Privacy Policy

This Privacy Policy was last updated on 24 June 2024.

Table of Contents:

1.   Who we are

2.   Information we collect

3.   Why we collect your data

4.   How this data helps us

5.   How we use your data

6.   Rights and choices

7.   Third-party links

8.   Cookies Policy

9.   How we retain and store your data

10. Disclosure information

11. Automated Decision-Making and Profiling

12. Conclusion

1.   Who we are?

Company legal name – Veritas Mundi Education Ltd.

Company address – 9, The Timms, Stanford in the Vale, Faringdon, SN7 8FX, UK

Privacy queries email – info@veritas-mundi.com

Named DPO – in lieu of a designated Data Protection Officer, our organisation has appointed Dr. Dhara Malavia-Jones, who is responsible for overseeing our data protection strategies and ensuring compliance with data protection laws. Dhara serves as the primary point of contact for any inquiries or concerns related to data privacy and security. Their role includes monitoring our compliance with data protection laws, overseeing data protection training and audits, and managing responses to data breaches or data access requests

2.   Information we collect about you

Listed below are the types of data we may handle:

a.   Views and Opinions: for example, survey responses and testimonials, enquiries, requests, complaints.

b.   Operational Data: for example, details of complaints and issues, completed tasks, disciplinary actions, contractual information.

c.   Technical Identification (IT): for example, usernames, passwords (internal staff directory).

d.   Aggregated or Analytical Data: This refers to data that may include statistical or demographic information. Although Aggregated Data may originate from your personal data, it is not considered personal data under the law because it does not reveal your identity either directly or indirectly. However, should we combine or link Aggregated Data with your personal data in a way that could potentially identify you, this combined data will be treated as personal data and will be handled according to this privacy policy.

e.   Contact Details: for example, name, email address, phone number, postal address.

f.   Financial Information: for example, billing address, credit card number, bank account details.

g.   Family and familial connections: for example emergency contact, marital status, next of kin.

h.   Location Data: for example, postal address, country of residence, country of birth

i.   Communications Data: for example, WhatsApp messaging data, social media posts and messages.

j.   Identification and Legal Documents: for example, passport, proof of residence, national identification card.

k.   Social media Activity: for example, interests, tagged media.

l.   Personal Information: for example, nationality, gender, date of birth, CV, academic qualifications, employment history, faculty and staff data.

m.   Images and Recordings: for example, photos, videos.

3.   Why we collect your data

3.1 Enhancing our agent training: We gather data to evaluate and improve the training we offer to our agent counsellors. This involves assessing the effectiveness of current training methodologies and identifying areas that require enhancement to boost recruitment efficiency and outcomes.

3.2 Developing and evaluating resources: By collecting feedback on the utility of training resources and tools provided to recruitment agents, we aim to refine these resources, making them more effective for the needs of the wider education community.

3.3 Optimising our recruitment strategies: Feedback on the performance of agents helps us tailor our recruitment strategies that are aligned with the unique demands of higher education institutions, ensuring they attract suitable student candidates.

3.4 Student counselling for studying abroad: Data collected from students and educational institutions aids in tailoring our counselling services to better assist students in making informed decisions about studying abroad. Importantly, this information can also help strengthen our relationship with our university partners. This includes matching students with suitable programmes and universities that meet their academic and personal aspirations.

3.5 Building strategic partnerships: We utilize data to foster strategic partnerships with universities and various education service providers. This helps universities expand their reach, enhance their offerings, and meet their strategic goals more effectively.

4.   How your data helps us

4.1 Service Improvement: The insights gained from the data are directly applied to enhance the range of services we offer to universities, including student recruitment and strategic partnerships.

4.2 Enhancing and Expanding Services: The data we collect plays a crucial role in the ongoing development and enhancement of our services. By analysing the information gathered from universities, students, and our strategic partners, we are able to identify key areas where our services can be improved and new opportunities where they can be expanded.

4.3 Personalized Solutions: Based on comprehensive data analysis, we provide customised recommendations to universities and students, ensuring that our solutions are appropriately aligned with their specific needs and objectives.

