Date of issue: October 2024

INTO University Partnerships Group

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Privacy Notice

INTO University Partnerships Limited, its subsidiaries and affiliates (together “INTO” and individually an “INTO Entity”) are committed to protecting the privacy of individuals whose personal data we hold. This notice will help you understand how we look after personal data and how we make sure that we meet our obligations under data protection law (referred to in this notice as the "Data Protection Laws").

If you have any questions in relation to this notice or generally how personal data is processed by us, please contact our Data Protection Officer by email at: privacy@intoglobal.com

Introduction

In this privacy notice, the terms "we", "our", and "us" refer to INTO University Partnerships Limited and IUP2 LLP, both of 1 Gloucester Place, Brighton BN1 4AA (ICO registration numbers Z3504921 and ZA032598 respectively).

We are a controller of the personal data that is entered on Partner Portal by invited users using the secure log-in facility to access their account; from that point we become responsible for looking after that data. We use personal data fairly, lawfully and in a transparent manner, and in accordance with the Data Protection Laws.

We reserve the right to update this privacy notice at any time by changing it as it applies to the contractual obligations between us and the users of Partner Portal.

1. Important information

This privacy notice is intended for invited users of Partner Portal, giving them information about how INTO collects and processes personal data, including any information they may provide when submitting one or multiple international studies applications on behalf of students they are working with.

It is important that this privacy notice is read together with any other privacy notice or terms of use that we may provide to be fully aware of how and why we are using personal data. This privacy notice supplements INTO’s other notices and is not intended to override them.

It is also important to us that the personal data we hold is accurate and current. Please ensure any personal data of students that you are working with is kept update by securely logging-in to your account or contact us if any of personal data that we hold for you changes during your relationship with us.

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, please contact our DPO at privacy@intoglobal.com

What do the key terms mean?

“Data Protection Laws” means any law which relates to the protection of individuals with regards to the processing of their personal data; this includes the UK GDPR, the UK Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003; and where the EU GDPR also applies, the law of the European Union or any member state which relates to the protection of personal data; and any code of practice or guidance published by a Data Protection Regulator from time to time;

"Personal data" means 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" means 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.

Not covered in this privacy notice – our services may include links to websites run by universities or other companies; they will have their own privacy notices so remember that any personal data you give to them will follow their own rules and not ours. Make sure to read the privacy notice of every website you visit.

Individuals based within the European Union

Following the UK’s exit from the European Union (“EU”), we appointed EU Rep (Bizlegal t/a EUREP, Company number 635921, Ireland) as our Representative under Article 27 of the EU General Data Protection Regulation (“GDPR”).

All GDPR queries from EU Data Subjects or Data Protection authorities should be submitted to EU Rep via their dedicated form.

Supplemental privacy notices

2. The personal data that we collect

When logged into your Partner Portal account or depending on which entry route or country-specific services are selected by or for you, we may collect, use, store and transfer different kinds of personal data which we have grouped together as follows:

  • Contact Information includes email address, mailing address and telephone numbers;

  • Identity Information includes first name, last name, username or similar identifier, title;

  • Student application data may include Contact and Identity Information as well as educational history, qualifications, certifications, and test scores for students who you are working with - student application data submitted via Partner Portal is processed by us in accordance with our privacy notice published here;

  • Technical Information includes user authentication and login information, time zone setting and location, internet protocol (IP) address, browser and operating system information relating to how you access our services;

  • Usage Information includes information about how the reference materials we provide to help you support the students you are working with, as well as our information services on Partner Portal, are used.

3. How is personal data collected

We use different methods to collect information from you, including:

  • Information you provide. You may give us information including Identity and Contact details when completing relevant applications on behalf of the students you are working with, or by corresponding with us by phone, email or otherwise when

    • submitting an enquiry to us;

    • requesting promotional or other information be sent to you; or

    • providing feedback when taking part in a survey.

