Privacy notice

CONTENTS

1. ‐ Privacy notice
2. ‐ Site specific privacy notice

Privacy notice

This privacy notice has been compiled to help you understand why we ask you for your personal information when you use one of our websites and how we will store and use this information.

IDP Connect Limited, an IDP Education owned company, is the principal company and the Data Controller in the IDP Connect Group of companies (Hotcourses Pty Ltd (Australia), IDP Connect Inc (North America) and Complete University Guide).

At the heart of our work is helping you and other users find suitable courses and learning providers. This is defined as our Legitimate Business Interest. We process your personal data to help you make informative decisions when selecting courses and learning providers. We do that by:

• Providing extensive educational information
• Providing advertising and promotional opportunities for education providers
• Providing features to enable users to directly contact education providers
• Recommending things which we think you'll like, such as courses and learning providers
• Notifying you about things you've told us you like, such as a new course in your local area
• Personalising sections of our websites to your preferences
• Dealing with any requests you make or content you submit
• Getting in touch if we need to tell you about something, like a change to our policies or issues with our service
• Monitoring usage and performance in order to improve the services we offer.

This privacy notice applies to all our website and app users regardless of location, whether registered or not, including people responding to surveys, competitions and writing reviews. We refer to all registered users as “members of our community”.

Keeping your information safe and private is very important to us. All our services are designed with privacy and security in mind. We will never sell your personal information to any third party.

Collecting and using your personal data

You can browse our websites without providing any personal information. However, to use some of our enhanced functionality we sometimes ask for additional information in order to process your request. Examples include:

• Providing your name, email, and contact details to request a prospectus or make an enquiry to an education provider.
• Providing your name, email address, and preferences to create an account to receive email newsletters and save your preferences.
• Providing your name, contact details, and education history to engage with offline education counselling services.

The details we request for each piece of enhanced functionality will depend on what is required to perform the action. For example:

• If we need to contact you by email, we will request your email address.
• If we tailor your experience by displaying available courses, we will ask for your preferred start date.

Details of why we collect each piece of information is displayed clearly next to the field used to enter the data.

A full list of the data collected by each website is available on the site-specific data collection notice.

We also collect some technical information while you use our websites. For example, information on the type of browser you use and your IP address. This information is used to maintain and monitor the performance of our websites.

Cookies

We use cookies on our websites to provide login and preferences functions, and to collect anonymised data on user interactions. For example, we use cookies to:

• Keep you logged into the website.
• Understand and save your user preferences for future personalised experience and to allow us to deliver the type of content and products in which you are most interested.
• Compile anonymised data about site traffic and site interactions in order to offer better site experiences and tools in the future. We use tools such as Google Analytics, IDP Connect Insights, and the IDP Connect Enrolment Matcher Tool to do this.
• To provide targeted content and advertising based on your preferences and previous interactions. We work with third-party companies to provide targeted advertising. Personal data is not shared with these companies. Further details of the companies we work with are available within our Cookie Policy.

Personal information is never held on any of our first-party cookies.

You can choose to have your computer block some or all cookies for you. You do this through your browser settings. Each browser is a little different, so look at your browser's Help menu to learn the correct way to modify your cookies.

If you disable cookies, some advanced features will be disabled and some of our services may not function as intended.

You can read more about how we use cookies on our Cookie Policy.

Anonymised analytics and insights

Occasionally, we will ask for additional information to help us monitor the reach and effectiveness of our services. For example, when creating an account, we may ask for your country of residence or postcode. This data will only ever be used in an anonymised format to help us demonstrate the effectiveness and improve the products and services we offer.

We use Google Analytics to log review aggregated use data across all our websites. No personal data is shared with Google Analytics.

Geographical data and geotargeting

As with all websites, your IP address is sent to us each time a webpage is viewed. For some functionality we use this, along with geo-location information provided by your browser to provide location-specific content within our websites and apps. When you browse our website or use our apps your IP address and location information is stored on our system anonymously unless you are a registered user in which case it will be possible to link it to your profile. This link will only exist temporarily and will be removed three months after your visit. We will not use this information to identify you personally. We use location data for analytics purposes, in order to understand the locations our products are successful in and to ultimately deliver a better service. You can stop sharing this information by changing your browser settings.

Mobile app specific settings

We offer push notifications, location based services, and targeting advertising through our apps. When you first use one of our apps, you will be asked whether you want to turn-on these services. You can opt-out of these services at any time using the changing the permissions through your device settings.

Storing your data

The personal data you provide is stored in a secure hosting environment based in the UK. We employ a range of technology and procedures to ensure that this data is secure, including encryption, anti-virus and anti-malware software, intrusion detection, company-wide data usage policies, and mandatory security and privacy staff training.

