Smart Prospects Ltd., Private Limited Company, registered by the Registrar of Companies for England and Wales under registration number 084223213, with its registered office in Orchard House, 15 Market Street, TF2 6EL, Telford, United Kingdom (hereinafter referred to as Smart Prospects) being the owner of Smart Prospects web portals located at the website https://www.uniedu.uk/ ; https://app.uniedu.uk and https://sp.edu.pl and its subpages (hereinafter referred to as the ‘Web Portal’) makes every effort to ensure the most comprehensive protection of personal data of the Users of the Web Portal.
Controller – natural or legal person, public authority, agency or other body which independently or together with others determines the purposes and means of the processing of personal data,
Personal data – means any information relating to an identified or identifiable natural person; an identifiable natural person is a person who can be directly or indirectly identified, in particular on the basis of an identifier such as name, identification number, location data, online identifier or one or several special factors specifying physical, physiological, genetic, mental, economic, cultural or social identity of that natural person,
Processing ‒ means any operation or a set of operations carried out with respect to Personal data or sets of Personal data in an automated or non-automated way; such as gathering, recording, organising, putting in order, storage, adaptation or modification, downloading, viewing, using, disclosing by sending, dissemination or other type of provision, adjustment or combining, limiting, deletion or destroying,
User – Guest, Registered Guest, Applicant referred to in the Regulations of provision of services by electronic means by web portal https://www.uniedu.uk, being an individual who by using the Web Portal or otherwise provides Smart Prospects with personal data concerning him or her.
Other definitions can be found in the Terms of Service available here.
Smart Prospects processes personal data of Users in compliance with the law, in particular with the Regulation of the European Parliament and of the Council (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (‘GDPR’), repealing Directive 95/46/EC, and any applicable UK or EU member state laws implementing the GDPR including the UK Data Protection Act 2018, and any successor laws and/or regulation.
We take the appropriate organisational and security measures to protect your personal data.
The information we collect includes:
Personal and contact details such as: name, email address, phone number.
Information relevant for the recruitment process to apply to a university: such details are included here. The Controller also processes text included in Personal Statements, chat and reference letters. Other data that can be processed includes a link to the Applicant's Facebook profile, universities of further choice and additional comments provided by the Applicant.
More details on the process and types of data required can be found in our Terms of Service available here.
The data controller is Smart Prospects Ltd., Private Limited Company, registered in the Registrar of Companies for England and Wales under registration number 084223213, with its registered office in Orchard House, 15 Market Street, TF2 6EL, Telford, United Kingdom, which may be contacted in writing at the aforementioned address or by email at firstname.lastname@example.org.
The Controller may provide other entities with personal data of Users, ensuring sufficient guarantees of the implementation of proper technical and organisational means so the processing of data is lawful and protects Users’ rights. Personal data of Users may be provided only to authorised employees of the Controller, external entities rendering services to Smart Prospects (including with respect of handling payments, courier, accounting, IT, hosting, marketing services and other companies/services used for the optimisation of the services provided to the Users including processing of the text from the Users’ Personal Statements and reference letters, and information provided by the Users in the chat functionality), public administration bodies and other entities or companies to enable them to provide the User with services the User has asked for.
Users’ Personal data is provided to higher education institutions located in the area of the United Kingdom and to partner organisations cooperating with the Service Provider as well as cloud/hosting providers, consultancy organisations that the Service Provider use and other third party services (for the purpose of provision of services and performance of an agreement entered into with a User). The Service Provider also uses Google Analytics referred to in Clause 12 and Zoho.
The Controller can also share personal data of Users where there is a legal or regulatory requirement to do so or in an instance of a litigation.
Smart Prospects processes personal data provided by Users:
within the scope arising out of a consent given by a User ‒ as set out in Art. 6(1)(a) of the GDPR,
within the scope necessary for the conclusion, performance and termination of the legal relationship arising out of a service agreement entered into with a User and ensuring on-going communication with a User ‒ as set out in Art. 6(1)(b) of the GDPR,
within the scope necessary for fulfilment of the Controller’s legal obligations, in particular tax and accounting obligations ‒ as set out in Art. 6(1)(c) of the GDPR,
within the scope necessary for pursuing a justified interest of the Controller in the form of possibly determining, pursuing or protecting against claims, considering submitted complaints, and within the scope necessary for sending up-to-date information on changes and improvement of functionalities of the Web Portal website by using cookies and Internet analytics tools (to gather information on the methods of use of the Web Portal by Users, service of logging on, protection against repeatedly displaying the same contents, compiling anonymous statistics of the contents of the web portal) ‒ as set out in Art. 6(1)(f) of the GDPR.
Commercial/marketing information is sent to a User of the Web Portal only on the basis of User’s prior consent which may be revoked at any time.
