For the purposes of the Data Protection Act 1998 and the EU General Data Protection Regulations , the Company is a Data Controller in respect of any personal data that the Company, its affiliates and/or its subcontractors collect. The Company also acts as a Data Processor in respect of any personal data it receives from and/or collects directly on behalf of each of our Partners. Further information on how your data is processed and for what purposes is set out below.
The information you provide to us through the Site, Third Party Websites and/or which you otherwise provide to us through other means from time to time will initially be collected by the Company but may then be shared with other companies in the Keypath group of companies, including Keypath Education Holdings LLC (“the Group”). All references to “the Company”, “we” and “our” in this Policy therefore include the Group, unless distinguished in the text. Depending upon your relationship with the Company, we may separately provide you with further details about our use of your personal information.What type of information does the Company collect and why?
When you visit our Site, we may, like the majority of websites, automatically collect standard internet and website log information and details of patterns about how website visitors behave. The information we may collect may include but is not limited to:
- information about your Internet service provider;
- your operating system;
- browser type;
- domain name;
- the Internet protocol (IP) address of your computer (or other electronic Internet-enabled device);
- your access times;
- the website that referred you to us; and
- the Web pages you request and the date and time of those requests.
This may allow us to find out which parts of the Site are popular or need changing to enhance your website experience.
The Site allows you to interact with the Company primarily through the request form set out on the Site. If you want to use the Company’s services to obtain further details about a Partner(s) or if you request further information about our services, you will need to provide us with some additional personal information eg name and email address so that we can liaise with you in order to deal with your request or query. If you do choose to provide us with your personal information, we will collect that information for our own use and for the purposes described in this Policy.What type of personal information does the Company collect?
Where you choose to provide personal details to us, whether through the Site or otherwise, we may collect the following personal information from you:
- details of your visits to the Site, which may include traffic data and location data;
- the reason for your contact, which may be an enquiry or a request;
- information that you provide when you sign a “Request More Information” form, which may include the course you would like to study, your name, address, email address, telephone number and/or country;
- information necessary for legal compliance; and/or
- if you publicly post about us, or communicate directly with us, on a social media website, we may collect and process the data contained in such posts or in your public profile for the purpose of addressing any customer services requests you may have.
This information will be collected primarily from you as information voluntarily provided to us (primarily by telephone) or to our Partners, but we may also collect it where lawful to do so from (and combine it with information from) public sources, third party service providers, individuals who you have indicated have agreed for you to provide their personal information, government, tax or law enforcement agencies and other third parties. We may also collect personal information about you from your use of other Company websites or services.How does the Company use information about you?
The Company may use information about you for purposes described in this Policy or as otherwise disclosed to you on our Site or with our services. For example, we may use information about you for the following purposes:
- to respond and/or deal with your request or enquiry;
- to send you information about the course, programme and/or university which may be of interest based on the preferences you have indicated;
- to provide you with marketing information where you have agreed to receive this ();
- to ensure that our content is presented in the most effective manner for you and for your computer (or other electronic Internet-enabled device);
- to administer the Site;
- for internal record keeping;
- to contact you by e-mail or phone for any of the above reasons;
- where necessary as part of any restructuring of the Keypath Group; and
- for compliance with legal, regulatory and other good governance obligations.
This list is not intended to be exhaustive and may be updated from time to time as business needs and legal requirements dictate. Some of the personal information that the Company maintains will be kept in paper files, while other personal information will be included in computerised files and electronic databases as set out in more detail below.
In most cases, the information the Company processes about you is required to deal with the purpose for which you have specifically submitted them, such as the receiving requested information, responding to your enquiry, as required by law or is necessary for the exercise of the Company’s legitimate business interests and needs.
The Company may also convert personal information into anonymous data and use it (normally on an aggregated statistical basis) for research and analysis to improve Company and Group performance. Any such information that we collect and share is anonymous and not personally identifiable.Does the Company share personal information with third parties?
