Privacy Notice
DATE OF ISSUE: September 2024
RETURN & CONNECT – INTO UNIVERSITY PARTNERSHIPS GROUP
Privacy Notice
INTO University Partnerships Limited, its subsidiaries and affiliates (together “INTO”, individually an “INTO Entity”) is committed to protecting your privacy. This notice will help you understand how we look after your personal information and how we make sure that we meet our obligations to you under data protection law (referred to in this notice as the "Data Protection Laws").
If you have any questions about this notice or how your personal information is processed by us, please contact INTO’s Data Protection Officer (DPO) by email at: privacy@intoglobal.com or as specified in the “How To Contact Us” section below.
Introduction
In this privacy notice, the terms "we", "our", and "us" refer to INTO University Partnerships Limited and IUP2 LLP, both of One Gloucester Place, Brighton BN1 4AA, UK (registered with the UK’s data protection regulator, reference numbers: Z3504921 and ZA032598 respectively).
We are a controller of your information which means that we are responsible for looking after it. We will use your personal information fairly, lawfully and in a transparent manner, and in accordance with the Data Protection Laws.
We give you the power to share in enhanced career opportunities as part of our mission to help you bridge the gap between international education and employment worldwide, connecting you with employer and alumni networks, for in-market work experience and post-study work placements. This notice describes what information we collect from you and how it is used and shared.
We reserve the right to update this privacy notice at any time by changing it as it applies to your use of our services.
1. Important information
Purpose of this privacy notice - your trust is very important, and this notice aims to give you information on how we collect and process your personal information, including any information you may provide when you enter your details onto and use our Return & Connect platform.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide you on specific occasions when we collect or process your personal information, so you know how and why we are using your information. This privacy notice supplements our other notices and is not intended to override them.
It is important that your personal information is accurate and up to date. Please contact us if any of your personal information changes during your relationship with us or email our DPO at: privacy@intoglobal.com if you have any questions about this privacy notice.
What do the key terms mean?
“Account” means the account that is created when a student or graduate signs up to use this site and provides the requested personal information for this purpose.
"Personal data" means any personal information which we hold about you from which you can be identified. It may include contact details, identification numbers, other personal information, photographs, expressions of opinion about you or indications as to our intentions about you.
"Processing" means doing anything with personal data, such as collecting, recording, organising, structuring, storing, adapting or altering, retrieving, accessing, consulting, disclosing, disseminating, aligning or combining, restricting, erasing or destroying or using data in any way.
Not covered in this privacy notice - our services may include links to websites run by other companies; those companies have their own privacy notices and cookies policies, so remember that the information you give them will follow their rules and not ours. Make sure to check their privacy notices so you know how they will use your personal information.
Individuals based in Australia, China, the European Union and in the US – please see the supplementary information that we provide for you in our other privacy notices.
2. The information we collect about you
Depending on which services you use, we collect different kinds of information from or about you. We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:
- Identity Information includes first name, last name, username or similar identifier, date of birth, gender, photograph, and video recorded image.
- Contact Information includes home address, mailing address, email address and telephone numbers.
- Education Information includes your educational history, qualifications, skills, and certifications.
- Technical Information includes registration and login information for your account, internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our services.
- Profile Information includes your username and password, home country (collected during account registration), resumes and work experience, your career interests, internship and job searches, services selected by you, community group interactions, communications with us, your feedback and survey responses, and details of your home country to help us determine which services are available to you.
- Usage Information includes information about how you use our websites and services.
- Marketing and Communications Information includes your preferences in receiving marketing from us and related third parties, and your communication preferences.
3. How is your personal information collected?
We use different methods to collect information from and about you, including through:
- Information you provide - you may give us your Identity, Contact, Education and Profile information when signing up to create an account on our website, or by corresponding with us online or by email. This includes personal information you provide when you:
o apply for an internship or other work experience opportunity;
o use a recruitment-related service;
o take part in a survey;
o share information about employment options you pursued after studying; or
o give us some feedback or contact us.
- Information we collect automatically - as you interact with our websites, we may automatically collect Technical Information about your equipment, browsing actions and patterns. We collect this personal information by using cookies and other similar technologies to understand how you are using this website in order to give you a better experience. If you are signed in, your account lets you personalise your experience.
- Third parties or publicly available sources. We may receive personal information about you from time to time from third parties including employers who you have engaged with about employment opportunities via this website. We may also collect additional personal information during job-related activities throughout any internship placements that you may accept.
4. Basis for using your personal information
We are passionate about ensuring the success and transforming the lives of international students and will use your personal information to help ensure that we provide, improve and develop our services for you.
We need to have a valid reason to use your personal information. This is called the "lawful basis for processing". Sometimes we might ask for your consent to do something, for example, when you subscribe to an email or sign up to receiving a newsletter. Other times, when you would reasonably expect us to use your personal information, we do not need to ask for your permission but only when the data protection laws say it is fine for us to use it, and it fits with the Rights that you have.
