Gradstar Global Education “Gradstar,” “we,” “us,” or “our”) recognises the importance of protecting the privacy and the privacy choices of its online visitors and other individuals from whom it receives personal information.
This privacy and cookies policy (“Policy”) sets out Gradstar’s policies and practices on the collection, use, disclosure, storage, security and management of personal information obtained from an individual through the use of www.gradstarglobal.com or any other website owned, operated or controlled by us (“website”) or obtained from individuals other than through the website (including but not limited to, personal information collected by our employees, customers, vendors, service providers or any other individual(s) having any association with us in the course of our business activities).
In this Policy, we describe:
By visiting and using our website and otherwise providing your personal information to us (either through the website(s) or outside the website(s)), you are agreeing and consenting to the policies and practices described in this Policy.
Important notes:
Please note that our website might offer links to other sites that are owned or controlled by third parties. This Policy applies only to Gradstar’s website. We do not control or endorse the content of any third party sites and cannot accept responsibility for the privacy practices of any websites not controlled by us. We encourage you to review the privacy policies of any third party sites that you visit.
In this Policy, the term “personal data” or “personal information” means any data or information that relates to a natural individual / person, which, either directly or indirectly itself or in combination with other information is capable of identifying such individual / person.
The types of personal data we collect about you depends on your use of our Website(s) or the nature of the relationship that you may otherwise have with us, and generally includes, where permitted by applicable law, the following:
| Categories of personal data collected | Specific personal data | Source of personal data |
|---|---|---|
| Identifiers | Name, email address, phone number, billing or mailing address, IP address, date of birth, national identification numbers and documents that may include your photograph and/or government identifier. | Directly from you, third parties on your behalf and as instructed by you, other users and customers, our service providers, employees and affiliates. |
| Financial information | Bank and credit account information, credit history as applicable, details of any transactions carried out with us, credit card, debit card, other payment instrument details. | Directly from you, third parties on your behalf and as instructed by you, recruitment partners, etc., other users and customers, our service providers, employees and affiliates. |
| Internet or other similar network activity | Other information collected through cookies and other tracking technologies and as described in the section below entitled “Our use of cookies and other tracking mechanisms” | From you directly and our third party analytic tools and cookies usage (See the section below entitled “Our use of cookies and other tracking mechanisms”). |
| Commercial information | Information about your business | Directly from you, third parties on your behalf and as instructed by you, other users and customers, our service providers, employees and affiliates. |
| Geolocation data | Geolocation | Directly from you and/or indirectly from you by your use of the websites and/or our third party analytic tools and/or cookies usage (See the section below entitled “Our Use of Cookies and other Tracking Mechanisms”). |
| Professional or employment information | Name and contact information, professional credentials and skills, educational and work history, salary, evaluations, references, interviews, certifications, disciplinary matters, physical, physiological and/or mental health information, medical history, biometric information and/or any other information of the type included on a resume, curriculum vitae or cover letter or in the employment contract or other documents pursuant to your employment or professional appointment / engagement with us. | Directly from you or when another party, such as a recruiter, counsellor, or external website, provides it to us. |
| Other categories | Any other information that you choose to provide to us (e.g., when you send us an email/otherwise contact us). | Directly from you, third parties on your behalf and as instructed or permitted by you. |
We collect personal data directly from you, about you from third parties (such as our marketing affiliates and service providers used to verify your identity and prevent fraudulent activity), other users, customers for the purpose of providing our services, our service providers, or as part of a customer referral program employees for effectuating our obligations as an employer, or other individuals pursuant to any other association that they may have with us in the course of our business activities and automatically as you use our Website.
We receive personal data about you from third parties, such as banking references, credit reporting agencies, affiliates, other users, events vendors, and other third parties (e.g., entities that assist us in validating your identity, for risk assessment purposes, for fraud prevention, etc.). We may combine this information with other information that we collect about you.
