Our privacy policy will help you understand what information we collect at StudentApply Website (“Website”), how StudentApply uses it, and what choices you have. Our systems and procedures are subject to ongoing change as both our technology and data practices evolve and improve, and this document will reflect that, always conforming and complying with European General Data Protection Regulation (GDPR). When we talk about “StudentApply”, “we,” “our,” or “us” in this policy, we are referring to StudentApply., the company which provides the Services. When we talk about the “Services” in this policy, we are referring to our online community and platform intermediation service.

This Privacy Policy applies to your use of the StudentApply Service as a customer. This Product Privacy Policy describes how we collect, receive, use, store, share, transfer, and process your Personal Data. It also describes your choices regarding use, as well as your rights of access and correction of your Personal Data.

We periodically update this Product Privacy Policy. We will post any changes on this page and, if the changes are material, we will provide an update through the notification app in your StudentApply account. Content and information submitted by users to the Services is referred to in this policy as “Personal Data”. Where StudentApply collects or processes Personal Data, it does so on behalf of the Customer in order to deliver services, or to keep the customer aware of services they have either expressed an explicit interest in or are directly related to services they are explicitly interested in.

StudentApply may access and use the Personal Information you have provided us as reasonably necessary and in accordance with your instructions to provide, maintain and improve the Services.

I. HOW WE COLLECT AND USE YOUR DATA

Personal information you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your personal information in the following ways: to operate, maintain, and improve our Services; to personalize and improve your experience; to respond to your inquiries and send you promotional communications about our products and services, unless you have opted out of such promotional materials, and other communications; and to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.

The StudentApply Service and Website can also be used to help organize sales data about The StudentApply sales pipeline (e.g., leads, customers, deals, etc.). The information added to The StudentApply Service, either by site visitors providing their contact information or when a Service user adds the information, is stored and managed on our service providers servers. The Website provides to StudentApply the tools to supply marketing, sales, and customer service needs. Regarding this matter, it is also important to note the following:

1. Create a Student Profile and/or Apply to an Educational Program: We may collect information that you submit or otherwise provide to us, such as when you submit comments or make an inquiry or register from any component of the Services. For example, we may collect your email address and contact information when you e-mail us comments or inquiries.

   In order to apply to an educational program, you (or the recruitment partner acting as your legal representative) are required to create a student profile on our Website. The personal information we collect in your student profile helps us match you with schools and programs that fit your preferences and qualifications. This information may also be required by the school for the purposes of processing your application. This information may include your first and last name, email address, gender, date of birth, home and mailing address, passport details, marital status, emergency contact information, language test score(s), educational preferences (such as preferred study destination and educational fields of interest), education history, volunteer experience, and other educational information.

   For the record, we may collect your information in any of the following scenarios when you engage in or perform any of the following activities, among others, in relation with or at the StudentApply Website:

   • VII.Create a StudentApply Account.
   • Create a Profile and/or Apply to our School Partners.
   • Schedule an Individual Consultation with StudentApply
   • Communicate with Us via Email, by Phone or directly through the StudentApply Website or web application.
   • Use our Services and pay for them through the payment platform of our choice.
   • Provide information to third parties who we work with.
   • Sign up for marketing emails and other communications.
   • Participate in our surveys and customer research.
   • Sign up for contests and promotions.
   • Apply for employment at StudentApply.
   • Apply to become a Recruitment Partner.

2. StudentApply processes our costumers information as they direct and in accordance with our agreements with our costumers, and we store it on our service providers servers. Our agreements with our customers prohibit us from using that information, except as necessary to provide and improve the Service, as permitted by this Product Privacy Policy, and as required by law.

3. Use of Our Services for Visa Processing: We offer students the option of processing their student visas through StudentApply. If you choose to use this service, we may collect personal information for the purposes of processing your visa application (if necessary), including passport details and information included on a visa application form.

4. Payment Processing and Transaction Tracking: StudentApply uses, with your consent, third party certified payment service providers such as PayPal. Our applications are designed to directly connect our user’s security, transparently and cryptographically certified payment processor. This ensures we maintain the privacy of your financial transactions. The payment processor provides StudentApply with a transaction number and status. This information is often required for Visa applications as proof of program payment as well as a demonstration of student commitment to their selected program.

