Privacy Policy UniApply About us Student Path S.R.L., a company incorporated and functioning under the laws of Romania, having its registered headquarters in Romania, Tax Code 43299136, registered with the Trade Registry under no. J38/883/2020 in the rest of this document referred to as Uniapply. We maintain our headquarters at: Episcopul Radu 8B street, Bucharest, Romania; For more information visit: https://www.uniapply.org Uniapply hereby wishes to inform you of the processing of your personal data under the Participation Agreement that you have agreed to at the events organized by Uniapply. This section of the information note shows the purposes, legal basis and personal data processed by Uniapply during the recruitment process and during the online information events on the offers of university study programs within Uniapply. Please note that some of the processing described in this Policy we undertake as controller, but for some of the processing we may merely act as processor and the educational institutions and other organisations for which we collected your information or to whom we disclosed your personal information, which will act as controller. Please check the privacy policy of the educational institutions concerned to find out how they process your personal data. Types of personal data we process General We may collect and process, whether or not on our own behalf or on behalf of one or more educational institutions, the following categories of personal information: 1 of 9 Name, email address and other identifying information • For example, we may record your name, email address, gender, date of birth, nationality, country of residence, education history, achievements, or language test scores. Your contact details and personal account/registration details • Your contact details may include: your address, telephone number, and email address. When you create a personal account or register for a service, we may also record your sign-in details and other information you provide when you create your personal account or fill in a registration form. Your personal documents • For example, we may need your documents so that we can transfer these documents to partner universities or other institutions where an applicant wishes to retain our services regarding the educational process of applying to a curriculum. Our communication with you • When you send us an email, or chat with us online or via social media, we save your correspondence with us. Information we collect when you use our Website • When you visit our Website or use our services, we may register your IP address, browser type, operating system, referring website, web-browsing behaviour. • We may receive an automatic notification when you open (or open a link from) a newsletter. Cookies and similar technologies When you use our Website for the first time, a cookie notice is shown. UniApply uses the information collected through cookies strictly for the purposes stated in the Cookie Statement, found to this link. How we collect your data UniApply collects personal information in a number of ways. Information is obtained, for example, when you visit our Website, register on our Website, communicate with us via social media, or subscribe to our newsletter. 2 of 9 We may also receive personal information from associated educational institutions, subsidiaries, partners, or other service providers. Purposes of processing your data We process personal information for the following purposes: Providing services to you UniApply processes personal data to provide our services. For example, personal data is processed so, for example: • Based on the country or field of study that you choose, we can send you programme recommendations that we believe best match your profile; • To make your user experience easier and more effective, we may assess how you use our services, and combine this data with information collected via your personal account, registration details, cookies, and similar technologies. This combination enables us to, for example, optimize our search algorithms, assess your admission chance or match with particular education opportunities; For these purposes, UniApply processes the following personal data: name, digital contact details, shortlisted programmes, disciplines and countries of interest, funding situation, previous education information. UniApply is allowed to process personal data for these purposes for pursuing its own legitimate interest or those of the educational institutions; with the legitimate interest being to allow UniApply to provide the best service it is able to, in order to align you with the educational institutions of your choice. To communicate with you UniApply processes contact details to communicate with you, answer your questions, or handle your complaints. This applies to students. For this purpose, UniApply processes the following personal data: communication history, name, digital contact details, message. UniApply is allowed to process personal data for this purpose to pursue its own legitimate 3 of 9 For processing student applications for specific universities UniApply processes personal information to enable students to apply for specific universities through UniApply portal. For this processing of your personal data information, UniApply will act as a mere processor processing your information on behalf of the educational institution concerned. For this purpose, UniApply processes the following personal data on behalf of the educational institution: name, digital contact details, analog contact details, passport, educational transcripts, CV, various credentials (e.g. English language proficiency), demographic information, shortlisted programmes, disciplines and countries of interest, funding situation, preferred start period, previous education information, work experience. UniApply is allowed to process personal data for this purpose because it is necessary for pursuing the legitimate interests of the educational institutions; with the legitimate interest being UniApply to be able to communicate with you for providing the best service it can to align you with the educational institutions of your choice. Allowing you to provide reviews UniApply processes personal information when you have left behind a review about a specific educational institution or a specific program. For those purposes, UniApply processes the following personal data (whether or not by means of a rating): programme, educational institution, personal life and overall experience with respect to the educational institute and its location. Please note that any written reviews may be checked by UniApply before exposing, automatically or manually, because UniApply wants to make sure only high-quality reviews are being exposed. We only remove reviews in the following situations: • In case UniApply or another organisation or institution can prove a respondent did not study at the reviewed institution or program. • When the review includes abusive language, swearing, discriminatory remarks, threatening, or personal political, sexual, religious, and ethical viewpoints. • When the review promotes illegal or commercial activities. 4 of 9 • In case the review is written by a reviewer several years after they have studied at the institution. • When reviews are not the personal experience or opinion of the respondent. • If reviews repeatedly address fellow reviewers on a personal level. • If reviews are exposed in a repeatedly disturbing way. • If it includes contact details like phone numbers, addresses or links to other websites. • If reviewers pretend to be another person or organisation than itself. • If we suspect that a review isn’t genuine; for example, might be used to target a competitor. • If a review contains content that violates the rights of another person or an organisation, intellectual property rights, and privacy rights. • Reviews entered by the threat of extortion. • If a review doesn’t contain information about the university or programme in detail. UniApply is allowed to process personal data for these purposes because this is necessary for pursuing its legitimate interest or that of the educational institutions. These legitimate interests being that student reviews have found to be extremely helpful when aligning potential students with the best fitted educational institution or programme which is the core of UniApply’s services. For statistical research UniApply processes personal information for the development and optimisation of its services. We broadly examine how our users behave towards our services, as well as the preferences our users set. Statistical research helps us develop better services and offerings, allowing us to improve the design and content of our Website. We can also advise higher education institutions on how they can better serve you. For this purpose, UniApply processes the following personal data: name, digital contact details, previous education information, IP address, cookies and comparable services, browser data, device specifications, referring website, browsing behaviour and website interactions, social media likes. We may also combine such aggregated data with information we receive from our subsidiaries, educational institutions, or from public sources. 