personal data: the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and whether there any applicable legal requirements which mean we have to keep certain types of document for a certain length of time.

 

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. We may also retain a record of your stated objection to the processing of your personal data, including in respect of an objection to receiving communications, for the sole purpose of ensuring that we can continue to respect your wishes to not contact you further, during the term of your objection.

 

 

You have a number of rights under data protection laws in relation to your personal data, including the right to: 

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: a) If you want us to establish the data’s accuracy; b) Where our use of the data is unlawful but you do not want us to erase it; c) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or d) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you;
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact our data protection officer by email: raghav.thakur@schoolapply.com

 

No Fee Usually Required  

 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

 

What We May Need from You  

 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

Time Limit to Respond  

 

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

  1. GLOSSARY

 

Lawful Basis: 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

 

Personal Data:

Any information which we hold about you from which you can be identified. It may include contact details, identification numbers, other personal information, photographs, expressions of opinion about you or indications as to our intentions about you.

 

Processing:

Doing anything with the personal data, such as collecting, recording, organising, structuring, storing, adapting or altering, retrieving, accessing, consulting, disclosing, disseminating, aligning or combining, restricting, erasing or destroying or using the data in any way.

 

  1. HOW TO CONTACT US

 

If you have any questions or comments about this privacy policy, please contact us as indicated below:

 

Email: raghav.thakur@schoolapply.com

 

By post: Bahnhofstrasse 7, 6300, Zug, Switzerland

 

Thank you for taking the time to read our privacy policy.

 

We keep our privacy policy under regular review to make sure it is up to date and accurate.

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