We have no direct relationship with individuals who provide Personal Information to our customers. Our customers control and are responsible for correcting, deleting or updating information they have collected from using the StudentApply Service. We may work with our customers to help them provide notice to their visitors about their data collection, processing and usage.

II. WHAT INFORMATION DO WE COLLECT?

When You Visit our Website

You are free to explore the Website without providing any Personal Information about yourself. When you visit the Websites or register for the Subscription Service, we request that you provide Personal Information about yourself, and we collect Navigational Information.

"Personal Information"

We collect personal information from you when you submit web forms or interact with our Website as stated on Point 1.1 of this Privacy Policy.

"Personal Information" refers to any information that identifies you personally, including contact information, such as your name, e-mail address, gender, date of birth, home and mailing address, passport details, personal identification numbers, marital status, emergency contact information, language test score(s), educational preferences (such as preferred study destination and educational fields of interest), education history, volunteer experience, and other educational information. Personal Information can also include information about any transactions, both free and paid, that you enter into on the Websites, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or information that we acquire from service providers.

Personal Information includes Navigational Information or Payment Information where such information can directly or indirectly identify an individual.

• Navigational information refers to information about your computer and your visits to the Websites such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the "Use of Navigation Information" section below.
• Payment information includes information we collect and process from you when you use payment platforms made available for you in our Website.

"Sensitive Information"

This refers to credit or debit card numbers, financial account numbers or wire instructions, biometric information, personal health information (or other information protected under any applicable health data protection laws), personal information of children protected under any child data protection laws, and any other information or combinations of information that falls within the definition of “special categories of data” under GDPR or any other applicable law relating to privacy and data protection.

Log Files

When you view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by StudentApply to provide general statistics regarding the use of the Website. For these purposes, we do link this automatically-collected data to other Personal Information such as name, email address, address, and phone number.

Information We Collect From and Of Third Parties

From time to time, we may receive Personal Information about you from third party sources including partners for whom we offer services as intermediaries and/or with which we offer co-branded services or engage in joint marketing activities, and sources such as social media websites.

If you are an administrator at one of our School Partners who uses StudentApply Website to receive student admission application data, we may collect your name, post, employment data, and email address in order to allow you to retrieve applicants information. The personal information of the administrator is also shared with certain third party vendors to enable access to a student applicant payment status information.

If you are a parent or legal guardian we may collect personal information about you from the applicant, including your name, relationship with the applicant, address, telephone numbers, and/or email address.

III. HOW WE SHARE THE INFORMATION WE COLLECT

1. With Service Providers: We employ other third-party service providers to provide services on our behalf to visitors to our websites, our customers, and Users of the Service and may need to share your information with them to provide information, products or services to you. Examples may include removing repetitive information from prospect lists, analyzing data or performing statistical analysis, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, and providing customer service or support. These service providers are prohibited from using your Personal Data except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies.
2. Due to Corporate Events: If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by StudentApply on the websites and the Service. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Data, and choices you may have regarding your Personal Data.

IV. DATA COLLECTED VIA TECHNOLOGY.

To make our Services more useful to you, our servers collect information from you, including browser type, operating system, Internet Protocol (IP) address, domain name, unique device identifiers, and information about how you use our Services. We also may collect information regarding the date and time of your visit and the solutions and information for which you searched and which you viewed. Like most Internet services, we automatically gather this data and store it in log files each time you visit our Services.

We, and third parties, may use cookies, web beacons, and other tracking technologies to collect this information. See below for information about the choices you may have in connection with such tracking technologies.

1. Cookies: are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Services. Most web browsers are set to accept cookies by default. If you prefer, you can typically remove and reject cookies from our Services with your browser settings. If you remove or reject our cookies, it will affect how our Services work for you.
2. Web Beacons: are digital images we use to log information on our Services and in our emails. We use web beacons to manage cookies, count visits, and to learn what marketing works and what does not. We also use web beacons to tell if you open or act on our emails. You may render some web beacons unusable by rejecting their associated cookies. If you choose to decline such cookies, certain features of the Services that placed the cookie may not function properly or at all as a result.
3. Flash Cookies: are used to store your preferences such as volume control or to display content based upon what you view on our websites to personalize your visit. Third party partners who provide certain features on our websites, such as videos, may place Flash cookies on your device. They may use Flash cookies to track your web browsing activity and to display personalized advertising. Flash cookies are different from other cookies because of the amount of, type of, and way in which data is stored. Cookie management tools provided by your browser usually will not remove Flash cookies. We do not control the privacy practices of the third parties who place, or track Flash cookies and this Privacy Policy does not cover their practices. You should visit the privacy policies of companies who place Flash cookies to understand their practices.
4. Analytics: We use analytics services to help analyze how users use the Services. These analytic services use cookies and scripts to collect and store information such as how users interact with our applications, errors users encounter when using our applications, device identifiers, how often users visit our website, what pages they visit, and what other sites they used prior to coming to our website.