Your personal information will be made available for the purposes mentioned above (or as otherwise notified to you from time to time), on a ‘need-to-know’ basis and only to responsible management, accounting, legal, audit, compliance, information technology and other corporate staff who properly need to know these details for their functions within the Company. Please note that certain individuals who will see your personal information may not be based at the Company or in your country of residence (please see below).Sharing information with the Keypath Group
The Site includes links to third party websites and some of your personal information from your browsing session may be transferred to such third party websites. Where our website contains links to websites operated by third parties (for example advertisers or affiliates of the website owner), you may provide your personal data to the owners of such third party websites without realising that the use of your data by the third party is not governed by this Policy. You should always check the privacy policies of third party websites before submitting your personal information. Please see our Cookies Policy for more information. We will not sell your personal information to any third party other than as part of any restructuring of the Company or Group or sale of a relevant Group business.Sharing of your personal information with Partners
In addition to processing your personal information on behalf of our Partners, you agree we may also collect and share your personal information with our Partners for the purposes of the Company and its Partners collaborating in order to develop, deploy and deliver courses to facilitate flexible online learning. For example, we may share the following information:
- your name, address, email address, telephone number and/or country;
- your preferred course(s) and/or programme(s);
- duration of your preferred course(s) and/or programme(s);
- enrolment details and/or time
- the number of course(s) and/or programme(s) you choose to enrol with; and
- financial investment in course(s) and/or programme(s).
Please note that our Partners will have their own privacy policies and they may be different from ours. Please visit the following Third Party Website for more information at http://www.exeter.ac.uk/privacy/.
If you wish to contact the Company in respect of its data sharing activities, please contact us at email@example.com, or write to:Keypath Education UK Ltd
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Will your personal information be transferred abroad?
Some transfers of personal information to third party recipients have been explained above. Where personal information is transferred outside of the European Economic Area (“EEA”), whether within the Group or to Partners or third parties (as set out in this notice), EU and UK data protection laws will not apply but steps will be taken to protect your personal information in that instance consistent with applicable law. We may also transfer your personal information outside of the EEA to the other members of the Group to assist us in addressing and/or resolving specific product or service issues you have raised with us, where we have been unable to identify the appropriate solution from within the UK.What choices does the Company offer you with regard to direct marketing?
The Company may wish to provide you with information about new products, services, promotions and offers, which may be of interest to you and may invite you to take part in market research or request feedback on our products and services and the Company’s products and services. This communication may occur by e-mail, telephone, post or SMS. We will obtain appropriate consent from you (on an opt in basis, as applicable) and advise you of how to opt-out of receiving such communications where we are required to do so in accordance with applicable law. You may opt-out of direct marketing activities by emailing firstname.lastname@example.org, or write to:Keypath Education UK Ltd
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What safeguards are in place to protect your personal information?
We use a variety of security measures to maintain the safety of your personal information. Your personal information is processed, stored and protected by firewalls and intrusion detection systems, plus industry standard encryption. Nevertheless, whilst we take efforts to safeguard your personal information which are consistent with relevant laws, the nature of the internet is such that we cannot guarantee absolutely the security of any personal information you disclose online.What rights do you have to review and amend personal information?
You have the right to review your personal information held by the Company (including any profiling information) and have certain inaccurate information about you corrected. Under UK law, a request for access to your personal data needs to be in writing.
If you wish to do so, or to contact the Company in respect of its data processing activities, please contact us at email@example.com, or write to:Keypath Education UK Ltd
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Keeping you informed
We will keep your details on record until we have completely dealt with your request, enquiry or application and then for a reasonable period afterwards, in accordance with data protection and other applicable legislation.
The Company may keep your details on record for as long as is necessary for the purposes set out above and will then endeavour to delete your details in accordance with data protection and other applicable legislation.Changes to this Policy
We keep this Policy under regular review. We may change this Policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. The date at the top of this Policy will be updated accordingly.
We encourage you to check the date of this Policy when you visit the Site for any updates or changes. We will notify you of any modified versions of this Policy that might materially affect the way we use or disclose your personal information.
By using our Site, submitting your personal information to us and/or registering an account, you consent to the use of your personal information as described in this Policy (as amended from time to time).
This Policy only extends to the personal information processed by us and does not, therefore, extend to your use of, provision of data to and collection of data on any website not connected to us to which you may link by using the hypertext links within this website including Third Party Websites.Contact/address details
If you have any questions about this Policy, please contact us at firstname.lastname@example.org, or write to:Keypath Education UK Ltd
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