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Privacy Policy

UNIVERSITY COMPARE

PRIVACY NOTICE

Introduction

Welcome to UNI COMPARE LTD’s (‘University Compare’s’) privacy notice. This privacy notice may be updated from time to time, so please check our website for the latest version. This privacy notice is dated May 2018.

University Compare respects your privacy and is committed to protecting your personal data. This privacy notice will tell you:

  • how we look after your personal data when you visit our website www.unicompare.com or use our App (the software applications made available by us for use on or through computers and mobile device), regardless of where in the world you visit it from; and
  • how we look after your personal data generally (so looking at your personal data and how it is used in ways that do not involve our website/App); and
  • about your privacy rights and how the law protects you.

To make this privacy notice as easy to understand as possible, you can either click on the link below to take you to particular information that you are interested in, or you can keep reading through the whole document.  If you are not sure what we mean by particular words or phrases, you can use the “Glossary” below which will help you understand the meaning of some of the terms used in this privacy notice.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED
  4. HOW WE USE YOUR PERSONAL DATA
  5. WHO WE SHARE YOUR PERSONAL DATA WITH
  6. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
  7. HOW WE KEEP YOUR PERSONAL DATA SAFE
  8. HOW LONG WE KEEP YOUR PERSONAL DATA FOR
  9. YOUR LEGAL RIGHTS
  10. GLOSSARY
  • Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how University Compare collects and processes your personal data through your use of our website www.universitycompare.com and your use of our services generally, including any data you may provide when you:

  • sign up to our services via the website or App;
  • fill in a form our website;
  • upload a review;
  • provide us with information about your interests and preferences; or
  • provide us with feedback.

It is important that you read this privacy notice together with any other privacy notice we may give you on specific occasions when we are collecting or processing personal data about you.  Reading our privacy notices will help you understand how and why we are using your data.

Controller

University Compare is the controller and is responsible for your personal data.  In this privacy notice, wherever the words “we“, “us” or “our” are used they refer to University Compare.

We take our duties to look after your personal data seriously.  To help us look after your personal data, we have appointed a member of our staff as a Data Privacy Manager to oversee your questions relating to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights (see below), please contact our Data Privacy Manager using the contact details set out below:

Contact details

Our full details are:

Full name of University Compare: UNI COMPARE LTD

Name of Data Privacy Manager: Owen O’ Neill

Email: hello[at]universitycompare.com

Postal Address: Unit 8B Kingsdale Business Centre, Chelmsford, Essex CM1 1PE

Telephone number: 0 (+44) 1245 600 094

We want to let you know that if you are unhappy about something relating to your personal data, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO).  The ICO is a government body that supervises data protection issues in the UK.  You can find out more information about the ICO by visiting its website (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact our Data Privacy Manager, and tell us why you are unhappy before contacting the ICO.

Your duty to inform us of changes to your personal data

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.  An example of when your personal data may change may be when you move house or when you change your contact details such as your email address.

Third-party links

When you use our website www.unicompare.com, it may include links to other websites that we do not own or control (third party websites)Clicking on those links may allow those third party websites to collect or share data about you. When you leave our website, we encourage you to read the privacy notice of every website you visit.  This will help you understand how those third-parties use your personal data, as we do not have any control over those other websites, nor do we endorse the products or services offered by any such organisation.

  • The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

“Special categories” of particularly sensitive personal information require higher levels of protection. We will only collect, store or use this type of personal information for the services we provide, for the purposes that we have informed you of and where you have provided explicit consent for us to do so.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, last name, title and date of birth.
  • Contact Data includes home address, email address and telephone numbers.
  • Profile Data includes your username and password used on our website or App, details about your postcode/region, preferences and interests, feedback and survey responses, including information provided by you when you upload a review.
  • Technical Data includes your internet address (IP address), your login data and details of the computers and mobile phones you use to access our website.
  • Usage Data includes information about how you use our website and our services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and how you prefer to receive that information.