  • As you interact with Partner Portal. We may automatically collect Technical Information to authenticate your log-in details, ensure your account functions as expected, and ensure the online forms and information we provide for you also function correctly so you can successfully use our services . This information is collected by using technology that is necessary to ensure Partner Portal functions correctly; this may include use of essential cookies that are strictly necessary for the provision of our services to you but will mean you can continue supporting the students you are working with;

  • Third parties or publicly available sources. We may receive personal data from various third parties including Technical Information and Usage Information from analytics providers.

4. Basis for using personal data

INTO will use information to help us ensure that we provide, improve, and develop our services so you can easily find the international study programs the students you are working with are interested in.

We do need to have a valid reason to use personal data however - the "lawful basis for processing". For example, sending you information about our relevant partnership events and experiences for a service you have enquired about would be in our legitimate interests, where we are using your personal data in a way that you would reasonably expect, and which has a minimal impact on your privacy – see more information below. Information we collect may be used in the following ways:

  • where we are about to enter or have entered into a contract with you in respect of INTO’s partnership services. If we do not have the personal data we need when we ask for it, or if you object to any processing using your personal data, it is likely to mean that we cannot enter into the contract with you or provide the services under it.

  • where it is necessary for our legitimate interests, we will carry out a balancing test of ours and/or a third party’s legitimate interests in processing your personal data against your interests and rights under the Data Protection Laws. We will only process your personal data when your interests and rights do not override those interests. Our legitimate interests include:

    • informing and formulating our future strategies;

    • ensuring the smooth running of the Partner Portal platform and ensuring secure accounts are always available for our INTO partners to access;

    • keeping our facilities safe and secure;

    • ensuring our IT systems are robust and secure;

    • keeping adequate records;

    • enabling us to engage with you and provide you with relevant services.

We will only use 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 receive more information on the basis on which we process personal data you can contact us at privacy@intoglobal.com

5. How we use personal data

We use this information to deliver and improve the services we offer to our INTO partners. Examples of the services offered, and how we use personal data, include the following:

  • to register your interest when you submit an enquiry about working as an INTO partner so we can respond to you as necessary or take steps at your request before entering into a contract with you, and/or where such processing is necessary for the purposes of our legitimate interests;

  • to provide you with information regarding our partnership services and opportunities where such processing is necessary for the purposes of our legitimate interests;

  • to deliver our services to you and to provide you with information about them, including letting you know about any new offers and services which may be of interest to you or the students you are working with, and to enable us to personalise our communications to you where such processing is necessary for the purposes of our legitimate interests;

  • to enable us to conduct analysis, historical research, budget forecasting and management planning where such processing is necessary for the purposes of our legitimate interests in the smooth running of our business;

  • to enable you to participate in any surveys or any other promotions we may be running where such processing is necessary for the purposes of our legitimate interests;

  • to administer and protect our business and INTO Partner Portal where such processing is necessary for the purposes of our legitimate interests;

  • to deliver relevant content to you where such processing is necessary for the purposes of our legitimate interests; and

  • to deal with any requests from you regarding your rights under this notice to enable us to comply with a legal obligation.

Automated decision making: Assumptions may be made about your interests depending on the information you have shared with us about yourself and content on Partner Portal that you access. For example, if you enquired about our presence in the US, we assume you may be interested in our partnership activities and services in the US. Please contact us if you require further information regarding when any automated decision making may feature in our processes.

Marketing: We aim to provide you with choices regarding how we contact you, around the marketing and advertising of our services, and sending details of promotional offers from us. We conduct surveys and research and analyse the information that we have to evaluate and improve existing products and services and develop new products or features.

6. Disclosures of personal data

We may share personal data with other INTO Entities. We may also share personal data with selected external third parties including:

  • business partners;

  • third party suppliers or service providers who perform any services for us: for example, payment processing companies who process payments on our behalf; or technology companies whose systems we use;

  • analytics providers that assist us with the improvement and optimisation of Partner Portal;

  • third parties with whom we have a duty to disclose, for example, where disclosure is necessary due to a legal process or an enforceable governmental request; and

  • 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 personal data and to treat it in accordance with the Data Protection Laws. We also require third parties to process personal data for specified purposes in accordance with our instructions.