V. DATA SUBJECT REQUESTS

If you are a customer, prospect, or otherwise interact with one of our Customers and would no longer like to be contacted by one of our customers that use our Service, please contact the customer that you interact with directly. If you want to access, correct, amend, or delete data controlled by a StudentApply customer, you should direct your query to the StudentApply. We will work with customers to respond to data subject requests.

You may request the deletion of your StudentApply account or Service by sending a request here asapanova@studentapply.org.

VI. DATA RETENTION

Customer Data collected during your use of the StudentApply Service is retained in accordance with the provisions in this Policy and is retained for as long as the provision of the service and the account validity or remain an StudentApply customer. Your data is deleted upon your written request or after an established period following the termination of all customer agreements. In general, Customer Data is deleted after your service ends and your Account becomes inactive.

Your Rights:

1. Access.
2. Correction (Right to rectification).
3. The right to withdraw or be forgotten.
4. The right to report or complain.

Should you wish to lodge a concern of complaint to StudentApply, please contact us as set out below. We will respond to your concerns in a reasonable time, typically within 15 business days.

VII. HOW WE TRANSFER DATA WE COLLECT INTERNATIONALLY

International Transfers Within StudentApply Entities: To facilitate our global operations, we transfer information to other countries and allow access to that information from countries in which StudentApply partners have operations for the purposes described in this policy. This Privacy Policy will apply even if we transfer Personal Data to other countries. We have taken appropriate security measures to require that your personal data remain protected. When we share information about you within and between StudentApply Partners, we make use of standard contractual data protection clauses, which have been approved.

1. International Transfers to Third Parties: Some of the third parties described in this privacy policy, who provide services to us under contract, are based in other countries that may not have privacy and data protection laws equivalent to those of the country in which you reside.
2. StudentApply is responsible for processing the personal data it receives under this Privacy Policy and subsequently transfers it to a third party acting as an agent on its behalf. StudentApply complies with the Privacy Principles for all subsequent transfers of personal data.
3. With respect to personal data received or transferred pursuant to the Privacy Policy framework, StudentApply is subject to the regulatory enforcement powers. In certain situations, StudentApply may be required to disclose personal data in response to lawful requests from public authorities, including to comply with national security or law enforcement requirements.

VIII. DISCLOSURE OF YOUR PERSONAL INFORMATION

We will share your personal information with third parties, including as follows:

1. We may share your information with our parent company, subsidiaries, joint ventures, and other companies under a common control to use consistent with this Privacy Policy.
2. We may share your personal information with third party service providers for the purpose of providing you with the Services. For example, we may share data with service providers who host our websites or provide email services on our behalf.
• We may disclose information about you if we believe such disclosure is necessary to:
• Comply with laws or to respond to lawful requests and legal process;
• Protect or defend the rights, safety, or property of us, users of the Services, or any person including to enforce our agreements, policies, and terms of use;
• In an emergency to protect the personal safety of any person.

We may also share information about you in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture or disclosure of all or a portion of our business or assets to another company. In these circumstances, we will only share information with a company that has agreed to data privacy standards no less stringent than our own. In the event that information is shared in this manner, notice will be posted through our Services.

In addition to the sharing described in this Privacy Policy, we may share information about you with others for their own uses whenever you consent to or direct such sharing. We also may share other information with third parties in a manner that does not identify particular users, including, for example, aggregated information.

IX. CHILDREN’S INFORMATION

Our Services are not directed to children under 13. If you learn that a child under 13 has provided us with personal information without consent, please contact us

You may direct any inquiries or complaints related to our Privacy Policy compliance here asapanova@studentapply.org also, if you have an unresolved privacy or data use concern that we have not addressed satisfactorily. Under certain conditions, more fully described in this Privacy Policy you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

You may contact our Data Privacy Officer by email at asapanova@studentapply.org.