Privacy Notice

Last Updated: 10-Nov-2022

This Privacy Notice must be read by all Users with consideration and agreement in conjunction with Our other Policies and Terms & Conditions, which will provide context and definitions.

Introduction

This Privacy Notice applies to The Apply Group Ltd’s Website(s) as defined on the Company Terms & Conditions, connecting existing university students (Mentors/Tutors) with potential applicants (Students/Applicants) and their representatives (inc. parents, legal guardians, schools) as well as potential employers. When we mention ” TAG” or refer to, “we, us or our” in this Privacy Notice then we are referring to:

The Apply Group Ltd. (‘TAG’) with CRN: 12938105 has its registered office at: Suite 209, Mayfair Point, 34 South Molton Street, London W1K 5RG, United Kingdom.

This Privacy Policy sets out the types of Personal Information we collect about Users; the data subject when you use our platform, as well as details on how we use and store that Personal Information, who we share it with, and what rights you may have in respect of that Personal Information.We respect your privacy and are committed to protecting your personal data.

• IMPORTANT INFORMATION AND WHO WE ARE
• THE DATA WE COLLECT ABOUT YOU
• HOW IS YOUR PERSONAL DATA COLLECTED
• OUR LEGAL BASIS FOR USING YOUR PERSONAL DATA
• HOW WE USE YOUR PERSONAL DATA
• DISCLOSURES OF YOUR PERSONAL DATA
• INTERNATIONAL TRANSFERS
• DATA SECURITY
• DATA RETENTION
• YOUR LEGAL RIGHTS

1. Important information and who we are

This Privacy Notice aims to give you clear and detailed information about:

• • how we collect and process your personal data• the legal grounds allowing us to do so
• • how we look after your personal data• your privacy rights
• • how the law protects you.

Controller

Under data protection law the controller of your personal data decides how and why your personal data will be processed and takes responsibility for looking after your personal data. The controller of your personal data will be specifically Us, The Apply Group Ltd.

Data Subject

In this privacy notice we refer to the data subject as ‘you the user’. A data subject is an identified or identifiable living individual to whom personal data relates.

Data Protection Compliance Manager

We have appointed an external trained and experienced data protection compliance manager (DPCM) who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact the DPCM using the details set out below.

Main Company Contact details

Full name of legal entity: The Apply Group Ltd. ICO Registration Number: 00019876788 Email address: contact(at)theapplygroup(dot)com

Postal address: Suite 209, Mayfair Point 34 South Molton Street, London, England, W1K 5RG

Changes to the Privacy Notice and your duty to inform Us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.When we issue a new version of this privacy notice we will post a message on our websites advising of this.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. The websites of any of our subsidiary businesses are subject to this privacy policy.

2. The data we collect about You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username, student ID number, marital status, title, date of birth, gender, photograph, immigration status, right to work, visa status, curriculum vitae (CV), covering letter, academic record, employment history and references, DBS information and experience relevant to assisting, mentoring and tutoring previous Tutees/Mentes.
• Special Category Data includes details about your race or ethnicity, religious beliefs, information about your health, genetic and biometric data (we have in place safeguards for processing such data including confidentiality agreements and restrictions on access to such data). Criminal Conviction Data includes details about any unspent criminal convictions and offences (where not covered by Section 1 (1) of the Rehabilitation of Offenders Act 1974) (we have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data).
• Contact Data includes your home address, email address and telephone numbers, next of kin and emergency contact information. Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of services you have purchased from us or other Users.
• Technical Data includes internet protocol (IP) address, your login data, 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 when accessing Our Websites.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our websites and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Aggregated Data includes statistical or demographic data which we may collect, use and share for any purpose. Where Aggregated Data can directly or indirectly identify you we will use it in accordance with this Privacy Notice.

If you do not provide us with 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. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time. When communicating with your Mentor/Tutor or Applicant/Student please do not share personal information that You have not already shared with Us.

We cannot monitor, protect or control or take any responsibility for the data You decide to share during Your meeting sessions or in any direct messaging function.

It is in Your best interests to only share personal data that is important for purposes of providing/receiving booked Services.

