We respect the privacy of every person (“you”,) who registers with any of the services run by our company, Oxbridge Interviews Ltd, (“OxFizz”, “Oxbridge Interviews” and “Oxbridge International Summer School”) and we are committed to ensuring a safe online experience.
1. PURPOSE OF THIS PRIVACY NOTICE
This privacy notice explains our approach to any personal information that you might supply to us (or that might be collected from you) in connection with your use of our services. It will explain our legal basis for processing that information and your rights around this. This document will show you how you can verify which of your personal information is collected by us and how you can request that we delete, update or transfer it. This privacy notice is intended to assist you in making informed decisions when using our services. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Terms and Conditions.
2. WHO ARE WE AND WHAT DO WE DO?
Our services are operated by Oxbridge Interviews Ltd, a registered company in England and Wales no. 06653969. Our principal address is Edspace, Hackney Community College, Falkirk Street, London, N1 6HQ.
Our principle activities our providing educational services to consumers. Under applicable European data privacy laws including, but not limited to, laws implementing the General Data Protection Regulation 2016/679 (GDPR) and the UK Data Protection Act 2018 (together the “Data Privacy Laws”), we are a data controller.
3. HOW TO CONTACT US:
If you have any questions about this privacy notice or want to exercise your rights, please contact us by:
- sending an email to firstname.lastname@example.org.
4. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE COLLECT IT?
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). We may collect, use, store and transfer different kinds of personal data about you, which we have set out below.
When you visit our website, there is some information which you give us, and some which we collect on you:
Information you give us: You may give us information about you by filling in forms on our website or through our partner sites linked to from our website, or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, complete a course and when you report a problem with our site. The information you give us may include:
- Contact information: such as your name, address, e-mail address and phone number;
- Payment data: such as financial and credit card information;
- Training and education information: such as personal description, personal statement and school information;
- Health information: medical and dietary information.
Information we collect about you:
- Automatically collected information. With regard to each of your visits to our site we may automatically collect the following information: – technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; – information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our contact number. We collect this data by using cookies and other similar technologies. Please see section 5 below for further details.
- Video recordings. As part of the provision of our online services, we may make video recordings of sessions with you that we will record using videocommunications software on programmes such as, but not exclusively, Zoom.
Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and email service providers) and may receive information about you from them.
Information about dependents/contacts. If you provide us with personal data about members of your family and/or dependents or beneficiaries (e.g., for emergency contact or benefits administration purposes), it is your responsibility to inform them of their rights with respect to such information. You also are responsible for obtaining the explicit consent of these individuals (unless you can provide such consent on their behalf) to the processing (including transfer) of that personal data for the purposes set out in this Notice.
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 perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel or reschedule a service you have with us but we will notify you if this is the case at the time.
Cookies are small files saved to the user’s computer’s hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server, to function properly and to provide the users with a tailored experience within this website.
Users are advised that if they wish to deny the use and saving of cookies from this website on to their computer’s hard drive they should take necessary steps within their web browser’s security settings to block all cookies from this website and its external serving vendors.
Other cookies may be stored to your computer’s hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.
6. DISCLOSURE OF YOUR INFORMATION
We may share your information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Oxbridge Interviews Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data, including any video recordings, in order to comply with any legal obligation, or otherwise to a governmental authority as required or permitted by law.
- In order to enforce or apply our Terms and Conditions and other agreements; or
- To protect the rights, property, or safety of Oxbridge Interviews Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
7. WHERE WE STORE YOUR PERSONAL DATA
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) that does not provide a level of data protection equivalent to that set forth by the law in your home country. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.
We will take appropriate steps to make sure that such recipients act in accordance with applicable law. To the extent that we transfer your personal data to recipients which are located outside the European Union or the EEA, we will provide an adequate level of protection of your personal data, including appropriate technical and organizational security measures and through the implementation of appropriate contractual measures to secure such transfer, in compliance with applicable law.
8. HOW DO WE USE YOUR PERSONAL INFORMATION?
We collect and use your personal information to operate the service efficiently and to deliver you the very best service, as well as for purposes required by applicable law, regulations, collective agreements or other contracts and to enable us to fulfil Oxbridge Interviews’ purposes and legal obligations. In particular, we may use your personal information for the following purposes:
- We shall use your personal information to provide the service to you. This will include using and analysing your personal information to arrange services, match you with the right tutors, interviewers or students, and train our staff to deliver services effectively.