If you fail to provide personal data

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 data when requested, we may not be able to provide you with help and assistance. Should this situation happen, we will tell you.

Children and minors

We are aware that due to the nature of the service that we provide, those between the ages of 14 and 18 may use our services. Individuals under the age of 13 are expressly prohibited from using the UniCompare Website and App, unless parental consent is provided and we are notified.

  • How is your personal data collected?

We use different methods to collect data from and about you.  To help make it easier for you to understand what data we collect and how we collect it, we have set out some examples in the table below:

Method of collecting data: Examples of how we collect data this way: What data do we collect this way:
Direct interactions:

When you:

ü fill in forms,

ü contact us by post,

ü contact us by phone,

ü contact us by email, or

ü have contact with us in person,

we collect personal data about you.

You provide us with personal data when you:

Ø  create an account on our website or our App;

Ø  link your UniCompare account to your Social Network account;

Ø  request marketing to be sent to you;

Ø  enter a competition, quiz, promotion or survey;

Ø  provide feedback; or

Ø  upload a review.

Ø  Identity Data

Ø  Contact Data

Ø  Technical Data

Ø  Profile Data

Ø  Usage Data

Ø  Marketing and Communications Data

 

 

Method of collecting data: Examples of how we collect data this way: What data do we collect this way:
Use of our website/App:

As you use our website/App, we may automatically collect data about your computer / mobile phone equipment and how you use and view our website and/or

 

 

We collect this personal data this way by using:

Ø  Cookies;

Ø  server logs; and

Ø  other similar technologies.

Please see our cookie policy for further details.

Ø  Technical Data

Ø  Profile Data

Ø  Usage Data

 

  • How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to provide you with access to advice and support (i.e. we have a contract with you).
  • Where it is necessary for our legitimate interests (or those of a third party) and your personal rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Where you have provided your explicit consent to us. For example, you may have provided your consent to us contacting you for marketing purposes by e-mail, fax, phone or mail, according to your preferences. We also rely on consent when you link your UniCompare account to your Social Network Account. You have the right to withdraw consent to marketing at any time by contacting our Data Privacy Manager or clicking “unsubscribe” on any marketing emails or texts that you may receive from us, or by clicking on the “unsubscribe” box on our website or App.
  • Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

We have set out below, in a table format, a description of all the ways we plan to use your personal data and the legal reasons why we use your personal data in this way.

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact our Data Privacy Manager if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new user of UniCompare.com. (a) Identity Data

(b) Contact Data

(c) Profile Data

(d) Marketing and Communications Data

 

(a) Performance of a contract with you

(b) To develop our products and services and to grow our business

(c) To provide you with promotional information about third parties which we think you might find interesting

(d) Your consent

 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To manage our relationship with you which will include:

ü  Telling you about changes to our terms or privacy policy

ü  Inviting you to leave a review or take a survey

ü  Inviting you to take a quiz

(a) Identity Data

(b) Contact Data

(c) Profile Data

(d) Usage Data

(e) Marketing and Communications Data

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(d) Necessary for our legitimate interests (to keep our records updated and to study how clients use our services)

 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To administer and protect our business and our website (including making sure our IT systems work properly). (a) Identity Data

(b) Contact Data

(d) Technical Data

(e) Profile Data

(f) Usage Data

(g) Marketing and Communications Data

(a) Necessary to comply with a legal obligation

(b) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).

To deliver relevant website/App content and adverts to you. (a) Identity Data

(b) Contact Data

(c) Technical Data

(d) Profile Data

(e) Usage Data

(f) Marketing and Communications Data

(a) Necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy) and those of trusted third parties.

(b) Your consent.

 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To use data analytics to improve our website/app and the services we offer. (a) Technical Data

(b) Profile Data

(c) Usage Data

(a) Necessary for our legitimate interests (to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to you about services that may be of interest to you. (a) Identity Data

(b) Contact Data

(d) Technical Data

(e) Profile Data

(f) Usage Data

(g) Marketing & Communications Data

(a) Necessary for our legitimate interests (to develop our products/services and grow our business) and those our trusted third party partners.

