Last modified: 9 May 2021
Protecting your data, privacy and personal information is very important to Unibuddy Limited, registered in England and Wales, having its registered office address at Third Floor, 20 Old Bailey, London, United Kingdom, EC4M 7AN, and registered in the USA, having its registered office at Corporation Trust Center, 1209 Orange Street, in the City of Wilmington, County of New Castle, Delaware 19801 (“our”, “us” or “we” or “Unibuddy”
(our “Website”) or using any of the services offered via the Website, such as the Unibuddy widget on a University website or the Unibuddy Mobile App (the “Platform”)
. You will be asked to indicate you acknowledge and consent to the practices described in this policy that set out the basis on which the Personal Data is collected from you, or that you provide to us will be processed by us.
“End User” means any category of individual that has access to or engages with the Unibuddy Platform including but not limited to Prospective Students, Students, Student Ambassadors, administrators and other Customer employees.
“Consumer” student, student ambassador, any user and job applicant
“Controller” has the meaning under the GDPR. Where indicated “Controller” also refers to a “Business” under the CCPA.
“Customer” has the meaning of any University or/and Higher education provider (“Customer”).
“Partner” means a third party that hosts the Unibuddy widget on their website.
“Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations (collectively the “Data Protection Laws”).
“Prospective Student” (“Student”) means any user willing to explore educational opportunities with a Customer.
“Student” (“Student”) means any user that is already studying in university or higher education.
“Student Ambassador” (“Ambassador”) means a person acting on behalf of a Unibuddy Customer as its representative and interacts with Prospective Students.
“Unibuddy Events” means a feature of the Platform that enables the hosting of multiple chat channels and sequential live streams in a conference configuration.
“Unibuddy Live” means a feature of the Platform that enables the Customer to stream video content over the internet to recipients that have a Unibuddy account.
For the purpose of the General Data Protection Regulation (the “GDPR”) and the California Consumer Privacy Act of 2018 (the “CCPA”):
Platform and Website Users
Where you are using your Unibuddy account or Unibuddy Platform directly, Unibuddy acts as the “Data Controller” of such personal Data (as defined in the GDPR) or “Business” (as defined under the CCPA)
and in such occasions, for some of our Products, we act as a Joint Controller, together with the Customer.
In respect of the Personal Data of End Users/Consumers (students and student ambassadors), whereby the users are accessing the Platform via the Customer, the Customer is the Data Controller. Unibuddy shall process personal information as a Data Processor on behalf of the Customer, who uses our services (see “Information We Receive from Other Sources” below). For all respective occasions above we ensure that we comply with existing Data Protection Laws.
In respect of Personal Data of individuals/consumers collected where you apply for a role at Unibuddy, we will be the Data Controller and certain aspects of this Policy will apply to our processing of your personal information.
Minimum User Age
Our Platform is only intended for use by persons above the age of consent in their respective jurisdiction. End Users are required to submit their date of birth for age verification purposes. Where there is a justifiable reason to use the Platform below the relevant age of consent, parental consent will be required for such use.
How to contact us
Where Unibuddy acts as a Processor, please contact the Controller/Business party in the first instance to address your rights with respect to such data.
1. HOW INFORMATION IS PROVIDED TO US
You will be asked to provide us with your information when you:
- fill in forms on our Website, Platform, or correspond with us by phone, email or otherwise;
- register to use our Platform (creating a Unibuddy account);
- use the Platform;
- report a problem with our Platform; or
- complete any surveys we ask you to fill in (although you do not have to respond to these if you do not want to).
Where you enter any details relating to a Third party, you must have obtained clear permission from the individuals whose data you provide us with before sharing that data with us.
2. INFORMATION WE COLLECT ABOUT YOU
Unibuddy acting as a Data Controller or Joint Controller
In respect of all End Users, with regard to each of your visits to our Website or use of the Unibuddy Platform, we may automatically collect the following information:
- device-specific information, such as your hardware model, operating system version, unique device identifiers, and mobile network information;
- technical information about your computer, including where available, your IP address, operating system and browser type, for system administration and analytical purposes; and
- details of your visits to our Website, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time), length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs), details of whether you are using the Website or the Unibuddy Platform.
In respect of End Users of the Platform we collect the following types of information and Unibuddy acts as a Data Controller of such Personal Data:
- Contact information such as names and email addresses;
In addition, Customers may request that Unibuddy collect certain additional Personal Data from Prospective Students in which case Unibuddy acts as a Joint Controller of such Personal Data. Such Personal Data may include but is not limited to:
- Additional contact information such as telephone numbers or addresses;
- IP address;
- Country of origin;
- Field of study;
- Personal interests;
- Education level; or
- Any other relevant Personal Data requested by the Customer;
Unibuddy acting as a Processor
Where Customers provide Personal Data of their End Users, such as Student Ambassadors or Students, Unibuddy acts as a Processor of such Personal Data. Such Personal Data may include but is not limited to:
- Contact information such as telephone numbers or addresses;
- IP address;
- Country of origin;
- Field of study;
- Personal interests;
- Education level;
- Any relevant Personal Data collected and provided by the Customer; or
- Any other Personal Data, including conversation data, voluntarily provided by End Users through the use of the Platform services including but not limited to the widget, Unibuddy Live and Unibuddy Events;
3. INFORMATION WE RECEIVE FROM OTHER SOURCES
When using our Platform, we will be in contact with third parties who may provide us with certain information about you in order to enable your use of the Platform:
- Customers. In relation to Student Ambassadors and other Customer employees, Unibuddy receives the Personal Data as set out below to enable Customer’s End Users to access the Unibuddy Platform.
- Service providers. For example, we may use analytics service providers to analyze how you interact and engage with the Platform, or third parties may help us provide you with customer support.
- Social networks connected to the services. If you provide your social network account credentials to us via the bio field or otherwise sign in to the Platform through a third-party site or service, you understand some content and/or information in those accounts may be transmitted into your Account with us.
- Partners. If you sign up to access Unibuddy through a third party partner website, Unibuddy and/or our partner may indicate that certain data will be shared with that third party.
4. HOW WE USE YOUR INFORMATION AND JUSTIFICATION OF USE
- Consent: where you have consented to the use of your information (you are providing explicit, informed, freely given consent, in relation to any such use and may withdraw your consent in the circumstance detailed below by notifying Us or the Customer);
- Contract performance: where your information is necessary to enter into or perform a contract with you;
- Legal obligation: where we need to use your information to comply with legal obligations;
- Legitimate interests: where we use your information to achieve the University’s legitimate interest and the reasons for using it outweigh any prejudice to your data protection rights; and
- Legal claims: where your information is necessary to defend, prosecute or make a claim against you or a third party.
In respect of the use of the Platform, Unibuddy (whether acting as Controller, Joint Controller or Processor) uses information held about you (and information about others that you have provided us with) in the following ways: