Last updated: February 2020
Effective as of 10th of February 2020
1. General Provisions
1.3 UniApply China Limited, a company registered in Hong Kong, has a position of a ‘Controller’ with regard to EU GDPR and we shall be responsible for, and be able to demonstrate compliance with, the principles relating to processing of personal data. We can be contacted by sending an e-mail to firstname.lastname@example.org.
2. Collection and Use of Personally Identifiable Information
2.1 We may obtain some of your personal Information in order to provide our Services. The Information we collect is necessary to provide our Services, and we shall not collect any Information which is not required by the nature of our Services. We may collect some of the following personal Information:
- First and last name
- E-mail address
- University Application Information
- IP address and server log files
- Other information which you choose to provide
2.2 In order to register to use our Platform you have to provide your first and last name. UniApply will only use this information to create an account for you and to address you whenever we contact you.
(B) E-mail Address
– When you contact us. We will collect your email address whenever you contact us through our email email@example.com. Whenever we collect your email address this way, we will only use it in order to respond to your enquiry.
– When you subscribe to the newsletter. We will collect your email address when you subscribe to receive more information about UniApply. By subscribing to our newsletter, you provide your consent for receiving the emails with the latest news regarding UniApply and related products.
(C) University Application Information
2.4 When you submit an application through the Platform, we may collect and process the information provided in such application which generally includes various personal information as requested by the applicable university. We process this information in order to provide our services upon your request. We will share this information with the university for which you applied, and you are encouraged to review their privacy and other data policies before applying. Once we transfer your information to the university, we lose all control over their handling of such information.
2.5 We may also collect personal information about you from third-parties such as to verify your recommendations, academic achievements and performance, and other information provided by you.
(D) IP Address and server log files
2.6 We integrate security systems on our Platform to prevent malicious attempts and exploits of the Site. We scan IP addresses and ban IP addresses that show malicious signs such as too many password failures, seeking exploits and similar. We process this information in the interest of protecting the integrity of the Site and of the databases connected with it. We collect your IP address on the basis of a legitimate interest to maintain the integrity and safety of our databases.
2.7 The Platform collects a series of general data and information when a person accesses the Site. This general data and information are stored in the server log files. Information that is collected includes (1) the software and browser types and versions used, (2) the operating system used by the accessing system, (3) the date and time of access to the Services, (4) the Internet service provider of the accessing system, and (5) any other similar data and information that may be used in the event of attacks on our information technology systems.
2.8 We collect this information for breach investigation purposes. When using this information, we may connect specific log files with specific Users provided that Users are logged in their UniApply accounts when accessing the Site. This information is needed to (1) troubleshoot problems and correct system bugs, (2) deliver the content of our Platform correctly, (3) optimise the content of our Platform as well as its advertisement, (4) ensure the long-term viability of our information technology systems and website technology, and (5) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. We collect this information based on our legitimate interest.
(E) Other Information
2.9 You may also choose to provide other personal Information during the course of your use of the Services. You may also opt in to allow us to use any testimonial you provide for our marketing purposes. Whenever we use your testimonial we will display your name and your photo if provided. You may withdraw your consent for our use of your Information for marketing purposes at any time by contacting us.
2.10 Some Services will not be available to you if you do not provide the requested Information. We may keep records of any questions, complaints or compliments made by you and the response, if any. Whenever you contact us, we shall collect any information which you chose to provide. We shall store and use this information only for the purpose of responding to your enquiries. Information contained within the enquiry, free from any personally identifiable Information, will be stored on our servers for the purpose of improving our Services and providing the best customer support possible.
2.12 We may disclose your personal information to the universities, agents and operators under confidentiality or similar agreements: (i) to provide Services per your request; (ii) to administer our business or the Site; (iii) to provide customer support; (iv) to update account information; (v) to forward updates, announcements, and newsletters; (vi) to respond to your communications, and communicate with you about the Site and other activities related to the Site; (vii) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of the Site’s business or operations (including without limitation in connection with bankruptcy or any similar proceedings); or (viii) as otherwise authorized by you.
2.13 We have implemented security procedures and measures in order to ensure appropriate protection of the Information we process, against any misuse, unauthorised access, disclosure or modification. We will remove any Information about you upon your request no later than fifteen (15) days after the request has been made.
2.14 We acknowledge that the safety of your Information is one of the highest priorities and therefore only authorised processors have access to your information. Although we take all appropriate measures in respect to keeping your information secure, you understand that no data security measures in the world can offer 100% protection. If we ever find or suspect a personal data breach we will without delay, within seventy-two (72) hours after becoming aware of it, notify the appropriate supervisory authority about the breach and Users where necessary.
2.15 Users may request access to, modification and erasure of personal Information and exercise the right to object. Such requests should be submitted to firstname.lastname@example.org.
3. Underage Users
3.1 If you are younger than 18, an account may be registered for you on the Site only by your parent or legal guardian. The information requested by some applications is very sensitive and you are advised to always seek an adult supervision when browsing applications as they can help you understand better the consequences of providing your personal information. If we ever suspect that the information is provided by an underage User without the approval of their legal guardian, we will temporarily suspend such account and seek the approval of the legal guardian for further data processing. If approval is not obtained within reasonable time, we will deactivate such User account and remove any personal information related to such account.
4. Storage and transfer of Information
4.1 Information will be stored on secure servers hosted in Hong Kong. Hosted servers are controlled and maintained in accordance with sufficient privacy safeguards. We may transfer Information on Users to servers located in other countries provided that such countries implement appropriate and suitable safeguards regarding the security of personal information.
4.2 Information is stored on the servers only for the duration necessary for providing the Services and maintaining the integrity of our databases.
4.3 Some services require the use of third-party solutions. When you are redirected from our Site to the third-party website you are no longer interacting with our Site. Any information that you provide through third-party websites will be handled and processed in accordance with their Privacy Policies and other applicable terms.
5. Third Party Websites, Services, and Cookies
5.1 The Site or e-mails may contain links to other external websites that do not fall under our domain. We are not responsible for the privacy practices or the content of such external websites. If you choose to follow such links to external websites, you do so at your risk.
5.2 Cookies help us optimise and improve the user experience of the Site by helping us deliver crucial functionalities. The cookies we use may vary over time as we continuously update and improve our Site and Services. We may use third party services like Google Analytics and others. Cookies from such services are used to collect data for statistical reports.
5.3 You can manage your cookies preferences at any time. This is done in your browser or device settings. Depending on which browser and device you use you may be able to control which cookies you allow, which cookies you want to block in the future, and delete cookies. For more information about these settings visit your browser or device´s help page. Note that some of UniApply’s Services might not work as intended if you choose to disable cookies.
6. Information retention period
6.1 If you register an account with us we will store your Information for as long as you have an active account. As soon as you delete your account we will remove all Information we have collected about you unless we have appropriate legal grounds for continuing their processing.
7. EEA User's Rights
7.1 If you are citizen or currently residing in any country member of the EEA you may request to:
- Obtain confirmation if your Information is processed, access Information about you that we had stored as well as supplementary information.
- Receive a copy of Information on you that is held by UniApply in a structured, commonly used and machine-readable format.
- Correct your Information.
- Have your Personal Information deleted.
- Object to the processing of Information by UniApply.
- Restrict the processing of your Information by UniApply.
- File a complaint with a supervisory authority.
7.2 These rights might be limited if they are subject to UniApply’s own legitimate interests and regulatory requirements.
9. Contact Information