Effective date: 12.02.2021
Personally Identifiable Information (PII) or personal data means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It includes information that is linked or linkable to an individual, such as medical, educational, financial and employment information. Examples of information that can identify an individual include name, email address, telephone number or social security number, location data, online identifier.
I. What personal data is collected, how, for what purpose and on what legal basis
We provide lead generation for the higher education market. This means our Website contains links (which may take the form of hyperlinks, widgets, clickable logos, images or banners) that will take you to third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third-party sites.
If you want to get in touch with us or become a collaborator you may contact us via contact forms available on our Website or via an email address published on our Website. In such case you will provide us with your personal data such as your name and email address (or any other personal data you decide to share with us). We process this personal data for the purpose of handling your request/question. The legal ground for processing this data is your consent.
We process your name and email address if you subscribe for our newsletter. The legal ground for processing of your personal data is your consent. You have the right to withdraw your consent at any time. In every email we will provide you with the opportunity to unsubscribe from any further marketing communications from us. You may unsubscribe by clicking on the “unsubscribe” link located at the bottom of our marketing emails.
Compliance with legal obligations
In some instances, legal regulations impose obligations on us under which we are obliged to process your personal data (such as accounting and tax laws). Legal grounds for processing this personal data are legal obligations.
We may process your personal data as well in cases where it is in our legitimate interest to process data about you such as to assert or defend against legal claims. Legal grounds for processing personal data is legitimate interest.
When you visit our Website, you are informed through a cookie banner that we collect cookies and you may manage the types of cookies that you allow to be dropped on your device. After choosing whether you consent to our cookies or not, you can change the settings and withdraw your consent through the settings at the bottom of our Website.
We use the following types of cookies: (i) essential cookies, which are essential for transmission of communication and for the provision of services explicitly requested by you; and (ii) analytical/performance cookies and other technologies which help us to analyse how you navigate our Websites and what content is relevant to our users. Essential cookies cannot be disabled as they are essential for the functioning of our Website. If you do not consent to the use of analytical, the functionality of our Website may be limited. When analytical cookies are collected we process personal data such as IP address, gender, time zone setting, operating system and platform, information about visits including the URL, the search terms, information about what you viewed or searched on our Website, page response times, download errors, length of visits to certain pages, page interaction information, (such as scrolling, clicks, and mouse-overs) and the methods used to browse away from the page, activities of users, browsing web pages.
When we collect essential cookies the legal ground for processing is legitimate interest. When we collect analytical cookies, we do so once you have given us your consent hence the legal ground for such processing is consent. You can withdraw your consent to analytical cookies at any time through the settings at the bottom of our Website.
We use Google Analytics to help us understand how you interact with our Website so that we can improve it and make it easier to navigate. If you for wish your website visits to not be subject to Google Analytics tracking you can use the their opt-out browser add-on that you can download here https://tools.google.com/dlpage/gaoptout. If you wish to opt out of all analytical cookies you can withdraw your consent through the settings at the bottom of our Website.
We use the so-called social plugins from the following social networks:
- (i) facebook.com,
- (ii) twitter.com,
- (iii) linkedin.com (“plugins”)
These are indicated by their logos on our Website. When you visit our Website, your browser establishes a direct connection with the servers on which these plugins run. The content of the plugins is transferred directly by Facebook/Twitter/Linkedin to your browser, which then integrates it into our Website. Integration of the plugins causes Facebook/Twitter/Linkedin/ to receive the information that you have accessed on the corresponding page of our Website. If you are logged with Facebook/Twitter/Linkedin it will be able to assign your visit to your account on these social networks. Please note that an exchange of this information already takes place when you visit our Website regardless of whether you interact with the plugin or not. If you do not want Facebook/Twitter/Linkedin to gather data about you via our Website, you must log out of them before visiting or Website. For more information regarding how these social networks process your data in their privacy policies:
- Facebook: https://www.facebook.com/legal/FB_Work_Privacy
- Twitter: https://twitter.com/en/privacy
- Linkedin: https://www.linkedin.com/legal/privacy-policy
If you wish cookies not to be collected, you may restrict, block or delete the cookies, including blocking all third-party cookies at any time by modifying your browser configuration. Although each browser is parameterized differently, cookie configuration is normally located on the “Preferences” or “Tools” menu. If you turn off cookies, the functionality of our Website may be limited (in the case of essential cookies you may not be able to access our Website). If you wish to prevent new cookies from being installed or if you wish to delete existing cookies you can find the instructions on the links below. The exact procedure depends on which browser you are using.
- Internet Explorer http://windows.microsoft.com/en-GB/internet-explorer/delete-manage-cookies
- Firefox –https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-websitepreferences https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
- Google chrome – https://support.google.com/chrome/answer/95647?hl=en
- Safari – http://help.apple.com/safari/mac/8.0/#/sfri11471
For mobile devices you can limit tracking via the privacy setting on your device (disabling the advertising identifier), for instructions please see: https://www.networkadvertising.org/mobile-choice/
III. Who has access to your data
For independent third parties that may have access to your data please refer to section service above.