If You choose to disclose personal information that has not been collected by Us to a Mentor/Tutor or Student/Applicant you do this at your own risk, we will not be able to monitor, take any responsibility for or protect this data on Your behalf.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:Direct interactions. You may give us your Identity Data, Special Category Data, Contact Data and Financial Data by filling in application forms, by sending us your CV and covering letter or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when/if You:

• Create an account on our website
• Requested marketing information is sent to you
• Apply for a job
• Apply to be a Mentor/Tutor
• Communicate between Mentor/Tutor and Student/Applicant
• Complete a survey
• Give us some feedback.

We may receive personal data about you from various third parties and public sources such as those set out below:

• Named Referees – Identity Data and Contact Data
• Recruitment agencies – Identity Data and Contact Data
• Disclosure and Barring Service – Criminal Conviction Data
• Providers of technical, payment and delivery services
• Contact, Financial and Transaction Data
• Technical Data from the following parties:
• (a) analytics providers
• (b) advertising networks
• (c) search information providers

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, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our separate Cookies Policy for further details.

4. Our legal basis for using 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 it is necessary for us to perform a contract entered into with you or is necessary for us to take steps (at your request) prior to us entering into a contract (CONTRACT).
• Where we have a legitimate organisational interest and use your personal data in a way that you would reasonably expect, and which has a minimal impact on your privacy (LEGITIMATE INTERESTS).
• Where we need to comply with a legal or regulatory obligation (LEGAL OBLIGATION).
• Where you have given us your consent to process your personal data (CONSENT).
• Where there is an emergency situation, for example, if you needed emergency medical treatment (VITAL INTERESTS).

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to the processing of Special Category Data or when sending third party direct marketing communications to you via email or text message.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out at Table 1 shown at the foot of this notice.

You have the right to withdraw your consent at any time by contacting Us.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside Our subsidiaries for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

When you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of purchasing a service or other transaction.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.

Internal Third Parties

Our Companies acting as joint controllers or processors and who are based in the UK,

provide (i) process customer orders, (ii) issue or complaint resolution.

External Third Parties

• • Insurance providers
• • Medical or Public Health authorities (and where an emergency situation to any other organisations/individuals deemed necessary as assessed at the time)
• • Appointment/Scheduling and payment systems (inc, APIs)
• • Employment/internship/work-placement/experience platforms
• • Local councils/authorities• HM Revenue & Customs, regulators and other authorities acting as processors• Service providers worldwide acting as processors
• • Cloud-hosted providers
• • Professional advisers worldwide acting as processors or joint controllers
• • Local authorities
• • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International transfers

We share your personal data within Our company. This may involve in some cases transferring your data outside the European Economic Area (EEA).

Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission (as at the date of this Privacy Notice this applies to Andorra, Argentina, Canada (commercial organisations), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland, Uruguay and UK).
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US, or we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe, with standard contractual clauses. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. Data security

The personal data that we collect from you will be stored:

• • in secure data centres located in the EU; and
• • in the secure data centre of our IT and system administration service provider

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 data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data retention

How long will you use my personal data for?

We will keep your Personal Information while you have an account with us. Thereafter, we will keep your Personal Information for as long as is necessary to respond to any questions, complaints or claims made by you or on your behalf, to show that we treated you fairly, and to keep records required by law.

We will not retain your Personal Information for longer than necessary for the purposes set out in this policy. When it is no longer necessary to retain your Personal Information we will securely destroy it in accordance with applicable laws and regulations. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Please see Table 2 at the foot of this notice to view details of retention periods for different aspects of your personal data.

In some circumstances you can ask us to delete your data: see ‘Request Erasure’ in Section 10 Your legal rights for further information.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

Request access to your personal data – (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of your personal data – This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data – (commonly known as the “right to be forgotten”). This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data – where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing your personal data – This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• (a) if you want us to establish the data’s accuracy;
• (b) where our use of the data is unlawful but you do not want us to erase it;
• (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request transfer of your personal data – (also known as the “right to data portability”) We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Right to withdraw consent – However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact our Data Protection Compliance Manager, in writing with full details of your request by emailing directly on:

Data Protection Compliance contact.at.theapplygroup.com

No fee usually required.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact Us in the first instance.

TABLE 1

LAST UPDATED 30/06/22

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TABLE 2

LAST UPDATED 30/06/22

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