We, and our third party service providers, automatically collect the following information about your use of our Website and our online Services through cookies, web beacons, log files and other technologies (subject to your consent where required by applicable law): your domain name, your browser type and operating system, web pages you view, links you click, your IP address, the length of time you visit our Website or use our Services, your activities on our Website, and the referring URL or the webpage that led you to our Website. Please see the section “Our Use of Cookies and other Tracking Mechanisms” below for more information.
We collect your personal data whenever you inter alia do any of the following and the same is used by us as described below:
Create a student member account: To access certain features on the Website, you are required to create a student member account and provide your email address and password or sign in with Facebook or Google. Your login information is used to create your account, and otherwise provide and administer the service(s) you requested.
Throughout the application process, you have the option to provide additional information such as documentation of awards and school projects. This information is usually not required to process your application but can be recommended to enhance the success of your application.
We may use your profile information and other information about your use of the Website (such as search queries or other links you click on) to provide you with tailored recommendations through the Website.
Post on our website or social media channels (including direct messages): You have the ability to post information (e.g. questions, comments and opinions) through Gradstar’s services or on social media platforms, such as Facebook, LinkedIn, or Instagram, as well as send us direct messages via these platforms. Please be advised that any personal data that you voluntarily post to any public forum will be available to other individuals and you should exercise caution when posting any personal data. Content you post on sites owned by third parties (such as social media platforms) is subject to the privacy policies of those third parties.
Communicate with us: When you contact us with a comment, question or complaint, you may be asked for information that identifies you (such as your name, email address and a phone number) along with additional information we need to help us promptly answer your question or respond to your comment or complaint. We may also retain this information to assist you in the future and to improve our customer service, products, service offerings, events and promotions.
Provide information to third parties with whom we work: We may obtain personal data about you through your legal representative, or from third parties, such as mailing list providers and third-party service providers. Third-party providers are responsible for obtaining consent to provide personal data to us.
Payment processing and transaction tracking: We use, with your consent, third party payment service providers. When you directly make a payment using these payment service providers, you are subject to their terms and conditions and privacy policies. They are independent of Gradstar and we are not responsible for their privacy practices.
Sign up for marketing email and other communications: We may offer you the ability to sign up to receive Gradstar marketing and promotional communications through the Website, on third party websites (including through social media sites), or educational events and information sessions. In these circumstances, we collect certain personal data (such as first and last name, email address or mobile phone number) which we use to send you email and other communications containing Gradstar updates, tips, and other content that may be of interest to you. You can opt out of receiving promotional email from us by following the “opt-out” or “unsubscribe” instructions provided in your email or text message, or by contacting us as set out below. Please note that you may continue to receive messages from us regarding your application or other transactional and account-related electronic messages from us.
Participate in our surveys and research: From time to time, we may offer you the opportunity to participate in one of our surveys or other research. The information obtained through our surveys and research is used in an aggregated, non-personally identifiable format. We use this information to help us understand our customers, vendors, other individuals with whom we may have business arrangements and to enhance our product and service offerings, promotions, events, etc.
Sign up for contests and promotions: When you participate in a contest or promotion, we may collect your name, address, phone number, email address, and other information you provide. We use this information to administer your participation in the contest or promotion.
Apply for employment at gradstar: In connection with a job application or related inquiry regarding potential employment with Gradstar, you may provide us with certain personal data about yourself (such as that contained in a resume, cover letter, or similar employment and education-related materials). We use this information for the purpose of processing and responding to your application for current and future career opportunities. Pursuant to your employment with Gradstar, we may also from time to time collect additional personal data, including but not limited to financial information (such as bank account information), physical, physiological and/or mental health information, medical history, biometric information and other personal information as may be required for us to effectively discharge our duties and obligations of an employer under the applicable laws.
Other associations with Gradstar: You could also have some other form of contractual arrangement or association with us, which may not have been contemplated above, where personal information may be obtained from you with your consent for the purposes of our legitimate business activities and/or our performing certain contractual and/or legal obligations.
You are responsible for providing authentic, accurate and up-to-date information.
Gradstar shall not be responsible in any manner whatsoever.
