Privacy Policy
Background
This Privacy Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum, to make sure you understand the information provided. However, to achieve this objective we would like to explain to you the following concepts.
a) What is Personal Data?
Personal Data is any includes information relating to an individual who can be identified or who is identifiable, directly from the information in question; or who can be indirectly identified from that information in combination with other information.
b) What is Processing?
“Processing” means and covers virtually any handling of data.
What law applies?
We will only use your Personal Data in accordance with the applicable data protection laws, in particular the UK’s Data Protection Act (“DPA”) and the EU’s General Data Protection Regulation (“GDPR”).
Who is responsible?
The person responsible is Study Options Limited of 83 Alma Road, Clifton, Bristol, BS8 2DP (“Study Options”, “we”, “us”, or “our”). Please direct any questions you may have to our Data Protection Manager, Stefan Watts, by email using stefan@studyoptions.com, or write to us at the above address.
Data collection
All Personal Data that we obtain from you will only be processed for the purposes described in more detail below. In particular, we collect Personal Data only if:
● you have given your consent;
● the data is necessary for the fulfilment of a contract / pre-contractual measures;
● the data is necessary for the fulfilment of a legal obligation; or
● the data is necessary to protect the legitimate interests of our company and business.
Data retention
We process and store your Personal Data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period exists (in particular commercial and tax law in accordance with applicable Commercial Laws and Fiscal Codes and others for up to 6 years). Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.
Data storage
In general, your data is saved and stored using the services of OneDrive cloud storage service provided by Microsoft and our Salesforce CRM (see below). We will retain your Personal Data as necessary in connection with the purposes described in this Privacy Policy, and in accordance with the UK`s retention periods if applicable.
Data we collect automatically
a) Provision and use of the website
When you visit our website, we collect the Personal Data that your browser automatically transmits to our server. This is technically necessary for us to display our website and to ensure its stability and security. In this sense, we collect the following data: i) IP address of the requesting computer, ii) Date and time of access, iii) name and URL of the file accessed, iv) website from which the access was made (referrer URL), v) browser used and, if applicable, the operating system of your device as well as the name of your access provider. The legal basis is our legitimate interest.
b) Hosting
The hosting services used by us for the purpose of operating our website is UK-2. In doing so UK-2 processes inventory data, contact data, content data, usage data, meta data and communication data of customers, interested parties and visitors of our website and services, on the basis of our legitimate interests.
c) Content Management System
We use the Content Management System (CMS) of WordPress by Automattic Inc to publish and maintain the created and edited content and texts on our website. This means that all content and texts submitted to our website are transferred to WordPress. The legal basis for this processing is our legitimate interest.
d) Fonts
We use Google Fonts by Google LLC and Font Awesome of Fonticons Inc on our website to display external fonts. To enable the display of certain fonts on our website, a connection to a Google/Font Awesome server is established when our website is accessed. The connection to Google/Font Awesome established when you call up our website enables Google/Font Awesome to determine which website sent your request and to which IP address the display of the font is to be transmitted. This represents a legitimate interest.
e) reCAPTCHA
We also use Google’s reCAPTCHA from Google to check whether data input is made by a human being or by an automated program. For this purpose, reCAPTCHA analyses the behaviour of the website visitor on the basis of various characteristics. This analysis begins automatically as soon as the website visitor enters the website. The legal basis for using reCAPTCHA is our legitimate interest.
f) Economic analyses and market research
For business reasons, we analyse the data we have on web and server traffic patterns, website interactions, browsing behaviour etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarised and or anonymized values. For this purpose we use Google Analytics. The legal basis is our legitimate interest and your consent. For further information, on our use of Google Analytics, please refer to our Cookie Policy.
g) YouTube Videos
We have integrated videos from YouTube. The integration requires that YouTube can perceive the IP address of the user. The IP address is required in order to send the video content to the user’s browser. If you click on a YouTube video on our website, your internet browser will be prompted to download a corresponding representation of the video and also places certain cookies. In this way, YouTube knows which specific sub-pages you have visited. The legal basis for the data processing is our legitimate interest and your consent.
h) Cookies
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. As set out in the UK`s Privacy and Electronic Communications Regulations (“PECR”), the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies. For further information on the cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.
i) Cookie consent
Our website uses the cookie consent tool CookieLawInfo of CookieYes, to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to our website. The basis for processing is our legitimate interest and your consent.
j) Links to other websites
Please note that if you use a link from our website to a third-party website, that third-party may also set new cookies that are not covered by this or our cookie policy. In such cases, we recommend that you read the cookie policy on the third-party website itself.