4.4 Policy Development: Data we collect from surveys and engagements also informs policy development and strategic decision-making, helping us navigate the complexities of international student recruitment, agent accreditations, and partnerships.

By understanding and addressing the specific needs of both students and educational institutions, we ensure that our services not only meet but exceed the expectations of all stakeholders involved.

5.   How we use your data

We will use your personal data only when permitted by law. Typically, we use your personal data under the following circumstances:

5.1 Performance of Contract: This involves processing your data as necessary to fulfill a contract you are part of, or to take actions at your request before entering a contract.

5.2 Legitimate Interests: This means we process your data when it is necessary for the legitimate interests of our business, such as providing you with the best possible service and ensuring a secure experience. Under such circumstances, we will use your information, so long as this is not overridden by your own rights and interests. Examples of legitimate interests include (but are not limited to):

a.   Non-Personal Data Use: We may utilise your non-personal data for analysing traffic patterns on our website, understanding customer demographics and interests, and improving the services we offer. This data also helps in our marketing and promotional efforts.

b.   Marketing Emails: The basis for sending you marketing emails may be either your consent or our legitimate interests. We use your data to send emails about relevant topics, company news, upcoming training, and potential products or services from us or our partners that might interest you. We also analyse how these emails perform to enhance our marketing strategies.

We never sell, rent, or trade our email lists with other companies.

c.    Social Media Platforms: Interactions on social media platforms are governed by the privacy policies of each platform. We encourage you to handle your personal information carefully on social media and to discuss sensitive matters through direct communication channels like phone or email.

d.   Promotional Offers: We may use various data types like Identity, Contact, Technical, and Usage data to tailor our promotional offers that align with your interests. You will receive these communications if you've requested information or bought services from us unless you opt out.

5.3 Change of Purpose: We will only use your personal data for the original purposes we collected it for unless we reasonably believe another use is necessary and compatible with the original purpose. If it's needed, we'll explain how the new purpose is compatible. Should we need to use your personal data for an unrelated purpose, we will inform you and explain the applicable legal basis. Where required by law, we will seek your consent to use your personal data for a new purpose.

5.4 Compliance with Legal Obligations: We process your personal data as required by the UK General Data Protection Act 2018.

5.5 Consent: By using our site and services, you have given clear consent for us to process your personal data for a specified purpose or purposes listed in this privacy policy. We also rely on explicit consent for marketing and communication (e.g. emails, newsletters or updates), surveys and questionnaires. However, we may process your personal data without your consent in compliance with legal requirements, when necessary.

6.   Rights and Choices

You have the right to:

6.1 Access your personal data through an access request, which can be made in writing on the email provided above. This allows you to obtain a copy of the personal data we have about you and verify that we are processing it lawfully.

6.2 Correct any personal data we hold about you. This helps you to rectify any data that is incomplete or inaccurate, although we may need to check the accuracy of the new data you provide.

6.3 Erase your personal data. This right lets you request the deletion or removal of your personal data when there is no valid reason for us to continue processing it. You can also request deletion of your personal data if you have exercised your right to object to processing and we have processed your information unlawfully, or if we need to comply with a legal requirement. However, there are specific legal reasons that might prevent us from fulfilling this request, which we will explain if relevant.

6.4 Object to the processing of your personal data based on our legitimate interests (or those of a third party) if something about your situation makes you oppose this processing, especially if you believe it affects your fundamental rights and freedoms. You can also object to the processing of your data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds for processing that override your rights and freedoms.

6.5 Restrict the processing of your personal data. This allows you to request that we suspend processing of your data under certain conditions:

• To verify its accuracy.
• When the processing is unlawful, and you oppose its erasure.
• When you need us to keep the data for legal claims, even if we no longer need it for processing.
• If you have objected to our use of your data and we are verifying whether our legitimate grounds override yours.

6.6 Transfer your personal data to you or a third party. We will provide your data in a structured, commonly used, machine-readable format. This right applies only to automated information that you initially consented to us using or that we used in performing a contract with you.