Your personal data may be shared with third parties that that process personal data on behalf of our company and in line with our instructions, hence these third parties are our service providers or processors.
Currently, we use the following categories of processors:
- Marketing tools and Analytical tools
- IT tools/providers, communication tools, business administration tools
- Legal services, tax, accounting, and audit services
Subject to the previous paragraphs, your personal data shall not be shared or provided to any other third party without your consent except for the following cases: i) we are obliged to provide your personal data based on law or upon order of a public authority, ii) it is allowed by applicable legal regulations.
Transfers to third countries
The organization will transfer your data to countries outside the EU/European Economic Area only if such a transfer is GDPR compliant. That means, for instance, the provider is seated in a country for which the European Commission issued a decision that it provides an adequate level of personal data protection, standard contractual clauses and/or other transfer mechanisms are in place that ensure adequate safeguards with respect to the protection of privacy and fundamental rights and freedoms of individuals and, if necessary, additional measures are applied to ensure that the data subject is granted a level of protection essentially equivalent to that guaranteed by the GDPR.
IV. For how long we keep your data
Generally personal data shall be kept for as long as necessary for the purpose for which it was processed. For how long the organization will hold your personal data will as well depend on the legal basis on which your data is processed. Shall the processing be based on legitimate interest your data will be processed for as long as the given legitimate interest of our organization is in place. For data kept based on legal obligations the data retention period is prescribed by applicable legal regulations. For data processed based on performance of a contract the data is processed for the duration of the contractual relationship and for an applicable limitation period. Shall the processing be based on your consent your personal data shall be erased after you withdraw your consent. Please bear in mind that the same data may as well be processed based on other legal basis in which case your withdrawal of consent might not mean a full erasure of your data.
V. Data Security
We are committed to processing and storing your data securely. Therefore, we have implemented technical and organizational measures in an effort to safeguard the personal information in our custody and control (which do not, however, deprive you of your duty to take proper steps to secure your data). The aim is to eliminate unauthorized or unlawful processing of your personal data or the accidental, unauthorized or unlawful accessing, use, transferring, processing, copying, transmitting, alteration, loss or damage of your data. We protect your data, including but not limited to, in the following ways: using passwords and other access management and restricting access to your data (i.e. access to your personal data is granted only to those of our employees or contractors for whom the access is necessary), using security IT tools such as firewalls and antivirus/anti-malware software, implementing appropriate physical security of premises where personal data is stored, implementing controls on premise entry.
VI. Your rights
Where EU General Data Protection Regulation 2016/679 (“GDPR”) applies to the processing of your personal data you are entitled under the GDPR to the following rights:
Rights of access
You are entitled to be informed inter alia about what personal data we process about you, for what purposes, who are the recipients of your personal data.
Right to rectification
You have a right for any of your incomplete, inaccurate, or out-of-date personal data to be rectified.
Right to erasure (‘right to be forgotten’)
You are entitled to erasure of personal data that we have collected and processed about you.
Right to restriction of processing
In given cases such as when we process inaccurate personal data about you, or you deem the processing as no longer necessary you may ask for a restriction of the processing.
Right to data portability
You have a right to receive personal data you provide us with in a structured, commonly used, and machine-readable format and have it transmitted to another controller where technically feasible.
Right to object
You are entitled to object, on grounds relating to your particular situation, at any time to processing of personal data that concerns you and is carried out in public interest or for the purposes of legitimate interests pursued by our organization, including profiling.
The exercise of your rights may be limited shall we be obliged to keep any of your personal data for the purpose of compliance with legal obligations, for the establishment, exercise or defense of legal claims or any other compelling reasons as provided by the relevant data protection law.
Should you wish to exercise any of your rights you may contact us at: [email protected]
If you feel that your data has been processed unlawfully, contact us and we will undertake to resolve the problem. Under GDPR you have the right to lodge a complaint with our supervisory authority, find the link here: http://www.dataprotection.gov.cy/
VII. California Consumer Privacy Act of 2018 (“CCPA”) Notice
Consumers residing in California have some additional rights in respect to their personal information under the California Consumer Privacy Act or (“CCPA”). If you are a California resident, this section applies to you and supplements the above policy
Sale of Personal information
Under CCPA, “selling” information occurs when personal information is shared in exchange for valuable consideration. This includes sharing data which identifies your device such as cookies. We use third party cookies and other technologies to better understand our users’ needs and to optimize our services and user experience.
To opt out of these “sales” please refer to the “Do Not Sell My
Personal Information” in the bottom of our Website.
Your Californian Consumer Rights
Where the California Consumer Privacy Act of 2018 Assembly Bill No. 375 (“CCPA”) applies to the processing of your data you are entitled to the following rights:
Right of access
Right to request deletion
You are entitled to the erasure of personal data that we have collected and processed about you.
Right to opt out of sales of personal information
You have the right to opt out of sales of personal information. To opt out of these “sales” please click the “Do Not Sell My Personal Information” link here.
Right to receive equal services
You have a right to not be discriminated against even if you exercise any of your CCPA rights.
VIII. Final Provisions