This notice applies to personal information provided by our contacts, users and customers whose data we process. In this notice “you” refers to any individual whose personal data we hold or process. This notice is governed by the EU General Data Protection Regulation (the “GDPR”).
Basis on which we process personal data
Personal data we hold about you will be processed either because:
the processing is necessary in pursuit of a “legitimate interest”, a legitimate interest in this context means a valid interest we have or a third party has in processing your personal data which is not overridden by your interests in data privacy and security;
you have consented to the processing for the specific purposes described in this notice; and/or
the processing is necessary in order for us to comply with our obligations under a contract between you and us.
Personal data we collect and the basis on which we process that data
We may collect and process the following personal information or data (information that can be uniquely identified with you) about you:
Certain information required to register with our Website or to access other services provided by us, including your name, address and date of birth. We process this information when we communicate with you to obtain necessary information in order to provide our services on the basis of i) our legitimate interest in providing our services to customers and the users of our services, and ii) on the basis of the performance of our contract with you.
Your e-mail address and a password.We process this information when we communicate with you or provide services our services on the basis of i) our legitimate interest in providing our services to customers and the users of our services, and ii) on the basis of the performance of our contract with you.
Information provided in connection with bookings you make through the Website,We process this information when we provide our services (to run our business and provide you with services requested) on the basis of i) our legitimate interest in providing our services to customers and the users of our services, and ii) on the basis of the performance of our contract with you.
A record of any correspondence between you and us.We process this information when we monitor our relationship with you and communicate with you on the basis of i) our legitimate interest in providing our services to customers and the users of our services, and ii) on the basis of the performance of our contract with you.
Your replies to any surveys or questionnaires that we may use for research purposes. We process this information when we monitor our relationship with you and communicate with you about our services (including to keep our Website updated and relevant, to develop our business and inform our marketing strategy) on the basis of i) our legitimate interest in providing our services to customers and the users of our services, and ii) on the basis of the performance of our contract with you.
Details of accounting or financial transactions including transactions carried out through our Website or otherwise (this may include information such as your credit card, debit card or bank account details.We process this information in order to provide our services on the basis of i) our legitimate interest in providing our services to customers and the users of our services, and ii) on the basis of the performance of our contract with you.
Details of your visits to our Website and the resources that you access. We process this information when we monitor our relationship with you and communicate with you about our services on the basis of our legitimate interest in providing our services to customers and the users of our services.
Information we may require from you when you report a problem with our Website.We process this information when we monitor our relationship with you and communicate with you (including to provide administration and IT services) on the basis of i) our legitimate interest in providing our services to customers and the users of our services, and ii) on the basis of the performance of our contract with you.
We only collect such information when you choose to supply it to us. You do not have to supply any personal information to us but you may not be able to register to use our services or fully take advantage of all the services we offer without doing so.
Information is also gathered without you actively providing it, through the use of various technologies and methods such as Internet Protocol (IP) addresses and cookies. These methods do not collect or store personal information.
An IP address is a number assigned to your computer by your Internet Service Provider (ISP), so you can access the Internet. It is generally considered to be non-personally identifiable information, because in most cases an IP address can only be traced back to your ISP or the large company or organisation that provides your internet access (such as your employer if you are at work).
We use your IP address to diagnose problems with our server, report aggregate information, and determine the fastest route for your computer to use in connecting to our site, and to administer and improve the site.
Use and Disclosure
We may use this information to:
ensure that the content of our Website is presented in the most effective manner for you and for your computer and customise the Website to your preferences;
assist in making general improvements to our Website;
carry out and administer any obligations arising from any agreements entered into between you and us;
allow you to participate in features of our Website and other services;
contact you and notify you about changes to our Website or the services we offer (except where you have asked us not to do this);
collect payments from you;
analyse how users are making use of our Website and for internal marketing and research purposes.
We do not disclose any information you provide via the Website to any third parties except:
where we work with third party providers, for instance to carry out identity checks (our current third party provider is Shufti Pro);
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);
to protect the rights, property, or safety of Scholar Hub, our Website’s users, or any other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Other than as set out above, we shall not disclose any of your personal information unless you give us permission to do so.
A cookie is a piece of data stored locally on your computer and contains information about your activities on the Internet. The information in a cookie does not contain any personally identifiable information you submit to our site.
Once you close your browser, our access to the cookie terminates. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. To change your browse settings you should go to your advanced preferences.
If you choose not to accept the cookies, this will not affect your access to the majority of information available on our Website. However, you will not be able to make full use of our online services.
We use log files generated by our web servers to analyse site usage and statistics but the files do not identify any personal information. Log file analysis helps us to understand usage patterns on our website and to make improvements to our service.
Access to and correction of personal information
With respect to your personal data, you have the right to:
request that your personal data will not be processed;
ask for a copy of any personal data that we have about you;
request a correction of any errors in or update of the personal data that we have about you;
request that your personal data will not be used to contact you for direct marketing purposes;
request that your personal data will not be used for profiling purposes;
request that your personal data will not be used to contact you at all;
request that your personal data be transferred or exported to another organisation, or deleted from our records; or
at any time, withdraw any permission you have given us to process your personal data
All requests or notifications in respect of your above rights may be sent to us in writing at the contact details listed below. We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).
If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office (ICO) and/or the person responsible for managing data protection at Scholar Hub.
If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.
We will take all reasonable steps in accordance with our legal obligations to update or correct personally identifiable information in our possession that you submit via this Website.
We take all appropriate steps to protect your personally identifiable information as you transmit your information from your computer to our Website and to protect such information for loss, misuse, and unauthorised access, disclosure, alteration, or destruction. We use leading technologies and encryption software to safeguard your data, and operate strict security standards to prevent any unauthorised access to it.
Where you use passwords, usernames, or other special access features on this site, you also have a responsibility to take reasonable steps to safeguard them.
Our current data retention policy is to delete or destroy (to the extent we are able to) personal data after the following periods:
Records relating to a contract with us - 7 years from either the end of the contract or the date you last used our services or placed an order with us, being the length of time following a breach of contract in which a contract party is entitled to make a legal claim.
Marketing records - 3 years from the last date on which you have interacted with us.
For any category of personal data not specifically defined in this notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data. The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).
We cannot be responsible for the privacy policies and practices of sites that are not operated by us, even if you access them via the Website that is operated by us. We recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
In addition, if you came to this Website via a third party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
Transferring your information outside of Europe
We will not transfer your personal data in a systematic way outside of the European Economic Area (“EEA”) but there may be circumstances in which certain personal information is transferred outside of the EEA, in particular:
If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with our services;
We may communicate with individuals or organisations outside of the services in providing our services, those communications may include personal information (such as contact information) for example you may be outside of the EEA when we communicate with you;
From time to time your information may be stored in devices which are used by our staff outside of the EEA (but staff will be subject to our cyber-security policies);
From time to time our servers may be located in a country outside of the EU, or one of our service providers may be located outside of the EU>
If we transfer your information outside of the EEA, and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice.
If you use our Website while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.
If at any time you would like to contact us with your views about our privacy practices, or with any enquiry relating to your personal information, you can do so by way of our contact page, or by using one of the using one of the following contact methods:
The Educator c/o Scholar Hub Limited, Kemp House, City Road, London, England, EC1V 2NX;