6.7 Withdraw your consent at any time where we rely on consent to process your personal data. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted in reliance on lawful processing grounds other than consent. If you withdraw your consent, we might not be able to provide certain products or services, and we will advise you if this is the case.

You also have the right to lodge a complaint with the appropriate regulator at any time.

You will not be charged a fee to access your personal data or exercise any of your other rights unless your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request under these circumstances.

To confirm your identity and ensure your right to access your data, we may need to request specific information from you as a security measure to prevent data disclosure to unauthorized parties. We might also contact you to ask for more information about your request to help us respond quickly.

We aim to respond to all legitimate requests within one month. However, if your request is particularly complex or you have made multiple requests, it may take longer than a month. We will notify you and keep you updated if this is the case.

7.   Third-Party Links

Our website and surveys contain links to external websites, plugins, and applications owned by third parties. Interacting with these links or enabling these connections could allow third parties to collect or share your information. We do not have authority over these external sites and cannot be held accountable for their privacy practices. We recommend that you review the privacy policies of any website you visit after leaving ours.

8.   Cookies Policy

8.1 Cookies are small text files that are placed on your device (such as your computer, smartphone, or tablet) when you visit a website. They are widely used to make websites work more efficiently and to provide information to website owners.

8.2 We use cookies for various purposes. The types of cookies we use include:

a.   Essential Cookies: These cookies are necessary for the operation of our Website. They enable you to navigate through the Website and use its features.

b.   Analytics Cookies: We use analytics cookies to collect information about how you interact with our Website. This helps us improve the Website's performance and your user experience. These cookies may collect information such as your IP address, browser type, operating system, referral source, the pages you viewed, and the time and date of your visit.

c.    Functional Cookies: Functional cookies allow us to remember choices you make on the Website (such as your preferred language) and provide enhanced, more personalised features.

d.   Third-Party Cookies: Some of our pages may contain content and services from third-party providers (such as social media sharing buttons or embedded videos). These third parties may use cookies to collect information about your interaction with their content. We have no control over these cookies and recommend reviewing the privacy policies of the respective third parties.

8.3 You can manage your cookie preferences by clicking the Consent Button. This will let you revisit the cookie consent banner and change your preferences or withdraw your consent immediately.

In addition to this, different browsers provide different methods to block and delete cookies used by websites. You can change the settings of your browser to block/delete the cookies. Listed below are the links to the support documents on how to manage and delete cookies from the major web browsers:

• Chrome
• Safari
• Firefox
• Internet Explorer

If you are using any other web browser, please visit your browser’s official support documents.

Please be aware that if you disable cookies, some features of our Website may not function correctly, and your user experience may be affected.

8.4 We may update our Cookie Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. Please revisit this page regularly to stay informed about our use of cookies.

9.   How we retain and store your data

9.1 Purpose of Data Retention: The data we collect is retained to provide ongoing services, comply with our legal obligations, resolve disputes, and enforce our agreements. This includes but is not limited to data collected through surveys, testimonials, student counselling, and strategic partnerships. For more information on the types of data we collect, refer to section 2.0

9.2 Retention Period: The specific duration for which we retain your data depends on the nature of the data and the reasons for which it is processed. Generally, personal data is retained for the duration of the relevant business relationship or agreement. For example:

a.   Survey Data: Retained for a period of up to two years after the last interaction to allow for analysis and reporting.

b.   Student Counselling Data: Kept for the duration of the student’s application process plus an additional two years to provide ongoing support and maintain records for potential follow-up services.

c.    Partnership data: Maintained for the length of the partnership and an additional five years post-termination to address any late-arising issues or inquiries.

9.3 Legal Compliance: We regularly review our retention periods to ensure compliance with the Data Protection Act 2018. Where mandated by law, some data may be kept for longer periods, particularly data related to financial transactions, which are kept for a minimum of seven years for tax and accounting purposes.

9.4 Data Disposal: Upon the expiry of the data retention period, personal data is securely deleted or destroyed to prevent unauthorised access and use. We use industry-standard methods to delete or de-identify your information securely.