Disclosure of information to third parties
We share your personal data with third parties, including service providers, regulated institutions (e.g., financial institutions), affiliated entities, and business partners and for the reasons as set out in the table below. We will ensure that the third parties with whom your personal data is shared, disclosed or otherwise transferred, that ensures the same level of data protection that is adhered to by us.
| With whom we share your personal data | Reason |
|---|---|
| Schools | We share the information in your application with the schools that you are applying to (either directly or through a third party on your behalf, within India or abroad). Once Gradstar has provided your information to these schools for your application for admittance, Gradstar does not have any control over the use of such information by these schools and recommends that you contact them directly if you have any questions about the manner in which your personal data is treated. |
| Partners | From time to time, we may partner with third parties to provide benefits to registered members of the Website. We may provide certain personal data to third parties so that they can contact you with information about the benefits and/or we may share your non-identifiable profile and usage data with third party partners for marketing and analytics purposes. We may use Facebook’s Custom Audiences to deliver advertisements to our subscribers on Facebook. Your personal information is not shared with Facebook; your email address is converted to a unique number that is matched with another unique number to identify you within Faebook. You can opt out of Facebook Audience ads. |
| Service Providers | We may transfer (or otherwise make available) your personal data to third parties who provide services on our behalf. For example, we may use service providers such as cloud providers to send our emails, host the website and data (including cloud providers) and operate certain of its features. Other service providers may assist us with the provision of the services, help us verify your identity, prevent, detect and protect against fraudulent activity or abuse of our services, conduct internal research and analytical assessments, process your transactions, maintain your account(s) and provide you with customer care services. These service providers include internet service providers, data and cyber security services, banks, financial institutions, payment processors, financial services providers, remote access services, service providers that help us verify your identity and help us comply with our legal and regulatory obligations; and our business, legal, tax, financial and other advisors, on a confidential basis. Your personal data may be maintained and processed by third party service providers in India or other jurisdictions. Our service providers are given the information they need to perform their designated functions, and we do not authorise them to use or disclose personal data for their own marketing or other purposes. |
| Parties to and those involved in a business transaction with Gradstar | We may transfer any information we have about you as an asset in connection with a proposed or completed merger, amalgamation, demerger, share sale, asset sale or pursuant to any other form of transaction (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Gradstar or as part of a corporate reorganisation or other change in corporate control. |
| Researchers | With your consent Gradstar uses your data internally for research and development to improve our existing products and services and/or create new features to serve you better. Gradstar also uses non-personal data (“Metadata”) for this same purpose. With your consent, we may share your personal data with third parties involved in research and development to improve our existing products and services and/or create new features to serve you better. Such third parties may include educational institutions, academics, and others in similar fields. |
| Lawyers, courts and law enforcement | Gradstar and our service providers may provide your personal data in response to a search warrant or other legally valid inquiry or order, or to an organisation in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by applicable law. We may also disclose personal data where necessary for the establishment, exercise, or defence of legal claims, to detect, suppress or prevent fraud, and to investigate or prevent actual or suspected loss or harm to persons or property. |
If you do not want us to use your personal data for us to market to you, and/or to pass on to third parties for marketing purposes, please contact us through the various communication channels available, as listed under the Section titled “Contact us, Questions, Updating your information, Opting out” below. You will also be able to unsubscribe from any marketing emails sent to you by Gradstar using a link provided in such emails. We do not sell your personal data.
Where we store your data
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Our servers are predominantly located in India. Many of our service providers may be located outside of India. While we use appropriate safeguards to keep your information secure, the laws in other places may differ from those in India and authorities in those jurisdictions may access your information in accordance with their local laws.
Security practices and procedures
Gradstar takes the security of your personal information very seriously. We have implemented reasonable security practices and procedures, administrative, technical and physical safeguards in an effort to protect against unauthorised access, use, modification and disclosure of personal data in our custody and control, including limiting access to our database to legitimate users and employing device encryption and version tracking. Gradstar has implemented the International Standard IS/ISO/IEC 27001 on “Information Technology – Security Techniques – Information Security Management System – Requirements”.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to secure and protect your personal data, we cannot guarantee the security of your data transmitted to our Website or otherwise electronically transmitted to us; any transmission is at your own risk. Once we have received your information, we will use strict practices and procedures and security features to try to prevent unauthorised access.