- We may use your personal information to: develop and improve our service; to send you administrative e-mails about the service; and to contact you to answer any queries you may have.
- We may use your personal information to exercise our rights under local laws and comply with applicable legal and regulatory requests and obligations (including investigations in relation to the same), or to establish or defend legal claims and allegations.
- These requests and obligations include, but are not limited to, the recording and processing of video recordings for safeguarding purposes. Such recordings will initially be stored on the Cloud or equivalent and on the video communication software programmes’ servers. Upon completion of each event day, the recordings will be downloaded and stored on our secure server and will only be accessed in the event of a safeguarding allegation.
- Where you consent (by opting in on sign up forms), we may use your personal information to contact you by e-mail about our products and/or services that we think will be of interest to you. We will not use your personal data for marketing purposes unless you expressly consent to us doing so.
What is our legal basis?
- It is necessary for us to use your personal information to provide the service to you and perform our obligations in accordance with any contract that we may have with you, including our Terms and Conditions.
- It is also in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can to you. Our legitimate interests or those of a third party include our requirements to use your personal data: in litigation or for other legal purposes involving Oxbridge Interviews and/or any affiliate of Oxbridge Interviews; to keep our website updated and relevant; to keep our records updated and to study how customers use our services; for running our charity, provision of administration and IT services, network security; to prevent fraud and in the context of a reorganisation or restructuring exercise. and may also include the need to transfer your personal data to third countries without adequate data protection laws. In this event, we will take reasonable steps to protect your personal data as required by the Data Privacy Laws.
- Where we process your sensitive personal data, we shall be relying on your consent to do so. We may collect health-related data that is specific to the provision of our educational services.
- It is also necessary for us to use your personal information to comply with legal obligations to which we are subject. We hold your data to comply with other statutory obligations relating to Child Protection.
You are required to be at least 15 years old to use our services so we do not intentionally collect personal information from anyone under 15, and no one under 15 should attempt to submit any personal information to us. Should we discover that any such personal information has been delivered to any of the sites, we will remove that personal information as soon as possible.
10. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
We will only keep your personal information for as long as necessary to fulfil the purpose it was collected for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. In particular we keep your personal information as long as we need to fully deliver the service and may keep it for longer where we have a legal basis to do so. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
In general, we will keep personal information for up to three years following from the provision of the service, to comply with Child Protection legislation. We will delete sensitive data as soon as the service has been delivered.
11. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION
We are committed to keeping the personal information you provide us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
- unauthorised access;
- improper use or disclosure;
- unauthorised modification; and
- unlawful destruction or accidental loss
All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the security and confidentiality of the personal information of all users of the Service, and to treat it in accordance with the law. We select our data processing partners based on their security and approach to data privacy.
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions.
12. HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS:
Where use of your personal information by us requires your consent, it will be obtained via one or more opt-in box(es) presented to you on sign up forms. These opt-in boxes clearly and specifically set out the type of processing for which we are seeking consent. We do not assume consent by your reading this Notice or by your signing up to our service. You may withdraw your consent at any time by emailing us at email@example.com.
You have the right to ask us not to process your personal data for marketing purposes. We will seek your consent in order to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
You have the following rights in relation to the personal information we hold about you:
- Your right of access: If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
- Your right to rectification: If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
- Your right to erasure: You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
- Your right to restrict processing: You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. You will need to specify a particular reason, as required by the Data Privacy Laws, for requesting the restriction. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
- Your right to data portability: With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere.
- Your right to object: You can ask us to stop processing your personal information, and we will do so, if we’re:
- relying on our own or someone else’s legitimate interests to process your personal information unless we can demonstrate compelling legal grounds for the processing;
- processing your personal information for direct marketing; or
- processing your personal information for research unless such processing is necessary for the performance of a task carried out in the public interest
- Your rights in relation to automated decision-making and profiling: You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, and it produces a legal effect or similarly significantly affects you, unless such profiling in necessary for entering into, or the performance of, a contract between you and us
- Your right to withdraw consent: If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
- Your right to lodge a complaint with the supervisory authority: If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
To exercise your legal rights, the best way to notify us is by using the contact details provided in section 3 of this Notice.
13. CHANGE TO THIS PRIVACY NOTICE
We may make changes to this privacy notice from time to time. To ensure that you are always aware of how we use your personal information we will update this privacy notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We may notify you by e-mail of any significant changes. However, we encourage you to review this privacy notice periodically to be informed of how we use your personal information.