Your data is not stored outside EU however it may be accessed by one of our principal companies based in USA, India or Australia if they need to provide you with a service on our behalf. To ensure your data is secure and we comply with our privacy obligation, we have data sharing agreements and security operational and technical measures in place with these companies.

How long will you keep my information for?

We will keep your data for as long as we are required to, either:

• By law, for example to meet financial regulations relating to payments
• For as long as we require the data to provide a service to you

Personal data is deleted in accordance with our internal retention policy. All identifiable personal data is deleted three years following your last interaction with this website, for users registering from within the UK, and after two years for international markets.

Your rights

Reviewing and updating your data

You can update the information we store on your behalf by logging into your website account and updating your profile. If you were not assigned a password when creating your account, you can request a new password online by selecting the ‘forgotten password’ option. If you do not have access to this account, you can request a data update by contacting the Privacy Manager.

In line with the privacy regulations across the world, including GDPR (European Union) and CCPA (California, USA), you have the following rights:

The right to be informed

You have the right to be informed why and how we collect your personal data, how we will use this information, who we share it with, what are the security measures we take to protect this information and what are your individual rights. We will publish this information in this Privacy Notice.

The right of access

You have the right to access the information we hold for you by logging into your online profile, if you require a permanent record you can download this information in PDF format from our website. Alternatively you can make an offline Subject Access Request by contacting the Privacy Manager.

The right to rectification

You have the right for inaccurate or incomplete data we hold to be updated. You can make a request to have your data updated through the Privacy Manager.

The right to erasure

You have the right to be forgotten at any point by contacting the Privacy Manager or emailing delete@idp-connect.com

At your request, we will remove all the data we have for you which we are not required legally to retain.

The right to restrict processing

You have the right to restrict processing when you have exercised one of the above rights and it may take some time to process that request. For example: when you contact us to update your details you have the right to request restriction until your details are updated.

Right to withdraw consent

For the processing activities where we have asked you for consent, you have the right to withdraw this consent at any point by clicking on the unsubscribe link in any email we send you, or by updating your profile in the application or by contacting the Privacy Manager.

The right to object

You can object to the processing of your personal data at any point by contacting the Privacy Manager. There may be instances where we may not be able to fulfil those requests, but we will provide you with an explanation when replying to you.

Right to not be subject to automated decisions and profiling

None of our processing activities are purely automated. There are instances where we process data to analyse or predict behaviour but we will ask you for explicit consent when this processing will involve your personal data.

Right to data portability

If you have provided us with your personal data with consent or under the contact obligations, you have the right to request the data you have provided to us in a machine-readable format should you decide to move to another data controller.

Marketing and Email newsletters

As industry experts, it is our primary objective to help you with your educational journey. As part of this, we offer a number of subscription options for you to choose from.

You have the following two marketing options sent directly from us:

• Newsletters – inspiring emails from our editorial team, providing you with the latest university news, tips and guides.
• University Updates – emails sent from us providing news and updates of course information, open days, events and scholarships from universities and partners that match your interests. You will receive these newsletters based on your course, institution or location search history. We will not share your personal data with these institutions. We will only partner with carefully selected education sector institutions that have compatible activities and can help you with your journey. You can withdraw your consent at any point by logging in to our website and going to your profile page.

Marketing options from our partner institutions

When you use our applications you may also be invited to subscribe to our partners’ (Universities) marketing directly. When this option is available there will be a consent box on the relevant form with a link to the partner’s Privacy Notice. Before subscribing please read the Privacy Notice of the partner as they are acting as a separate data controller and may have different processing activities and retention schedules to our own.

If you give consent to a University, you will need to contact the University directly to subsequently withdraw your consent or change your preferences. You can find out which universities you have subscribed to by accessing your profile page when you are logged in to your account.

For more details please contact us via the contact details provided in this Notice.

Market Research, Surveys and Competitions

To be able to offer you beneficial services and products, or to advise our partners on your educational preferences, we often run surveys and market research campaigns which you can choose to take part in.

The data collection, use and storage vary depending on the focus of the research. Before supplying any personal information and for more details on the research we are conducting, please read the privacy note included on each survey or survey invitation you receive from us. We currently run surveys using a 3rd party platform called Typeform.

For market research, we may engage a specialist company to conduct the research on our behalf and they may have access to your personal data. We will take all steps necessary to protect your personal data throughout the research period and either randomise it or delete it when it is no longer required.

To reward people for taking part in our surveys, market research or social media engagement campaigns we often run competitions. If you would like to take part in such a competition, we will ask you to enter an email address. We will only use this information to contact you if you are the competition winner and to arrange a prize delivery. We will delete all personal information collected as part of a competition one month following the competition closing date.