Your privacy choices
You have the following rights:
You may access, update and correct inaccuracies in your personal data in our custody or control at any time, subject to limited exceptions prescribed by law. Simply log into your account, go to your account profile, and make the necessary changes.
You can also request access, corrections or updates to other personal data in our records by contacting us as set out below. We may request certain personal data for the purposes of verifying the identity of the individual seeking access to their personal data records.
You may request your data be withdrawn (forgotten); this type of request can be performed assuming Gradstar is in a legal position to fulfill such a request. You must not have an active study application where financial or billing records are or may be in process should an application to a third-party service be engaged. Should Gradstar be able to comply with your request, only the personal data you provided will be forgotten. Non-personal data (“Metadata”) will be maintained regardless. Please note that upon complying with your withdrawal request, as contemplated in the foregoing, Gradstar will also have the right to stop performing or providing any of its services to you, for which your personal information had been sought.
Should you wish to lodge a concern or complaint to Gradstar, please contact us as set out below.
Privacy of minors
By using the website, you confirm that you are either 18 years of age or more, or an emancipated minor, or possess legal parental or guardian consent, and are fully able and competent to enter into, comply with, and be bound by the terms, conditions, obligations, affirmations, representations, and warranties set forth in this Policy. Gradstar does not intend to collect personal information from minors under the age of 18 years without consent from the minor’s parent or legal guardian.
Minors under 18 years of age should not submit any personal information to us without the express permission of their parent or legal guardian. If you believe that your child / minor under your guardianship has submitted personal information and you would like to request that their personal information be removed from our systems, please contact us at the information provided below.
Use of cookies and other tracking mechanisms
We and our third-party service providers use cookies and other tracking mechanisms (including tracking technologies designed for mobile applications) to track information about your use of our website. We may combine this information with other personal data we collect from you (and our third-party service providers may do so on our behalf).
Cookies: Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our website, while others are used to enable a faster log-in process or to allow us to track your activities at our website.
Cookies may involve the transmission of information from us to you and from you directly to us, to another party on our behalf, or to another party in accordance with its privacy policy. We may use cookies to bring together information we collect about you. You can choose to have your device warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. If you turn cookies off, you won’t have access to many features that make your guest experience more efficient and some of our services will not function properly. Please see the last section of this Cookies policy for more information about how to manage or disable browser cookies.
We use several categories of cookies and each performs different functions.
Generally, there are four types of cookies:
| Strictly necessary cookies | These are cookies that are required for the operation of our website. They include, for example, cookies that enable users to log into secure areas of our website. |
| Analytical/performance cookies | These types of cookies allow us to recognise, count the number of visitors, and see how visitors move around our website when they are using it. This assists us to improve the way in which our website works, for example, by ensuring that you can find what you are looking for easily. |
| Functionality cookies | These cookies are used to recognise you when you return to our website. They enable the personalisation of content, recognition of users, and also remember your user preferences (for example, your choice of language or region). |
| Targeting cookies | These cookies record your visit to our website, the individual pages visited, and the links followed. If the cookie is set by a third party (for example, an advertising network) which also monitors traffic on other websites, this type of cookie may also be used to track your movements across different websites and to create profiles of your general online behaviour. Information collected by tracking cookies is commonly used to target online advertising. |
The four types of cookies above will be either session cookies or persistent cookies.
HTML5 Storage: We may also store your user information and website preferences locally within your web browser via HTML5.
Clear GIFs, pixel tags and other technologies: Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our website to, among other things, track the activities of website visitors, help us manage content, and compile statistics about website usage. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Changing or disabling your cookie Settings: Most web browsers automatically accept cookies, but if you prefer you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our website who disable their web browsers’ ability to accept cookies will be able to browse the website, however, most site features will not function if you disable cookies and you will not be able to login to use our services. However, please note that in order to delete all cookies across all your devices you will need to separately adjust your cookie settings for each device.
