Privacy Notice

This Privacy policy, subject to our terms and conditions, sets out how we, Keystone Abroad owned by Studee Ltd, collect, store, source, retain, disclose and use information about you when you use or interact with our websites or how and why we process your personal data. If we wish to use your personal data for a new purpose, not covered by our Privacy Notice(s), we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

This Privacy policy is effective from 1st June 2024.

Our details

Studee Ltd (company registration number: 06842641 of 15 The Woolmarket, Cirencester, Gloucestershire, GL7 2PR, England. You can contact the Data Protection Officer by writing to this address or sending an email to abroad@keystoneacademy.co.

If you have any questions about this Privacy policy, please contact the data protection officer.

Who we are

Studee Ltd helps international students find and apply online to universities abroad, and helps universities to find the best students to enroll at their institutions.

Studee Ltd is the data controller with regards to the processing of your Personal Data (as defined below), unless specifically stated otherwise.

What Information we collect and process

In order to provide you with services and communications suited to your needs, we require information about you.

We collect and use information from our website visitors via forms and through direct engagement upon request such as Student Fairs . This information is processed through our business systems in order to help us generate useful business analytics that enable us to facilitate our customer requirements. We also carry out research where you have given consent to participate in order that we can improve our services and identify student requirements.

We use platforms such as Slack, ClickUp, BoltBot, Element 451, Daktela, GMail, GDrive, Google Workspace and chat functions, Zoom, Microsoft Outlook & TEAMS.

Web server log information

Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, Names, telephone contact details, company email address, information to help us find suitable programs for you, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.

Use of website server log information for IT security purposes

We collect and store server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by detecting unusual or suspicious activity.

We also use website server log information and third party analytics software to analyse website use to improve our website.

We use the information collected by our website server logs, along with third party analytics software, including but not limited to Google Analytics and Domo to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit, the operating system and browser used, the number of course enquiries made on our websites and the number of links clicked on.

We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based on what users are engaging most with and the duration of time spent on particular pages on our website to provide a better user experience. To prevent Google Analytics from using your information for analytics, you can install the Good Analytics opt-out browser add-on Google Analytics Opt-out Browser Add-on Download Page We keep analytics data from your visits to enable us to provide a personalised service, understand trends, and user behaviour, to improve our services.

Cookies and similar technologies

Cookies are data files which are sent from a website to a browser to record and track information about users for various purposes. A cookie banner is displayed giving you clear information about the purpose, storage and access to the cookie and that you give consent in line with Article 4(11) of the UK General Data Protection Regulations, before it captures your data.

We use cookies and similar technologies on our website, including essential, functional, analytical and targeting cookies and web beacons. For further information on how we use cookies, please see our cookies policy. You can reject some or all of the cookies we use on or via our website by changing your browser settings, but doing so can impair your ability to use our website. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

User session recording

We may use a third-party user session recording service, to help us understand how our users interact with our website and to enhance user experience. This service may record mouse clicks, mouse movements, scrolling activity, and any text you type in our website. It does collect personally identifiable information (PII) that you do not voluntarily enter on our website.

We use the information to identify preferences, diagnose technical problems, analyze trends and user behavior in order to offer our visitors a better user experience.

By using our website, you consent to the processing of the data collected by this service in the manner and for the purposes set out above.

Information we collect when you contact us

We collect and use information from individuals who contact us as detailed below:

Email

When you send an email to a @studee.com email address, we may collect your Name, email address, IP Address, location and any other information you provide in that email (such as your telephone number and the information contained in any signature block in your email).

Phone

When you contact us by phone, we collect your phone number and any information provided to us during your conversation with us. We may record phone calls for staff training, improvements to services or dealing with complaints. We retain biometric voice recordings for 3 months.

Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Information we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website.

Email communication

When you sign up for an email service promoted on our website or opt to receive news and advice in relation to studying abroad, by submitting your name and email address; we collect your name, email and any other details you provide. You can unsubscribe to this consent at any time by contacting abroad@keystoneacademy.co.

Using our online tools

When you interact with one of the tools on our website that helps you better understand which programs, universities, locations and/or subjects are most suited to your needs, aspirations and circumstances, we will collect any information that you provide to us, which may include but is not limited to; where you want to study, what you want to study, what funds you have available, your qualifications/exam results and which English Language Tests you have passed.

