Data Protection and Privacy Notice
This policy applies to data that is held by Uni Direct Limited a company registered in England and Wales with number 10005606) (we/us/our) and to the website hosted at www.university-direct.com, (Website) which is operated by us. We are the data controller and this policy sets out the basis on which any personal information that will be processed by us that is: (i) provided to us by a student (this may be provided to us by one of our partners through which you may have first come into contact with us) so that we can carry out our obligations pursuant to an agreement with a student or university and provide application services (Services); or (ii) that we collect from you when you visit our Website.
Personal information that we will require you to provide to us may include your name, contact details, and other information about you or any third party (Personal Information) to enable us to provide the Services. It may be the case that some of this Personal Information is provided to us by a third party introducer (Introducer) and they should have obtained your consent to or have another legitimate basis for passing your contact details to us. If this is not the case then you should notify us immediately and we will delete your Personal Information. We may gather information from other public sources of data in order to assist us to provide the Services.
Personal Information we process as described in this notice may also include Personal Information about third parties if you provide them to us (e.g. a contact address that is not your primary residence).
If an application involves children then such children must be represented by their parents or guardians.
When someone visits our Website we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not collect personally identifiable information through our Website.
Reasons for and basis of processing
If we have a contract with you then we are processing Personal Information about you including Disclosure of your Personal Information as below for the purpose of providing the Services relying on the performance of our contract with you as the basis for processing.
If we have a contract with the university then we are relying on your consent as the basis of processing Personal Information about you including Disclosure of your Personal Information as below which you may withdraw at any time.
We process analytical data from Google in relation to our website on the basis of our legitimate interests seeking to develop our own business and we do not carry out any automatic profiling.
Disclosure of your information
We will need to disclose Personal Information about you to universities which we will have discussed with you in advance.
We may disclose your Personal Information to a third party consultant or tutor to whom we may be sub-contracting the provision of some of the Services where we have a contract with you. They will be working within our Systems and be based within the UK or the EEA.
We may disclose your Personal Information to other third parties to enable us to provide the Services. (such as our accountants, providers of software, web designers, consultants)
We will not otherwise disclose your Personal Information to a third party without your express consent.
Systems used to process data
Our data is held in software on a “Google Drive” cloud based platform on third party servers operated by Google. We will take all appropriate technical and organisation measures to ensure that your Personal Information is treated securely and in accordance with this privacy notice.
We will only collect from you and process special categories (e.g. racial origin, religious beliefs) of Personal Information if it is necessary for us to provide the Services. We will obtain your express consent prior to processing of such special category data including to disclosure to universities or to consultants or tutors. You may withdraw your consent at any time.
If you have consented for us to do so, we will email you to contact you about other services that we provide. You may withdraw your consent at any time.
We will not provide your Personal Information to third parties for the purposes of marketing or otherwise without your express consent.
Transfers to and from outside of the EEA
The Personal Information that we hold is backed up within the secure systems operated by Google which might mean that your data is stored on a server in the USA. Google who are part of the Privacy Shield which requires them to provide similar protection to personal data shared between EEA and USA.
We do have introducers based outside of the EEA (e.g. India and Russia). If you give Personal Information to such an introducer (as opposed to direct to us) then you should be aware that such countries do not have the same data protection laws as the UK and EEA. We have put in place European Commission approved clauses in the agreements with these introducers that are designed to help safeguard your privacy rights and give you remedies. A copy of these clauses is available upon request.
We will not otherwise transfer your Personal Information outside of the EEA.
We will only store your Personal Information for as long as is reasonable necessary for us to fulfil our obligations under an agreement with you or a university or as otherwise required for audit purposes. We will delete all special category data as soon as it is no longer necessary for the performance of the specifically relevant aspect of the Services.
Third Party Sites
Our Website may contain links to and from third party websites. If you follow a link to any of these websites then please note that these websites will have their own privacy policies and we do not accept any responsibility or liability for these websites.
When you use our website we may gather information about you through cookies. ‘Cookies’ are text files placed on your computer to collect internet log information and anonymous user behaviour information which are used to track website usage and monitor website activity. You may set your browser to not accept cookies. To find out more about the cookies we use and how to delete them please contact us.
You have a number of rights free of charge. You have the right of access, correction, erasure, objection and data portability and the right to withdraw consent as applicable. You also have the right to make a complaint to the data protection authority and for further information see www.ico.org.uk/concerns.
The data controller is Uni Direct Limited, a company registered in England and Wales with number 10005606). You can contact us by telephoning our customer service team Tel: 0207 060 6861 or by email: firstname.lastname@example.org or writing to us at: 24 Holborn Viaduct City of London, EC1A 2BN if you would like to correct or request (in accordance with applicable law) information that we hold relating to you or if you have any questions in relation to the above.