Disabling/enabling cookies via your browser
There are a number of ways for you to manage cookies and other tracking technologies. Through your browser settings, you can accept or decline cookies or set your browser to prompt you before accepting a cookie from the websites you visit. You should be aware that you may not be able to use all our interactive features if you set your browser to disable cookies entirely.
If you use different computers in different devices or locations, you will need to ensure that each browser is adjusted to suit your preferences.
You can delete or disable any cookies that have been installed in the cookie folder of your browser. The various browsers provide different procedures to manage your settings. Click on any of the browser links below for instructions.
If you are not using any of the above-listed browsers, then you should select “cookies” in the “Help”, “settings” or “security” function of your browser for information on where to find your cookie folder.
You should also be aware that disabling cookies does not disable other types of analytics products which we may use to collect generic information about how you and other visitors use our website.
Cookies overview
Do Not Track: Currently, our systems do not honour browser “do-not-track” requests. You may, however, disable certain tracking as discussed above (e.g., by disabling Cookies); you also may opt-out of third party analytics or targeted advertising by following the instructions in the third party ad networks section below.
Social media: We may offer you the opportunity to engage with our content on or through third-party social networking websites, plug-ins, and applications. When you engage with our content on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture) to deliver the content or as part of the operation of the website, plug-in or application. When you provide information from your social media account, we may use this information to personalise your experience on the website and on the third-party social networking websites, plug-ins and applications, and to provide you with other products or services you may request.
Links to other websites: Our website may contain links to other websites that Gradstar does not own or operate, including the websites of third-party partners. Also, links to our website may be featured on third party websites on which we advertise. Except as provided herein, we will not provide any of your personal information to these third parties without your consent. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organisations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.
Third party analytics
Gradstar uses the web analytics services from Google Analytics and other third-party providers to collect standard internet log information. Tools such as these may use cookies to help us analyse how visitors use the website. For example, with Google Analytics, the information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by a Google server. Google uses this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators, and providing website operators with other services relating to website activity and internet usage. You can prevent the storage of data relating to your use of the website and created via the cookie (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. You can also obtain additional information on Google Analytics’ collection and processing of data and data privacy and security at the following links: https://policies.google.com/technologies/partner-sites and https://support.google.com/analytics/topic/2919631.
Third party ad networks
We use third parties, such as network advertisers and other marketing agents, to display advertisements on our website, to assist us in displaying advertisements on third party websites, and to evaluate the success of our advertising campaigns. Network advertisers are third parties that display advertisements based on your visits to our website and unrelated third-party websites. This enables us and these third parties to target advertisements by displaying ads for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other technologies to measure the effectiveness of their ads and to personalise advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information about your use of our website, as well as aggregate or non-personally identifiable information about visitors to our website.
Data retention
Gradstar will only retain your personal data while it is needed to fulfill the intended purpose for which it was collected or as otherwise permitted or required by law or contract (which may extend beyond the termination of our relationship with you).
Typically, personal data is maintained during the time you are engaged in the institutional program you applied to, or for up to a year following our last contact with you. We may retain certain data as necessary for:
All retained personal data is treated in accordance with this Policy.
If you request that your personal data be removed from our databases and/or systems, it may not be possible to completely delete all your personal data due to technological and legal constraints. However, we will take such steps as are reasonable to securely destroy the information or to ensure that the information is de-identified and/or anonymised as necessary.
Should you request additional services from Gradstar which are subject to this Policy, you will be authorising the extension of the data collection and/or processing purpose as a result.
The entity, student or institutional partner which has uploaded the document(s) for verification may request premature deletion of uploaded files. This is most likely to occur in the case where a content correction or update is required.
Changes to our privacy policy
This Policy may change from time to time. Any changes in the future will be posted on our website and, where appropriate or possible, we will notify you by email.
We strongly encourage you to check back frequently to see any updates or changes to our Policy. We will not materially reduce your rights under this Policy without taking steps to bring such changes to your attention.