If you provide us with any information whilst using one of the tools on our website, before you provide us with your name and/or contact details, we may record those details anonymously and associate them with your browser and capture your IP address. If we have access to this information when you decide to give us your name and/or contact details we will associate the information you previously provided with your name and any contact details. This will prevent you having to enter your information for a second time.

Managing your profile

When you login to your account on our website and add or update any information within your profile, we will record the information you provide.

If you are logged in, we will record the information provided in the filters you use in order to present you with relevant programs.

Information we collect when you use our application service

If we are assisting you in completing an application form in the process of applying to a university then we may need to record all or some of the information you will be providing in your application. In addition, we may ask you for documents supporting your application, including but not limited to; biodata page passport, bank statements, affidavit of financial support, reference letters, sponsorship letters, government funding letters, statement of purpose, study permit / copy of visa, translations and payroll receipts. This information will be held securely in accordance with the UK's GDPR requirements, and will only be used in order to submit your application.

Information obtained from third parties

Application and enrolment support

In order to provide you with support when applying for a university and all the subsequent stages to enrolling, the university may provide us with information in relation to the status of your application, which we will be able to share with you.

If you ask us for information in relation to your submitted application, we may contact the university to get that information, which they will then provide to us. We will be able to share that information with you.

Other third party information

Other than the above, we generally do not receive information about you from third parties. However, in the event that we do, this will typically be your name and contact details, but could also include additional information about you that you have provided to the third party. No information about you will be passed to us by a third party without your expressed permission. All personal information is obtained from verified sources and will only be processed if a suitable legal basis has been established.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will permanently delete your information.

Disclosure and additional uses of your information

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below. Providing information to third parties such as Google Inc. Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: www.google.com/policies/privacy/partners/ You can opt out of Google Analytics by installing the browser plugin here: tools.google.com/dlpage/gaoptout Information collected by Google Analytics is stored outside the European Economic Area on Google's servers in the United States of America.

Transfers out with UK

We run our systems to make sure that your data is as safe as possible at all stages, both while it's processed, transferred and when it's stored. We will not transfer your data to a territory that has not been assessed as providing adequate protection for peoples rights and freedoms about their personal data.

Disclosure and use of your information for legal reasons

If we suspect that criminal or potential criminal conduct has occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that a fraud or a cybercrime has been committed or if we receive threats or malicious communications towards us or third parties. We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.

Legal basis for processing

Under Article 6 (1) (a) of the UK GDPR – In respect of personal data provided to us where you as the data subject have given consent to the processing,

Under Article 6 (1) (b) of the UK GDPR – processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract

Under Article 6 (1) (c) of the UK GDPR – processing is necessary for compliance with a legal obligation that applies to us

Under Article 6 (1) (f) of the UK GDPR – processing is necessary for the purposes of the legitimate interests pursued by us as Data Controller or by a third party

Under Article 8 (2) of the UK GDPR – We will obtain consent from the person who has parental responsibility, prior to obtaining personal information

Under Article 9 (2) (a) of the UK GDPR – the data subject has given explicit consent to the processing of special category personal data

Under Article 9 (2) (b) of the UK GDPR – processing is necessary for the purposes of carrying out the obligation of Studee Ltd as Data Controller in the field of employment and social security/protection law

Under Article 9 (2) (f) of the UK GDPR – processing is necessary for the purposes of establishing, exercising or defence of legal claims

Under Article 10 of the UK GDPR and Section 10(5) of the DPA 2018 – Where data relating to criminal convictions/offences is concerned

What information might be shared within the Group

We will keep your information within Studee Ltd and will only share it where you have requested it, required by law, or given your consent. We use Data Processors who are third parties that provide elements of services for us. We have a contract in place with our data processors and they will not share your personal information with any other organisation apart from us without a legal basis for doing so. We may also share your information across our commercial subsidiaries where this is necessary to provide you with the service you have requested:

ISAS Online Ltd

ISAS Ecuador

How long we retain your information

Retention periods

Server log information: we retain information on our server logs for up to 6 months in order to provide services to you. When you provide us with information in order to use our service, we retain that information for 6 years following the end of the financial year in which you place your order, in accordance with our legal obligation to keep records for tax purposes.

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form or by phone, we will retain your information in line with our retention policy and retention schedules. Email Newsletter: we retain the information you used to sign up for any one of our email newsletters for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;

sending an email to hello@studee.com asking that we stop sending you marketing communications or by including the words “OPT OUT”.