5. How do we use your personal information?
We use the information we hold to deliver and improve the services offered to you. We will only contact you when necessary or when you have given us permission - examples of how we use your personal information, include the following:
- to update you on any changes to Return & Connect policies, practices and Terms of Use,
- to register you as a new user on our Return & Connect website;
- to check with you about any services or activities you have signed up for,
- to answer you when you contact us, or to respond to a comment or complaint,
- to invite you to take part in surveys about INTO and our Return & Connect services, which are always voluntary for marketing purposes,
- to provide you with advice about internship and employment opportunities, or respond to your questions about such opportunities, for the purpose of our legitimate interests,
- to enable you to participate in any surveys or any other promotions we may be running where such processing is necessary for the purposes of our legitimate interests;
- to administer and protect our business and our websites where such processing is necessary for the purposes of our legitimate interests;
- to deal with any requests from you regarding your Rights under this notice to enable us to comply with a legal obligation;
- to deal with any requests from third parties for disclosure of your personal information where such disclosure is to comply with a legal or regulatory obligation.
Automated decision making
Assumptions are made about your interests depending on the information you have given us about yourself - for example, if you applied for an advertised internship placement, we assume you may be interested in other internship opportunities.
We also assume you speak certain languages based on your home country. If you require any further information regarding any automated decision making, please contact our DPO at: privacy@intoglobal.com
Marketing
We aim to provide you with choices regarding how we contact you, around the marketing and advertising of our services.
Promotional offers from us - we may use your Identity, Contact, and Profile Information to form a view on what we think may be of interest to you: for example, in respect of a new promotion that we are running. We conduct surveys and research and will analyse the information that we have collected to evaluate and improve existing products services and develop new features.
You may receive marketing communications from us if you have signed up to create an account on this website, have requested information from us or sent an enquiry to us and, in each case, you have not opted out of receiving communications from us.
Cookies
We use cookies and similar technologies to provide and support our services as detailed here:
|
Provider |
Service Type |
Usage |
|
Return & Connect |
Session; Authentication; User Preferences Cookies |
Authenticate & stores the user's personal preferences such as language, interface, and other settings. |
|
|
Tracking Cookies |
Track user behavior and collect analytical data. |
|
Youtube |
Tracking & Functionality Cookies |
Track user behavior and collect analytical data & Show video on the system |
|
Microsoft Booking |
Functionality Cookies |
Use for booking service & calendar |
|
OpenAI |
Functionality Cookies |
Use for generating text |
6. Disclosures of your personal information
We will never sell your personal information but may share it with selected external third parties, including:
other companies in the INTO Group as required,
- the Universities with whom you were studying when you signed up to create your Return & Connect account on this website,
- employers offering internship or employment opportunities that you are interested in,
- third party suppliers, service providers and sub-contractors who perform any services for us: for example, technology companies whose systems we use; companies who provide services to carry out marketing campaigns on our behalf; or companies who analyse data on how people use our digital services so we can improve them,
- analytics and search engine providers that assist us with the improvement and optimisation of our website, and
- third parties to whom we may choose to sell, transfer or merge part of our business to or with. Alternatively, we may seek to acquire other businesses or merge with them.
We make sure that your personal information is looked after as if we were handling it directly. We carefully select these companies, only share with them what they need to complete specific purposes and make sure they keep your information secure.
7. International transfers of your personal information
INTO is a global company and it has affiliates, service providers and relationships with third parties all over the world. This means that we may transfer your personal information to countries that may not have the same level of data protection laws as your local country. In these cases, we take steps to ensure that your personal information receives an adequate level of protection in line with applicable legal requirements.
Please contact us if you want further information on the safeguards we rely on for such transfers as specified in the “How To Contact Us” section below.
8. Information security
We place great importance on the steps we take to protect your personal information from unauthorised access and against unlawful processing, accidental loss, alteration, disclosure, destruction and damage.
We have in place procedures and technologies to maintain the security of personal data from the point of collection to the point of destruction. We will only transfer personal data to third parties if they agree to comply with those procedures and policies, or if they put in place adequate measures themselves.
The confidentiality of any password that enables you to access, for example, your Return & Connect account, is your responsibility, whether we have given you the password or you have chosen it yourself. We ask you to please not share your password with anyone. We will not be liable for any unauthorised transactions entered into using your username, personal information and/or password.
9. Information retention
When you give us your personal information, we will always comply to these principles:
· we only hold your information for as long as it is needed to carry out the activities we told you about or if we have a valid reason to keep it,
· we think about what type of information it is, the amount collected, how sensitive it might be and any legal requirements,
· we may close your Return & Connect account if you have not used in the last two (2) years; we will send you an email to tell you that we plan to do this before we delete anything, and you will have 30 days to log into your account to keep it active.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for statistical purposes, in which case we may use this information indefinitely without further notice to you. We may also retain a record of your stated objection to the processing of your personal data, including in respect of an objection to receiving communications, for the sole purpose of ensuring that we can continue to respect your wishes to not contact you further, during the term of your objection.
10. Your legal rights
You have the right to make decisions on the processing of your personal information. In addition to your rights set out in section 10. “Your legal rights” of our Privacy Notice, you may also ask for an explanation of our personal information processing rules.
11. How to contact us
We work to high standards when processing your personal information. You can contact us with any questions about this privacy notice, or our privacy practices more generally, by email to INTO’s Data Protection Officer at: privacy@intoglobal.com
Thank you for taking the time to read our privacy notice.