5 of 9 UniApply is allowed to process personal data for this purpose because UniApply has a legitimate interest in developing and optimising its services. You can object to this processing on the basis of your particular situation. For direct marketing purposes UniApply processes personal information for (direct) marketing purposes. This means we may use your personal information to send you newsletters, promotions, or other marketing communications. We use the results of our analysis to tailor our marketing communications to your specific interests and preferences. For example, if our analysis shows that you may be interested in certain types of programmes or a specific country, we may customise our newsletter and Website with content that are relevant to you. We may use different channels for our marketing communications, such as email, social media, and your personal online account. For this purpose, UniApply processes the following personal data: name, digital contact details, previous education information, IP address, cookies and comparable services, browser, device specifications, referring website, browsing behaviour and website interactions, social media likes. We may also combine such aggregated data with information we receive from our subsidiaries, educational institutions, or from public sources. UniApply is allowed to process personal data for this purpose because you gave consent or because UniApply has a legitimate interest. The consent can be withdrawn at any moment, and you can object at any moment to the processing of your personal data for direct marketing purposes when such processing is based on UniApply or the educational institutions’ legitimate interest. The withdrawal of consent or exercise of your right to object does not affect the lawfulness of the processing prior to the moment of withdrawal or exercise of the right to object. You may object or revoke your consent for receiving marketing communications at any time, by following the instructions in the relevant marketing communication or by sending an email at : GDRP@uniapply.org To initiate and evaluate business relationships Your personal data will be processed for the entering into agreements and the performance thereof to the point of commercial services and the managing of the business 6 of 9 relations which emerge from them, including the performance of activities aimed at the expansion of our client database. Disclosing or sharing data with third parties General We reserve the right to release personal information without your consent or without consulting you, when we deem it necessary to comply with our legal obligations, to enforce our terms and conditions, to protect the security of this Website, or to prevent fraud. Other institutions or businesses You can apply to education institutes through our Website, by means of an electronic form. The details in your inquiry will then be shared with the institute you are trying to apply. We may share personally identifiable information (such as name, nationality, and email address) with carefully selected education institutions, to verify the status of your application or enrolment, evaluate and manage the performance of our business agreements or initiate new agreements. Some of these institutions may also have access to your information so that they may consider further marketing campaigns or recruitment measures. We will inform the education institutions that they are not allowed to use your personal information for any reason other than mentioned above. Users should note however that, how these educational institutions use this data is not governed by our privacy policy. Therefore, we cannot be held responsible for how the data is utilized once it is shared with them. Educational institutions have separate policy practices for which UniApply has no responsibility or liability. For further information on how such institutions use your information, please visit the applicable privacy policy of that institution. Other countries UniApply may your personal data to countries outside of your country of residence. This might occur in the course of sharing information with education institutions or our subsidiaries, with whom we have explicit agreements with how they can or cannot 7 of 9 use the data. In most cases, these agreements will be in the form of a written and signed Partnership Agreement, on the use of personal data. Some of these countries may not have an adequate level of personal data protection compared to the level of protection provided in your own country. UniApply does not systematically store your information outside the European Economic Area (‘EEA’), and does not transfer your data outside of the EEA without either your consent or after ensuring adequate safeguards that allow the safe transfer of your personal information. If apply to, or enrol at, an education institution through UniApply which is located outside the European Economic Area, your data will necessarily be transferred to that country. Security and retention UniApply takes the safeguarding of your information very seriously. UniApply will take appropriate technical and organizational measures to protect your personal data against loss or unlawful use. These measures include but are not limited to: facilities protected by appropriate security measures, encryption of devices, version tracking and access to our databases is limited to key personnel and IP addresses and use of it is logged. Personally identifiable information and account activity are also protected through the use of user names and passwords. In order to help maintain the security of your information, you should protect the confidentiality of your user name and password. Your personal data will be retained for as long as required for the purposes described in this Policy, or insofar as is necessary to comply with our contractual or statuary obligations, and to solve any disputes. In most cases, your personal data will be retained for forty-eight (48) months after your last activity, or until you request deletion. UniApply retains your data for that period to optimize their services to you throughout your educational period, which statistical research has shown to usually span a period of more than thirty-six (36) months. Your Rights You can request access to or a copy of your personal data collected by us. You may also request the rectification and removal of personal data or the restriction of the processing of your personal data, if there is a reason for doing so. You also have the right to data portability. You also have the right to object to a processing on grounds relating to 8 of 9 your particular situation or against the processing of your personal data for direct marketing purposes. To exercise your right(s), please send your written request, to: GDPR@uniapply.org In order to ensure that the request you are submitting on your behalf is legitimate, in some cases it may be necessary for us to obtain further proof of identity either in person or via webcam. This is only necessary in those cases where we have doubts about the identity of the person submitting the request. Modifications to this Policy This Privacy Policy is effective as of 3 December 2020. We reserve the right to alter or otherwise make changes to this Policy. We will notify you of any changes by posting the revised policy on our Website and notifying you through a banner or in case of very material changes to the Policy, via email. Changes take effect as soon as the Policy is posted. Questions or complaints If you have any question or complaints about the processing of your personal data, please send an email to us at GDPR@uniapply.org. 9 of 9
