HOW SRT COLLECTS PERSONAL DATA
SRT receives Personal Data directly from the Data Subject.
Personal Data may be provided to SRT by third parties as well (universities, high schools, other educational institutions, etc.)
TYPES OF PERSONAL DATA COLLECTED/PROCESSED AND PURPOSE
SRT collects the following categories of Personal Data in order to provide international study programs:
- Contact information including, without limitation, email address, phone number, number of ID and/or passport.
LAWFUL BASES FOR PROCESSING YOUR PERSONAL DATA UNDER THE GDPR
SRT needs your contact details in order provide some of the Services included on or otherwise made available to you through the Website (“Services”) (https://srtfairs.com/services/universities/ ; https://srtfairs.com/services/high-schools/ ). Where applicable, we indicate whether and why you must provide us with your Personal Data, as well as the consequences of failing to do so. If you do not provide Personal Data when requested, you may not be able to benefit from our Services if that information is necessary to provide you with the Services or if we are legally required to collect it.
We may process your personal data because it is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract. In this respect, we use your personal data for the following:
- to interact with you before you are enrolled as a student, as part of the admissions process;
- once you have enrolled, to provide you with the Services;
- to deal with any concerns or feedback you may have;
- for any other purpose for which you provide us with your Personal Data.
Apart from the abovementioned grounds, most commonly Personal Data will be processed in the following circumstances:
- Where you have given us your consent;
- In order to fulfil SRT’s obligations to you as part of a contract;
- Where SRT needs to comply with a legal obligation;
- Where it is necessary for SRT’s legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- To protect the vital interests of the Data Subject or of another person;
- In order to perform a task carried out in the public interest.
SHARING INFORMATION WITH OTHERS
SRT will not share your Personal Data with third parties except:
- as necessary to meet one of its lawful purposes, including but not limited to, its legitimate interest, contract compliance, pursuant to consent provided by the Data Subject, or as required by law;
- as necessary to protect SRT’s interests;
- with other service providers acting on SRT’s behalf who have agreed to protect the confidentiality of the Personal Data.
The Personal Data that SRT collects may be shared with: high schools, universities and other educational institutions as necessary to facilitate study abroad; partner institutions, as well as other parties as necessary to organize and administer study abroad programs.
RETENTION OF YOUR PERSONAL DATA
The GDPR requires that Personal Data should be kept for no longer than is necessary for the purposes for which the Personal Data are processed (except in certain specific and limited instances).
We take measures to delete your Personal Data or keep them in a form that does not permit identifying you when these Personal Data are no longer necessary for the purposes for which we process them, unless we are required by law to keep them for a longer period.
Subject to any other notices that we may provide to you, we may retain your personal data for a maximum period of five years after your association with us has come to an end.
INDIVIDUAL RIGHTS OF THE DATA SUBJECT UNDER THE GDPR
- Request from SRT access to and rectification or erasure of Personal Data or restriction of processing concerning the Data Subject, the right to object to processing and the right to portability of Personal Data;
- Where processing is based upon consent, to withdraw consent at any time, without affecting SRT’s right to process Personal Data based upon consent before its withdrawal;
- The right to file a complaint with a supervisory authority appointed by an EU member state for the purpose of receiving complaints;
- Additional notice of the existence of automated decision-making, including profiling;
- If the Personal Data is going to be further processed for a purpose other than that for which it was collected, then notice of the purpose and basis or bases for the further processing;
- If Personal Data is collected for SRT’s legitimate interests or for a task carried out in the public interest, then the Data Subject has the right to object, on the grounds of his or her particular situation, to the processing of Personal Data concerning him or her (including profiling);
- Where Personal Data are processed for direct marketing purposes, the right to object at any time to processing Personal Data concerning him or her for such marketing; and
- Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her; provided, however, that this right does not apply if the decision is (a) necessary for entering into, or performance of, a contract between the Data Subject and SRT; or (b) is based upon the Data Subject’s consent.
Any Data Subject who wishes to exercise any of the above-mentioned rights may do so by filling such request at email@example.com
Generally we do not knowingly collect, maintain, or use Personal Data from children under 16 years of age, and no part of the Service is directed to children under the age of 16.
Where it is necessary to collect, maintain, or use Personal Data from children under 16 years of age, for the legitimate purpose of providing Services to such a person, we do not proceed unless consent is given or authorised by the holder of parental responsibility over the child.
If you learn that your child has provided us with Personal Data without your consent, then you may alert us at firstname.lastname@example.org. If we learn that we have collected any Personal Data from children under 16, then we will promptly take steps to delete such information and terminate the child’s account.
INTERNATIONAL DATA TRANSFERS
Some of the Personal Data we process about you will be transferred to, and stored at, a destination outside the European Economic Area (“EEA”), for example where it is processed by staff operating outside the EEA who work for us or for one of our suppliers, or where personal data is processed by one of our suppliers who is based outside the EEA or who uses storage facilities outside the EEA.
In these circumstances, your Personal Data will only be transferred on one of the following bases:
- where the transfer is subject to one or more of the “appropriate safeguards” for international transfers prescribed by applicable law (e.g. standard data protection clauses adopted by the European Commission);
- a European Commission decision provides that the country or territory to which the transfer is made ensures an adequate level of protection; or
- there exists another situation where the transfer is permitted under applicable law (e.g. where we have your explicit consent).
LINKS TO OTHER WEB SITES
To help protect the privacy of data and personally identifiable information you transmit through use of this Site, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.
This policy is effective as of 24th May 2018. SRT may change this policy from time to time by updating it and publishing it on this page.