Multimedia Content

As part of multimedia production activities, IDP Connect processes personal data on the basis of consent. There are a number of instances when we may ask you to take part in a video or appear in a photograph:

Student Events (organised or attended by our team)

Video and photo materials recorded at the event are used to stream the event live and/or promote future events. Some of these events will be featured in an article published on our websites and use video and photographic material from the event.

Promotional Video Production Events (commissioned by our clients)

These videos and photographs are used to promote a specific university and highlight certain aspects of the facilities the university has to offer.

Review Videos (recorded by our review collection team or supplied by you directly)

These videos are produced to give our users an independent view of your student experience.

Each time we record a video, or take a photograph, we will ask for your consent and provide you with a form containing specific information about the filming/photoshoot event. Please read all the information before signing.

Social Media

We use social media to make our editorial content more accessible and interact with you. You can engage with us by reading, sharing and commenting on our posts. You can also share any article that has that option on your social media page. When creating a post or leaving comments on a post, please do not leave any personal details as these posts are made public and anyone can see them. Instead, if you need to ask a more specific question, please send us a private message. Private messages will be stored for one year and will not be shared with anyone outside our company.

When you log in to our websites using Facebook credentials, we will create a user account for you using your details from Facebook. This is necessary as some of the features like making an enquiry or downloading prospectuses are only available to registered users.

You can stop sharing this information with us directly from your Facebook account. Please note this will not delete the data we have already received (name, email address or profile picture).

When contacting us via social media platforms please familiarise yourself with the privacy notice of that platform.

Sharing your data with partners

We work with a range of learning providers that either advertise courses on our platforms or offer services relevant to your educational research journey.

Your personal data will only be shared with learning providers you have chosen to engage with via our websites. For example, when you make an enquiry or a prospectus request to an institution, your details relating to that enquiry will be provided to the institution so that they may answer your enquiry directly.

We also provide anonymised site usage data to providers to enable them to monitor enrolment from users who use our websites.

If you take part in one of our market research campaigns or surveys, we will never share your personal data with our partners, we only share aggregated data that cannot identify you individually.

Our data handling procedures ensure your personal data is protected through the service you receive from us. Furthermore, we have data sharing agreements in place with our partners to make sure they apply security operational and technical measures when processing your personal information.

Links to other websites

On our websites there are lots of links to course provider websites. This privacy notice does not cover these links. We encourage you to read the privacy statements on the other websites you visit.

Changes to the Privacy notice

The date of the most recent version will appear on the top of this page. From time to time we may be updating this Privacy Notice, please review it each time you are to submit personal information. If we make any significant changes to this notice we will send you an email informing you of these amendments. If you do not agree with these changes please do not use our websites to provide personal information. You can also delete your account at any time ‐ please see your rights section.

Further questions

If you have any questions or complaints regarding your personal data, please contact the Privacy Manager at the address below:

Privacy Manager IDP Connect LtdFirst Floor, Bedford House, Fulham Green 69-79 Fulham High StreetLondonSW6 3JW

privacy@idp-connect.com

If you feel the Privacy Manager has not dealt with your enquiry promptly or correctly, you have the right to complain to the ICO https://ico.org.uk/make-a-complaint/

Site specific privacy notice

The following section provides information on the collection and processing of personal data specific to the Complete University Guide website.

This site is available at www.thecompleteuniversityguide.co.uk

The site is intended for use by users aged 16 years and over. Users under this age are not allowed to create an account on the website.

You will need to register with Complete University Guide to get a full range of services such as sending enquiries, bookmarking articles, ordering prospectuses, etc. To get the most appropriate search results, advice and guidance, we strongly recommend you register and create a profile with us.

What personal data do we collect?

You can make a subject access request and view all personal data we have collected about you by contacting the Privacy Manager on the details above or by using our online contact form and selecting the option 'Request my data'.

Data collected directly

The following items of personal data are collected as part of the registration process:

• First name
• Last name
• Email address
• Country of residence
• Qualification
• Preferred subject
• Expected year of entry
• Postal address

You can update your personal data and add additional information on your profile page:

• Which describes you best? (For example, student living in the UK, student living outside the UK, parent or guardian, etc)
• When would you like to start?
• What qualification you are looking for? (Undergraduate degrees, career choices, etc)
• What do you want to study?
• Which country do you live in?
• Postcode

If you contact us using our online form, we will ask you to supply minimum information in order to respond to your enquiry. As part of this activity we will ask for:

• Your name
• Email address

If you are featured in one of our articles and/or take part in our multimedia production activities, we will ask you to supply the following information:

• Full name
• University name
• Date
• Photo/video images

Data collected indirectly

If you use the 'click to call' function to contact an institution by telephone during the clearing and adjustment period, your telephone number will be recorded within our call logging systems. The telephone number you used to call the institution will not be associated with your user profile and will be used only for statistical purposes. Anonymised data on the number and duration of calls may be shared with the relevant institution in order to measure the effectiveness of their campaigns. Your actual telephone number will not be shared or used for any other purposes beyond statistical analysis.