Contact us, questions, updating your information, opting out
If you are a Gradstar student and would like to update your personal details contact us through the contact information below. If you are not a Gradstar student but have provided us with your personal or business details and you would like to update your details, you may contact us via the contact details listed below.
Please contact us if:
Attention to: Privacy Manager
12th Floor IThum Tower B, Plot No.
A-40 Sector 62, Noida, India.
Phone: +61 38640 4071
E-mail address: privacy@gradstarglobal.com
All grievances shall be redressed in an expeditious manner. Subject to complete details in relation to the grievance being provided, Gradstar shall redress all grievances within a maximum period of 1 (one) month from the date of receipt of the grievance.
Governing law
This Policy is governed by the laws of India. Any action, suit, or other legal proceeding, which is commenced to resolve any matter arising under or relating to this Policy, shall be subject to the exclusive jurisdiction of the courts of Mumbai, India.
Appendix 1: Additional terms for EEA and UK customers
The information below is required pursuant to EEA law regarding privacy and data protection. The terms below apply to our EEA and UK customers and website visitors, in addition to the terms in the rest of the Policy. For the purposes of the General Data Protection Regulation (“GDPR”), the data controller is Gradstar Global Education. If you have any questions about this Policy, please contact us at privacy@gradstarglobal.com.
If you are unhappy about how we are processing your data or how we have responded to a request or complaint, you have the right to make a complaint to your local supervisory authority.
WHEN DO WE SHARE YOUR PERSONAL DATA?
The heading “Disclosure of information to third parties” lists who we may share your information with, which include transfers for reasons of legal compliance and necessity in order to provide you with our services. You should be aware that when sharing your information, it may be transferred to, and stored at, a destination outside the EEA or the UK, as applicable.
Please note that where data is transferred outside of the EEA, non-EEA countries may not offer the same level of protection for personal data as is available in the EEA. Gradstar will take various measures to ensure that your data is treated securely, which may include, but not be limited to:
Please contact us at privacy@gradstarglobal.com if you require more detailed information about international transfers of your personal data, and the particular safeguards used.
LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA
We process your personal data based on the following legal bases, as recognised by and in compliance with the applicable data protection laws:
Sometimes we process data about you which the law considers to fall within special categories (see section “The Information that we collect” for more details), in which case, we use one of the following grounds:
If you would like more information about the legal grounds used to process your information, or about the legitimate interests referred to above, please contact us.
In cases where we have asked for, and you have given, your consent to our processing of your personal data, you have the right to withdraw such consent at any time. You can do this by contacting privacy@gradstarglobal.com.
DO YOU HAVE TO GIVE US YOUR PERSONAL INFORMATION?
In most cases, providing your personal data to us is optional, however, if you do not provide it, you will not be able to use our services. For example, we need details such as your name, address and bank account details so that we can make payments to you and receive payments from you. In other cases, you have a choice over whether we collect your personal data, for example, you can turn off cookies on your browser and we will not place any cookies on your device or computer (although in this case you may not be able to use all parts of our website).
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
Gradstar will only retain your personal data while it is needed to fulfill the intended purpose for which it was collected or as otherwise permitted or required by law or contract (which may extend beyond the termination of our relationship with you).
Typically, personal data is maintained during the time you are engaged in the institutional program you applied to, or for up to a year following our last contact with you. We may retain certain data as necessary for:
All retained personal data is treated in accordance with this Policy.
If you request that your personal data be removed from our databases and/or systems, it may not be possible to completely delete all your personal data due to technological and legal constraints. However, we will take such steps as are reasonable to securely destroy the information or to ensure that the information is de-identified and/or anonymised as necessary.
Should you request additional services from Gradstar which are subject to this Policy, you will be authorising the extension of the data collection and/or processing purpose as a result.
The entity, student or institutional partner which has uploaded the document(s) for verification may request premature deletion of uploaded files. This is most likely to occur in the case where a content correction or update is required.
YOUR RIGHTS UNDER GDPR
You have several rights in relation to your personal data which are described in more detail below. You can exercise your rights at any time by contacting us at privacy@gradstarglobal.com.