7. Transferring personal data outside the UK

The information we collect may be transferred to, and stored at, destinations outside the United Kingdom (UK). It may also be processed by staff of another INTO Entity operating outside the UK or by one of our suppliers. Such staff may be involved in providing support services as we require.

By submitting personal data to us, you are acknowledging that it could be transferred, stored or processed in a location outside the UK. Whenever we transfer personal data out of the UK, we ensure an equivalent level of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • personal data is transferred to countries deemed by the UK government to provide an adequate level of protection for personal data, known as ‘adequacy regulations’;

  • personal data is transferred to service providers who have agreed to contractual terms which gives personal data the same protection it has in the UK; we use the contractual terms approved by the Information Commissioner’s Office for restricted transfers.

Please contact us if you want further information on the specific mechanism used by us when transferring personal data out of the UK.

8. Information security

We place great importance on the steps we take, including use of different technologies and physical and organisational measures, to protect your information from unauthorised access and against unlawful processing, accidental loss, alteration, disclosure, destruction and damage.

We have in place procedures and technologies to maintain the security of personal data from the point of collection to the point of destruction. We will only transfer personal data to third parties if they agree to comply with those procedures and policies, or if they put in place adequate measures themselves.

Password confidentiality. The confidentiality of any password that enables you to access your Partner Portal account is your responsibility, whether we have given you the password or you have chosen it yourself. We ask you not to share your password with anyone. We will not be liable for any unauthorised transactions entered into using your account details, personal information and/or password.

9. Information retention

We will keep personal data for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, accounting, or reporting requirements. We may also retain it for a period after this time as may be necessary and relevant to our legitimate operations.

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

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

10. Legal rights

Individuals have several rights in relation to their personal data under the Data Protection Laws, including, the right to:

  • Request access to their personal data (commonly known as a "data subject access request") which enables them to receive a copy of the personal data that we hold about them;

  • Request the correction of their personal data that we hold. This enables any incomplete or inaccurate data that we hold to be corrected, although we may need to verify the accuracy of the new personal data that is provided to us;

  • Request erasure of their personal data. This enables them to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Please note, however, that we may not always be able to comply with such requests for specific legal reasons which will be notified to them, if applicable, at the time of their request;

  • Object to the processing of their personal data where we are relying on public interest or a legitimate interest (or those of a third party) and there is something about their particular situation which makes them want to object to the processing. They also have the right to object to where we are processing their personal data for direct marketing purposes;

  • Request the restriction of processing of their personal data. This allows them to ask us to suspend or limit the processing of their personal data in certain circumstances. This may be because they have issues with the content of the information we hold or how we have processed their data. In most cases you will not restrict the processing of their personal data indefinitely but will have the restriction in place for a certain amount of time;

  • Request the transfer of their personal data. Where possible, we will provide to their personal data in a structured, commonly used, machine-readable format. This right only applies to automated information which they initially provided consent for us to use or where we used the information to perform a contract with them; and

  • Withdraw their consent at any time where we are relying on consent to process their personal data. If consent is withdrawn, we may not be able to provide certain products or services to them and will advise them at the time.

To exercise any of the rights set out above, or to obtain further information about any of those rights, please email us via: privacy@intoglobal.com or complete our Online Rights' Request form - we need to ask for specific information to be able to deal with any such request. This is a security measure designed 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 for further information in relation to any request you make in order to speed up our response.

Time limit to respond: We aim to respond to all legitimate requests as soon as possible and within one calendar month of receipt. Occasionally it may take us longer than a month if a request is particularly complex but we will notify the requester and keep them updated.

11. What happens if I choose not to provide my personal information?

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, our obligations under a partnership agreement). In this case, we may have to cancel the contract you have with us or the services you require from us, but we will notify you if this is the case at the time.

12. How to contact us

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

Email: privacy@intoglobal.com

By post: F.A.O. The Data Protection Officer, INTO University Partnerships Limited, One, Gloucester Place, Brighton, East Sussex, BN1 4AA, England.

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