(b) Your consent.

 

Marketing

We want to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity Data, Contact Data, Technical Data, Profile Data and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services may be relevant for you.

You will receive marketing communications from us if you have:

  • registered on our website or App; or
  • requested information from us; or
  • have signed up to receive our services; or
  • if you provided us with your details when you entered a competition, quiz or registered for a promotion; or
  • you have provided us with your consent to receiving marketing communications from us

and in each case, you have not opted out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing messages at any time by contacting our Data Privacy Manager at any time] or by unsubscribing from any marketing emails or texts that you may receive.

Cookies

We use cookies on our website.  A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical purposes and the data is removed from our system.

Overall, cookies help us to provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data that you choose to share with us.

You can choose to accept or decline cookies. If you decline cookies it may prevent you from taking full advantage of the website.

Change of purpose

We will only use your 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. Please contact our Data Privacy Manager if you want further information about this.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with this privacy notice, where this is required or permitted by law.

  • WHO WE SHARE YOUR PERSONAL DATA WITH

We may have to share your personal data with External Third Parties as set out in the Glossary.

In addition, we will share your information with trusted third parties where you have provided your explicit consent for us to do so. We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

Each time that we ask for consent to share your Personal Data, we will provide you with a link to that organisation’s Privacy Notice/Privacy Policy as that organisation will be a Controller of your Personal Data in its own right. Please ensure that you read and understand that organisation’s Privacy Notice/Privacy Policy, so that you know how your Personal Data will be used, before you provide your consent.

The third parties that we currently share your data with, where you have provided your consent, include the following:

Milkround Limited:

Milkround Limited (‘Milkround‘) pays us to share certain Personal Data with them. The data that Uni may share with Milkround is limited to the following:

  • Your name
  • Your e-mail address
  • The University you attend (if any)
  • The year that you will graduate or have graduated (if applicable)

 

  • The course subject area that you are studying, or intend to study.

Milkround will use the above data for the following purposes:

Milkround will be the Controller of any of the Personal Data that it receives from us and is responsible for ensuring that it complies with law relating to your Personal Data. Please ensure that you read Milkround’s privacy notice before you agree to us passing your personal data on to Milkround. Milkround is not allowed to share your data with anybody else.

Universities

We may also pass on [                                  ] details to specific universities, where you have provided your consent for us to do so. The purpose of providing this personal data, is so that the universities may get in contact with you.

Agencies

We may pass on your personal data to agencies, which may benefit your future educational prospects, where you have provided your consent for us to do so. For example we have links with an agency based in Germany which will assist you with applications to study at German universities. We will provide you with more specific information about the identity and purpose of any such agencies and their Privacy Notices if and when we seek your consent.

 

  • International transfers OF YOUR PERSONAL DATA

We do not transfer your personal data outside the European Economic Area (EEA).

  • HOW WE KEEP YOUR PERSONAL Data sAFE

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those of our employees who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  • HOW LONG WE KEEP YOUR PERSONAL DATA FOR

How long will you use my personal data for?

We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting our Data Privacy Manager.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes or for reporting information to our funders in which case we may use this information indefinitely without further notice to you.

  • Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact our Data Privacy Manager whose contact details are set out above.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure 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 you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  • Glossary
Lawful Basis    
  Legitimate Interest: means the interest of University Compare in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).  You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our Data Privacy Manager.
  Performance of Contract: means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  Comply with a legal or regulatory obligation: means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that University Compare is subject to.
  Consent: means that you have given your positive agreement to us to process your data in the way that we have said we will, on the basis of genuine choice and understanding.
Third parties  
  External third parties: ü  Service providers acting as processors based in the UK who provide IT and system administration services;

ü  Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services;

ü  Marketing and market research agencies; and

ü  Other organisations that we may transfer our business to or merge with from time to time.

Your legal rights

 

You have the right to:
  (1) Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  (2) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  (3) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  (4) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  (5) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  (6) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  (7) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.