Accessing your data
You can ask us to:
You do not have to pay a fee for a copy of your personal data unless your request is unfounded, repetitive or excessive, in which case we will charge a reasonable amount in the circumstances. We will let you know of any charges before completing your request.
Correcting your personal data
You can ask us to correct any personal data which is inaccurate or incomplete (in most cases you will be able to make these changes yourself by logging into your account). This is free of charge.
If we have shared the personal data with anyone else, we will tell them about the correction wherever possible.
If we cannot action a request to correct your personal data, we will let you know and explain why this is.
Erasing your personal data
This right is sometimes referred to as “the right to be forgotten”. This is not an absolute right but you have the right to have your data erased, free of charge, in certain circumstances.
You can ask for your personal data to be erased where:
There are some exceptions to this right. If one of these applies, we do not have to delete the personal data.
If we have shared your personal data with third parties, we will tell them about the erasure of your data unless this is impossible or would involve disproportionate effort.
Please note, in connection with such requests, that personal data may be either deleted or retained in an aggregated manner without being linked to any identifiers or personal data, depending on technical commercial capability.
Restricting the processing of your personal data
You can ask us to restrict the processing of your personal data in some circumstances, free of charge. This is not an absolute right. If processing is restricted we can store the personal data and retain enough information to make sure the restriction is respected unless you consent or the processing is necessary in relation to a legal claim or to protect the rights of another person or for reasons of important public interest, but we cannot further process your personal data.
You can restrict the processing of your personal data in the following cases:
If we have disclosed the data to a third party, we will inform them about the restriction unless it is impossible or would require a disproportionate effort. We will tell you if we decide to lift a restriction on processing your personal data.
Objecting to the processing of your personal data
You have a right to object to the processing of your personal data at any time. This request will be free of charge. It is not an absolute right, but you can object to our processing of your personal data where it is:
We will stop processing your personal data unless we have compelling legitimate grounds for the processing which override your interests and rights, or unless we are processing the personal data for the establishment, exercise or defence of legal claims.
You can require us to stop using your personal data for direct marketing purposes. We will stop as soon as we receive your request, however we may not be able to implement this for any direct marketing campaigns which are already in progress. There are no exemptions or reasons for us to refuse.
Data portability
This allows you to obtain and reuse your personal data for your own purposes across different services. It applies where the following conditions are met:
We will provide your personal data free of charge in a structured, commonly used and machine-readable form.
Dealing with requests to exercise your rights
We will respond to your request without undue delay at the latest within one (1) month of receiving your request, unless it is particularly complicated or you have made several requests, in which case we may extend this by two (2) months. We will let you know if we are going to take longer than one (1) month in dealing with your request. If we have a lot of information about you we might ask you if you can tell us what exactly you want to receive. This will help us action your request more quickly.
For the purpose of complying with your requests to exercise the rights listed above, we shall perform the necessary internal processes to identify you.
Appendix 2: Additional terms for state of California customers
The information below is required pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”). The terms below apply to residents in the State of California in addition to the terms in the rest of the Policy.
CCPA REQUESTS
Under the CCPA residents in the State of California are provided with specific rights regarding the collection and storage of their personal data.
You may apply to us with requests as detailed below by contacting us at privacy@gradstarglobal.com. We do not discriminate against any individual based on the exercise of his/her privacy rights.
CCPA information request rights
You have the right to request that we provide to you the following information about our collection and use of your personal data over the preceding twelve (12) months. Once your verifiable consumer request has been confirmed through our review of the information you provide in your request, we will disclose to you:
CCPA deletion request rights
You have the right to request that we delete any of the personal data collected from you and retained, subject to certain exceptions and your verification. Your request to delete the personal data collected may be denied if it is necessary for us to retain your information under one or more exceptions listed in the CCPA.
We do not sell personal data collected about you to third parties. We may share your information with our service providers or as instructed by you from time to time for the purpose of providing you the Services and as detailed above under the section titled “WHEN DO WE SHARE YOUR INFORMATION”.
For more information, contact us at privacy@gradstarglobal.com.