Privacy Policy
THE DAILY PULSE
We are committed to maintaining the privacy and security of your personal data. This Privacy Notice explains how we collect, use, share and protect your personal data. It is important that you read this Privacy Notice so that you are aware of how and why we are using your personal data.
What is personal data
Personal data is any information about an individual from which that individual can be identified. Your name, address, phone number and bank account number are examples of personal data. It does not include data where the identity has been removed (anonymous data).
How we collect your data
Online:
Enquiries
When you request information or make enquiries about any of our services or programmes on our website or social media, we may use the personal data you provide in order to fulfil your request or respond to your enquiry. It is in our legitimate interests to use your personal data in this way so that you receive the information you have requested.
Marketing
Where you have explicitly consented to do so, or where you have already studied with us and based on legitimate interests, we may use your personal data to inform you of special offers and new or existing services that we believe may be of interest to you or to send surveys or questionnaires so that we can learn more about your needs and interests. If you would prefer that we do not send such communications to you, please follow the opt- out links on any marketing message or contact us using the contact details in our Privacy Notice.
Automated technologies or interactions
As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy on our website for further details.
Online and Offline:
Applications
If you make an application to study on one of our programmes or book accommodation, we may collect the following categories of personal data about you:
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Personal information: name, title, addresses, language, date of birth, gender, nationality, country of residence, passport number
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Contact details such as telephone numbers, and personal email addresses
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Visa information and immigration status
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Education history, employment history
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Funding information and bank account details
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Health information (history of physical or mental illness, medications and dietary requirements)
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Emergency contact details
For students under the age of 18, the personal and contact data of parents or Guardians will be collected.
It is in our legitimate interests to collect and use the above information in order to consider and process your application.
Study and accommodation
If we enter into a contract with you relating to study or accommodation, we may collect additional personal data relating to you including bank account details, billing address, credit card or other payment information in order to process your payments.
This information, together with the personal data provided to us above at application stage, will be used by us to perform the contract we have entered into with you. Where relevant may also collect further personal data relating to your visa application and immigration status as we have a legal obligation to use this information.
During your studies we will collect information about your academic experience and progression. This is in order to fulfil our contract with you but it is also in our legitimate interests to use this personal data in order to monitor the provision of our service to you.
We may also collect personal data about your health and your parents/Guardian if you are under the age of 18, in order to make appropriate arrangements and reasonable adjustments for you regarding your welfare, attendance or accommodation. We use this information in order to perform our contract with you but also in order to fulfil our legal obligations.
We may also collect personal data about you if you are named as an emergency contact for an individual. We use this information as it is in the vital interests of such individual. If you use an agent to arrange your application and study with us, we may collect the categories of personal data described above from your agent.
How we protect your data
We will comply with data protection law. This says that the personal information we hold about you must be:
• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes. Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about. Kept securely.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform a contract we have entered into with you
• Where we need to comply with a legal obligation
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
• We may also use your personal data in the following situations, which are likely to be less common: Where we need to protect your vital interests (or someone else's interests)
• Where it is needed in the public interest or for official purposes
• We also may use your personal data for our internal business purposes. This is in our legitimate interests in order to operate as a business and monitor and improve the services we provide. Where possible we will anonymise this information.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
If you are an Alumni we will contact you after the completion of your course about future courses with us on the basis of legitimate interest however you can opt out of receiving this correspondence at any time.
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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
When and how we share your personal data with others
We may share your personal data with third parties where required by law, where it is necessary to perform our contract with you or where we have a legitimate interest in doing so. Such third parties may include the following:
Our service providers: We may share your personal data with other companies that perform certain services on our behalf. These services may include processing payments, providing customer service and marketing assistance, performing business and sales analysis and supporting our website and IT functionality. These service providers may be supplied with or have access to your personal data solely for the purpose of providing these services to us or on our behalf. Alpadia is the data controller and will remain accountable for your personal data.
Our business partners: If you are a part of Garantiefonds Hochschule programme in Germany we will share your personal data with your sponsors with whom we have a contract relating to your programme of study. We may also share your personal data with other business partners where we have a contract with them relating to your programme of study.
Agents: If you use an agent to arrange your application or study with us, we may share your personal data with them.
Parents and guardians: If you are under 18, we may share your personal data with your parents or guardians in order to perform our contract, comply with our legal obligations, and if it is in your vital interests.
Other entities in the Kaplan group: Alpadia, alongside ESL and Kaplan International Languages are part of Kaplan International. We may share your personal data with other entities in our corporate group for the purposes of responding to your inquiry, for the purposes of managing bookings, marketing, as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise or for system maintenance support and hosting of data.
Regulators: We may need to share your personal data if required by a regulator or to otherwise comply with law.
Others: We may share your personal information with other third parties such as in the context of the possible sale of our business. We may also need to share your personal data in order to permit us to pursue available remedies or limit damages we may sustain.
The security of your personal data
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, service providers, business partners, agents and other third parties who have a legitimate need to know. They will only process your personal information on our instructions or as otherwise agreed and they are subject to a duty of confidentiality.
Our storage and retention of your personal data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. 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 requirements. Please contact us using the contact details in this Privacy Notice if you would like more information.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Changes to this Privacy Notice
We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.