2.WHO WE ARE
Enroly provides impartial guidance, application assistance and visa help to prospective international students. Through our peer-to-peer technology we match international students with admissions help to suit their personal goals. Inherent in this process is the request, collection and processing of certain personal data necessary to provide this service to you.
Here are the details the General Data Protection Regulation (GDPR) says we have to give you as a 'data controller':
- Our site address is www.enroly.com
- Our company name is Enroly
- Our registered address is EdSpace Office, Falkirk Street, London, N1 6HQ
- Our Data Protection Officer is Jeffrey Williams and they can be contacted at firstname.lastname@example.org
3.WHAT WE MAY COLLECT
In providing you with our impartial service, we may collect and process the following data about you:
Information you put into forms or surveys on our site at any time
- A record of any correspondence between us
- Details of transactions you carry out through our site
- Details of your visits to our site and the resources you use
- Information about your computer (e.g. your IP address, browser, operating system, etc.) for system administration and to report aggregate information to our advertisers
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) you have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are subject;
d) processing is necessary to protect the vital interests of you or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our credit card payment processing, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
As we operate a peer to peer referral system, parts of our service collect non-sensitive personal data indirectly, but with consent and processing limits as required by the GDPR. Specifically when receiving personal data via a 3rd party referrer we:
- Seek active confirmation from the person/s providing your personal data that they have your consent to provide this data to us; and
- Contact you within a reasonable period of time, defined by the GDPR as less than one month, to seek your active consent to use and share your personal data in the provision of our services.
5.HOW WE USE WHAT WE COLLECT
We use information about you to:
- Present site content effectively to you;
- Provide information, products and services that you request, or (with your consent) which we think may interest you;
- Carry out our contracts with you;
- Allow you to use our interactive services if you want to; and
- If you explicitly opt in to additional contact for services related to your enrolment: to tell you about other goods and services related to our services that might interest you. We may also let other people do this, and we (or they) may contact you.
If you are already our customer, we will only contact you electronically about things similar to what was previously provided to you.
If you are a new customer, you will only be contacted if you agree to it.
Please note: We don't identify individuals to our advertisers, but we may give them aggregate information to help them reach their target audience, and we may use information we have collected to display advertisements to that audience.
In addition, if you don’t want us to use your personal data for any of the other reasons set out in this section in 5, you can let us know at any time by contacting us at email@example.com, and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible service to you.
In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the services we can provide you if you don’t provide your personal data in these cases.
6.WHERE WE STORE YOUR DATA
We may transfer your collected data to storage outside the European Economic Area (EEA). It may be processed outside the EEA to fulfil your order and deal with payment.
By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.
Payment will be encrypted. If we give you a password, you must keep it confidential. Please don't share it. Although we try to provide protection, we cannot guarantee complete security for your data, and you take the risk that any sending of that data turns out to be not secure despite our efforts.
We only keep your personal data for as long as we need to in order to use it as described above in section 5, and/or for as long as we have your permission to keep it. Broadly there are two durations for keeping personal data that we follow:
- Personal data provided by a 3rd Party: We will contact the data subject within one month of their data being entered into our system. At this point we will seek their active consent to retain the data and if not received, all data will be removed within the following calendar month.
- Personal data provided by you with consent: We will maintain this data for the duration of your studies plus 2 years, unless we are required by law to retain particular personal data for longer.
In any event, we will conduct an annual review to ascertain whether we need to keep your personal data. Your personal data will be deleted if we no longer need it.
7.DISCLOSING YOUR INFORMATION
We are allowed to disclose your information in the following cases:
- If we want to sell our business, or our company, we can disclose it to the potential buyer.
- We can disclose it to other businesses in our group.
- We can disclose it if we have a legal obligation to do so, or in order to protect other people's property, safety or rights.
- We can exchange information with others to protect against fraud or credit risks.
We may contract with third parties to support our supply of services to you. Example services include administrative support, payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. An example of activities we conduct that require third party access to your information can be found below. This list is not exhaustive:
- Educational Agent support
- University relationship management
- Customer Relationship Management: i.e Streak
- Interactive website chat service: i.e. Tawk.to
- Google Analytics
- Mouseflow heat mapping
Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under GDPR and the law.
You can ask us not to use your data for marketing. You can do this by not ticking the relevant boxes on our forms upon registration, unsubscribing to the email service or by contacting us at any time at firstname.lastname@example.org
Under the GDPR, you have the right to:
- request access to, deletion of or correction of, your personal data held by us at no cost to you;
- request that your personal data be transferred to another person (data portability);
- be informed of what data processing is taking place;
- restrict processing;
- object or withdraw consent to the processing of your personal data; and
- complain to a supervisory authority.
You also have rights with respect to automated decision-making and profiling as set out in section 11 below.
9.LINKS TO OTHER SITES
Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our site. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
11. AUTOMATED DECISION-MAKING AND PROFILING
11.1 In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.
11.2 The right described in section 11.1 does not apply in the following circumstances:
a) the decision is necessary for the entry into, or performance of, a contract between the you and us;
b) the decision is authorised by law; or
c) you have given you explicit consent.
11.3 Where we use your personal data for profiling purposes, the following shall apply:
a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
b) Appropriate mathematical or statistical procedures will be used;
c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
12. DISPUTE RESOLUTION
12.2 If any such dispute cannot be settled amicably through ordinary negotiations between the parties, or either or both is or are unwilling to engage in this process, either party may propose to the other in writing that structured negotiations be entered into with the assistance of a fully accredited mediator before resorting to litigation.
12.3 If the parties are unable to agree upon a mediator, or if the mediator agreed upon is unable or unwilling to act and an alternative mediator cannot be agreed, any party may within 14 days of the date of knowledge of either event apply to LawBite to appoint a mediator under the LawBite Mediation Procedure.
12.4 Within 14 days of the appointment of the mediator (either by mutual agreement of the parties or by LawBite in accordance with their mediation procedure), the parties will meet with the mediator to agree the procedure to be adopted for the mediation, unless otherwise agreed between the parties and the mediator.
12.5 All negotiations connected with the relevant dispute(s) will be conducted in confidence and without prejudice to the rights of the parties in any further proceedings.
12.6 If the parties agree on a resolution of the dispute at mediation, the agreement shall be reduced to writing and, once signed by the duly authorised representatives of both parties, shall be final and binding on them.
12.7 If the parties fail to resolve the dispute(s) within 60 days (or such longer term as may be agreed between the parties) of the mediator being appointed, or if either party withdraws from the mediation procedure, then either party may exercise any right to seek a remedy through arbitration by an arbitrator to be appointed by LawBite under the Rules of the LawBite Arbitration Scheme.