Data we collect directly
a) Contacting Us
We offer you the opportunity to contact us using various methods. We collect the data you submit such as your name, email address, telephone number and your message in order to process your enquiry and respond to you. The legal basis is both your consent and contract.
b) Using our services
We process the Personal Data involved in your use of our application support service in order to be able to provide our contractual services. This includes in particular our support, correspondence with you, invoicing, fulfilment of our contractual, accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations and our legal obligations. For Further information, please also refer to our Services Privacy Policy,
c) Administration
We process data in the context of administrative tasks as well as organisation of our business, and compliance with legal obligations, such as storing using the OneDrive cloud storage service provided by Microsoft and archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.
d) Customer Relationship Management System
For support, we may store the data related to our customers (for example, your name, address, e-mail address or telephone number) in our customer relationship management system (CRM) using the services of Salesforce. This data processing is based on our legitimate interest in providing our customer service.
e) Student Stories
Within the Student Stories section, we may display certain personal information, share certain details, knowledge and insights. When you approve and submit your Student Story to us your consent is obtained, and you have choices about the information in your Student Story. The storage of your Student Story is based on your consent. You can revoke your consent at any time. For this purpose, an informal communication by e-mail to our DPM is sufficient. The legality of the data processing operations already carried out remains unaffected by the revocation.
f) Downloading Applications and Resources
When you go ahead and download Applications and Resources, your IP address is requested and logged for documentation purposes by WordPress. This is a mere technical process and required to make our Publications and Resources available for download to your device or depending on your browser available for viewing. The basis for this storage is the provision of a contract and our legitimate interest.
g) Links to further information
If you are interested in our references to further information about your studies and want to look at a certain article you will be redirected to the relevant source, and as such your IP address and other data may be transferred to the relevant source. We have no influence or control over the data collected and processed by the relevant operator when you are being redirected and you can learn more about data processing at the relevant operator’s privacy policy. We provide links to further information, on the basis of our legitimate interests in conjunction with the initiation of a (pre)contractual relationship with you.
h) Promotional use of your data
We use your data within the legally permissible scope for marketing purposes, e.g., to draw your attention to special promotions and discount offers. In addition, we may draw your attention to comparable offers by email, e.g., we may inform you about exclusive sales, promotions, or special events. The legal basis for processing is our legitimate interest.
Social media
a) General
We are present on social media on the basis of our legitimate interest (currently, Facebook, Instagram, and X (formerly Twitter)). If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Data collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest.
b) When you visit our profiles and interact with us and others
When you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture). Which Personal Data from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. The legal basis is our legitimate interest and your consent.
Data sharing
In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients.
a) Internal
If necessary, we transfer your Personal Data within Study Options. Of course, we comply with the DPA and the GDPR and ensure that your data is processed properly. Access to your Personal Data is only granted to authorised employees who need access to the data due to their job, e.g., to provide our services or to contact you in case of queries. For further information in relation to the adequate protection for your Personal Data when it is transferred within Study Options, please refer to our Data Processing Addendum.
b) External bodies
Personal Data is transferred to our service providers in the following instances:
● in the context of fulfilling our contract with you,
● to use marketing services and to advertise our services online,
● to communicate with you,
● to provide our website, and
● to state authorities and institutions as far as this is required or necessary.
c) International transfers
We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer.
Data security
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through our website.
Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
Your rights and privileges
a) Privacy rights
Under the DPA and GDPR, you can exercise the following rights:
● The right to access;
● The right to rectification;
● The right to erasure;
● The right to restrict processing;
● The right to object to processing;
● The right to data portability;
b) Updating your information and withdrawing your consent
If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to legitimate interest processing, please do so by contacting us.
c) Access Request
In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
d) Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in the UK is: The Information Commissioner’s Office, (www.ico.org.uk). However, we would appreciate the opportunity to address your concerns before you contact any supervisory authority.
e) What we do not do
● We do not request Personal Data from minors and children;
● We do not process special category data without obtaining prior specific consent;
● We do not use Automated decision-making including profiling; and
● We do not sell your Personal Data.
Changes
We may update this Privacy Policy from time to time. If we make changes to this Privacy Policy, we will revise the effective date.
Effective date
Sunday, 12th of May, 2024
Questions
If you feel that the above is not sufficient or if you have any queries as regards the collection, processing or use of your information we are looking forward to hearing from you. We will make every effort to reply as soon as possible and take into consideration any suggestions from your end.