We collect your search history and the articles you have read. We use this information to suggest courses you may be interested in or are eligible to apply to.

IP address

Each time you access our website we will receive your IP Address. We keep this information for 3 months and use it for analytical purposes only.

Location

If you enable location you can get a list of universities located closest to you. If you enable location on your internet browser we will collect this information and use it for analytical purposes. We use location data to analyse areas where we help students engage with universities better and identify the areas where we can do more to help you go to university. All location data is collected with a proximity of 650m. If you are a registered user, we will keep your location information for three months after which we will anonymise the data and keep it for future service planning. You can disable your location services at any point by changing your browser or app settings.

University Reviews

On the Complete University Guide we show reviews collected by Whatuni.com. For details and for any subject requests, please visit Whatuni Privacy Notice.

How we process your data

While using the Complete University Guide website you can carry out the following interactions where we process your personal data:

• Create a user account
• Request a prospectus or make an enquiry to a university
• Download a PDF guide
• Initiate counselling services with our parent company, IDP Education, when the option is available
• Contact us
• Take part in a competition

We use your personal details to respond to your enquiry, i.e. create an account for you, answer your question, contact you if you are one of the draw winners or send you newsletters if you have subscribed.

We also use your personal data and search history to suggest tailored content such as posts, universities and courses that may help your journey.

Consent options

As part of the registration process or when making an enquiry, you have the choice to opt-in to the following:

• Newsletters from the Complete University Guide (latest news, tips, league tables and guides)
• University updates (updates, guides, articles, events, etc, that can help your education journey, sent by our team on behalf of third-party partners and carefully selected partners)
• Surveys (market research initiatives and competitions where you can have your say on important education issues and the services you receive from us and our partners)

In addition you can also opt in to:

• Marketing options from our partner institutions (external subscriptions where you can opt in to receive newsletters and marketing materials from your chosen universities directly)

Occasionally we may ask people to take part in an interview or to be featured in one of our articles and when we do that, we rely on your consent. Each campaign may be different, please carefully read the Privacy Notice issued with each consent form.

All consent, except for the marketing options from our partner institutions, can be withdrawn at any point by contacting the Compete University Guide Privacy Manager, or by updating your user profile online, or by clicking on the unsubscribe link available in every email you receive from us.

To withdraw your consent for marketing from one of our partner institutions, you will need to contact the institution directly. You can view which institutions you have given consent to via your profile page.

Data sharing

Your contact details are shared with education institutions for which you have made an enquiry or requested a prospectus so that they can accommodate your request directly.

If you engage with the counselling services on the Complete University Guide website, your data will be shared with our parent company, IDP Education, which operates our counselling services.

Surveys and competitions

Occasionally we run surveys and competitions which may include a free prize draw. The details of the prize will be shown on the survey form. If you wish to take part in a prize draw, in order to contact you we will collect all or some of the following personal data:

• Full name
• Email address
• Phone number (interviews only)
• Postal address (if prize is to be delivered via post)

On some occasions we may collect additional personal data, such as your location, but we will inform you in more detail on the survey form. The purpose and data retention period will also be shown on the survey form.

Your postal address may be used to validate your residency and send a prize if you are one of the winners. Any data collected as part of a competition will be deleted one month after the draw closing date.

Only authorised staff will have access to your personal information. Your personal information collected as part of a competition will not be used for any other purpose, nor be shared with any other organisation.

We may use third party applications like Typeform or Survey Monkey to collect and store your response, or a market research company to help us analyse the data we gather. For that, we will only use companies that are deemed trustworthy, ethical and comply with the GDPR.

Open days booking

On the Complete University Guide, you can search for and book university open days including virtual events. Depending on the university, you may be able to book with them directly, or when the option is available use Complete University Guide to make the booking.

If you are a new Complete University Guide user, you will need to register with us first. If you are a registered user, you can simply make the booking. There may be some additional data we will ask for as part of the booking process like mobile phone number and special requirements. Any optional data collected only as part of the booking open day process will be removed from our systems one day after the event. All other data will be stored on our system in line with our retention policy and shared with the University you wish to visit.

You can view all your bookings under the activities tab on your Complete University Guide profile page. If you need to cancel or amend any bookings you will need to contact the university directly.