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy.

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, in line with Studee ltd Retention Policy and Retention Schedules, taking into account the following:

• The purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
• whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
• whether we have any legal basis to continue to process your information (such as your consent);
• how valuable your information is (both now and in the future);
• any relevant agreed industry practices on how long information should be retained;
• the levels of risk, cost and liability involved with us continuing to hold the information;
• how hard it is to ensure that the information can be kept up to date and accurate; and
• any relevant surrounding circumstances (such as the nature and status of our relationship with you).

How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

• only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
• verifying the identity of any individual who requests access to information prior to granting them access to information;

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to 15 The Woolmarket, Cirencester, Gloucestershire, United Kingdom, GL7 2PR, or sending an email to dpo@studee.com

• to request access to your information and information related to our use and processing of your information;
• to request the correction or deletion of your information;
• to request that we restrict our use of your information;
• to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to request to Port your personal information to transfer to another data controller (including a third party data controller); and to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) an
• to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
• The right to be informed about the personal data we process and to withdraw your consent to our use of your information any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
• The right not to be subject to a decision based solely on automated processing, including profiling.

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 23 and 34 of the General Data Protection Regulation, which is available here: gdpr-info.eu/ UK GDPR guidance and resources | ICO

Right to Lodge a complaint

If you are unhappy with the handling of your Data Subject Rights Request, you can request a review within 40 working days of receiving your initial response. If you wish to do this, you must do so in writing, identifying the decision that you wish to be reviewed or the aspect of the handling of your request that you are unhappy with. Please address your request for review to:

• The Data Protection Officer
• Email Address: abroad@keystoneacademy.co

If you are dissatisfied with the outcome of any review carried out by Studee Ltd in relation to information that we hold about you, in accordance with Article 77 of the General Data Protection Regulation, you have the right to lodge an appeal with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

For the purposes of the UK, the supervisory authority is the Information Commissioner's Office (ICO), the contact details of which are available here: ico.org.uk/global/contact-us/

For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO's website:

• ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and
• ico.org.uk/for-the-public/is-my-information-being-handled-correctly/

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identify you from such information, or if we have insufficient information about you, we will require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

Special Category personal information

‘Special Category personal information' is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person's sex life or sexual orientation.

Sensitive personal data

Criminal offence data

The UK GDPR gives extra protection to ‘personal data relating to criminal convictions and offences or related security measures. This covers information about offenders or suspected offenders in the context of criminal activity, allegations, investigations, and proceedings.

Vulnerable groups

We will hold our most precious data on the most vulnerable who hand over their data, often with little knowledge of their rights by protecting vulnerable groups such as:

• Children's personal information
• Individuals with learning individuals

We do not knowingly collect Personal Information on our Website directly from children under the age of 13. Parents and schools may use our Website to create accounts for children, such as registering them to get access to resource packs and careers advice. We encourage parents and teachers to spend time online with children and to monitor their online activities.

If you believe that a child has created an account on our Website, please contact us to have the account deactivated by sending us an email at hello@studee.com or by calling us at +44 0207 666 1222.

We may capture special category or sensitive personal information about you, we will use and process this personal information (such as your ethnicity and gender) for the purposes of University applications .

Changes to our privacy policy

We update and amend our Privacy policy from time to time, so you may wish to check it each time you submit personal information to us. If we change the way we use your personal information we will provide a prominent notice.

Minor changes to our Privacy policy

Where we make minor changes to our Privacy policy, we will update our Privacy policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy policy from its effective date onwards.

Major changes to our Privacy policy or the purposes for which we process your information

When we make major changes to our Privacy policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will update our privacy notices.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

Children

We provide particular protection when collecting and processing children's personal data and we will have a lawful basis for processing before we start and for children under age we will hold the appropriate consent from whoever holds parental responsibility for the child.

Copyright, credit and logo

The copyright in this Privacy policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved and unless stated Studee Ltd owns the copyright in all material on this site. Use of any of Studee Ltd logos without Studee Ltd consent infringes the copyright held in respect of the logos. No permission will be granted for the use of the logos nor will reproduction of the logos in any form be allowed unless Studee Ltd determines that:

• The material on which the logos is to be used
• Third parties are only using our logo to depict Studee Ltd and
• The use of the logos on such material have been expressly approved by Studee Ltdabroad@keystoneacademy.co