9.5 Review and Adjustment: Our data retention practices are regularly reviewed to ensure they comply with our policies and relevant legal requirements. Adjustments are made as necessary to respond to changes in our business needs, new legal requirements, and technical advancements.

10. Disclosing Your Information

We disclose personal information only under specific conditions:

10.1 To Service Providers: We engage third-party service providers to perform tasks on our behalf, such as data analysis, processing, and storage services. These providers are carefully selected and obligated to use personal data solely to administer the services they provide to us and are bound by confidentiality agreements.

10.2 For Legal Requirements: We may disclose personal information if required by law, such as in compliance with a court order, subpoena, or other legal process. In such cases, we disclose information only to the extent necessary to fulfil the legal requirement.

10.3 Strategic Partnerships: With your consent, we may share data with strategic partners who work with us to provide educational services. These disclosures involve data that helps partners deliver coordinated services that benefit the universities and students we serve.

10.4 Merger, Sale, or Acquisition: In the event that we are involved in a merger, acquisition, or sale of all or a portion of our assets, personal data may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

10.5 Ensuring Security and Compliance: All data disclosures are conducted in accordance with our Data Protection Policy, ensuring that the information is handled securely and with the utmost care. We review our data disclosure practices regularly to ensure they align with current laws and our ethical standards.

11. Automated Decision-Making and Profiling

11.1 Automated Decision-Making refers to decisions made without human intervention, using algorithmic models or calculations typically based on input data. Profiling involves the automated processing of personal data to evaluate certain personal aspects relating to a natural person, particularly to analyse or predict aspects concerning staff performance, economic situation, health, personal preferences, interests, reliability, behaviour, location, or movements.

11.2  Veritas Mundi Education may utilise automated decision-making and profiling to enhance our educational consultancy services, including:

a.   Student Recruitment and Counselling: Algorithms may be used to match students with appropriate universities and courses based on their academic records and preferences.

b.   Risk Assessment: In certain cases, automated decision-making is employed for compliance and risk management purposes, such as detecting and preventing fraud in admissions or financial aid.

c.    Marketing and Personalisation: Profiling may be used to tailor marketing communications to the needs and interests of potential clients or educational institutions based on collected data.

d.   Data Aggregation and Analysis: In the context of automated decision-making, we gather and analyse comprehensive data sets to support our algorithms and profiling activities. This process involves compiling data from various sources, which is then systematically analysed to discern patterns and insights. This analytical approach ensures that our automated systems operate on well-founded, robust data, enhancing their accuracy and effectiveness in decision-making tasks.

11.3 To ensure fairness and transparency in the use of automated decision-making and profiling, the following safeguards are implemented:

a.   Human Intervention: You have the right to request human intervention, to express your point of view, and to contest decisions made solely based on automated processing.

b.   Accuracy and Security: We ensure that personal data used for automated decisions and profiling is accurate and kept secure to prevent unauthorised access or data breaches.

c.    Limitation and Justification: The use of automated decision-making and profiling is limited to the purposes for which they are truly necessary. We continually evaluate the effectiveness and fairness of our processing activities.

11.4  This policy will be reviewed and updated regularly to ensure it remains compliant with legal standards and best practices in data protection. Changes to our automated decision-making and profiling practices will be communicated to affected individuals through updates to this policy.

For further information about our use of automated decision-making and profiling, or to exercise your rights as described, please contact us at info@veritas-mundi.com.

We recognise the importance of your privacy and are committed to maintaining the trust you place in us by implementing robust security measures and maintaining transparency in our data-handling practices. We encourage all stakeholders to understand their rights under this policy and to contact us with any questions or concerns regarding our data processing practices.

We are dedicated to continuous improvement in our data protection efforts. We will regularly review and update our policies and practices to adapt to new challenges and changes in regulatory requirements. This ongoing commitment ensures that we continue to meet the highest standards of data protection and maintain the integrity and trust required to fulfil our mission of providing exceptional educational consultancy services.

For any further information or clarification regarding our Data Protection Policy, please do not hesitate to reach out to us at the contact details provided in this document. Your privacy, trust, and confidence in our services are of utmost importance to us, and we strive to uphold these values in every aspect of our operations.