Personal data provided by Users is processed by Smart Prospects only for the purpose for which it was gathered and for the period necessary for its fulfilment, i.e. for the time of provision of services or the term of an agreement, and after its end:
personal data gathered to perform the agreement is processed not longer than until the expiry of the period of limitation of claims and/or until the fulfilment of the services (as defined in the Terms of Service available here),
personal data gathered to discharge tax and accounting obligations imposed on the Controller is processed not longer than until the legal obligation ceases to exist,
personal data gathered to gather information on the methods of use of the Web Portal by Users is deleted upon closing a web browser or stored for the period specified in parameters of cookies or until they are deleted by a User,
personal data obtained on the basis of a consent is processed not longer than until a User makes an objection or withdraws the granted consent.
A User has the right to access personal data concerning the User, correct or delete it or limit its processing, and the right to transfer data and the right to file a complaint to a supervising body.
A User has the right to withdraw a granted consent at any time, notifying the Controller about this fact by email or post. Withdrawal of a consent does not affect lawfulness of the processing carried out on the basis of the consent before its withdrawal.
A User has the right to raise an objection against the processing of data by the Controller for a specific purpose (e.g. for marketing purposes). A User may exercise the above right at any time and free of charge.
Rights outlined in §6-7 can be exercised by contacting the Controller whose contact details are included in §2.
It is the responsibility of a User to make sure the information the User provides is accurate and up-to-date and must inform the Controller about any changes.
Smart Prospects will not take decisions with respect to a User based exclusively on automated processing, including in the form of profiling.
The Web Portal uses information recorded with cookies and similar technologies, and obtains access to this information to ensure correct functioning of the Web Portal website, analyse web trafficking, for statistical purposes as well as to provide personalised advertising and social sharing features.
Cookies are small text files automatically stored on an end device which contain a character string. Their purpose is, among others, to allow the website to identify a web browser in case of another visit of a User, and to store data concerning User’s preferences and other data.
Session cookies used by the Web Portal are temporary files which are stored on User's end device until logging off, leaving the website or turning off software (closing a web browser). Persistent cookies are stored on User’s end device for the time specified in cookies parameters or until they are deleted by User.
Cookies used by the Web Portal are described below:
Essential cookies (first-party cookies) which are necessary for the provision of the service. These are cookies used to prevent cross-site request forgery attacks, session cookies, cookies used for registering Users’ consent to cookies. Out of all essential cookies, only one cookie can be accessed by a third party which is the session cookie, to which a third party, Stripe, requires access for the purpose of payment operations and payment fraud prevention.
The retention period for all essential cookies is not longer than 2 years.
Non-essential cookies: used for tracking and providing the User with additional features. The Web Portal uses three types of non-essential cookies:
(i) Google Analytics - used for tracking User interaction and detecting potential problems as well as managing traffic. These help the Controller to improve the services by providing analytical data on how the Users use the Web Portal;
(ii) Facebook Messenger Chat - used for enabling live chat functionality. These cookies allow the User to directly communicate with the Controller through on-site chatbox in the bottom right corner of the Web Portal;
(iii) Facebook - used for providing personalised advertising and social sharing features. These cookies enable the Controller to share data such as the Users’ likes with third-party sites including social networks.
All three non-essential third party cookies listed above can be accessed by those third parties as they are owned by those third parties and the retention period for these cookies is not longer than 2 years and set by the third parties.
For non-essential cookies, Users can choose from three options: agree to all non-essential cookies listed in the cookie banner in the Web Portal, agree only to selected non-essential cookies or reject all non-essential cookies.
Essential cookies are restricted to cookies that are strictly necessary for the correct functioning of the Web Portal and these cookies will be applied automatically. Software used for browsing websites will ask the User if they accept the storage of cookies on a User’s end device. Users can change in their web browser settings whether they consent to saving cookies in memory of an end device and obtaining access to information recorded in these files when using the Web Portal. Users may at any time change settings of their web browser concerning cookies (among others in such a way as to block automatic support of cookies, inform every time they are saved on an end device, change whether they consent to saving cookies in memory of an end device and obtaining access to information recorded in these files when using the Web Portal). Detailed information on the possibility and methods of supporting cookies is available in web browser settings.
A User should be aware that some functionalities of the Web Portal may be impacted or limited for the User if cookies are not accepted.
To pursue the Controller’s legally justified interest which is improvement of functionality of the Web Portal website, the Web Portal uses Google (Universal) Analytics ‒ an Internet analytics tool of Google LLC (more information: http://www.google.com/analytics/learn/privacy.html).
Full IP addresses of Users are not stored as the Web Portal uses the possibilities of anonymisation and IP address masking offered by Google. Anonymisation/IP address masking takes place immediately after Analytics Collection Network receives information, and before any data processing or storage activities.
By using a web browser add-on made available by Google a User may block Google Analytics without blocking at the same time sending data to the Web Portal website.
The Web Portal uses external mailing / CRM systems of ZOHO company.
Information contained in system logs in relation to the general principles of connections in the Internet is used by a hosting company supporting the Web Portal only for technical and statistical purposes.