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Hotcourses Group Privacy Notice

Last updated 12 June 2018

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.

Hotcourses Limited, an IDP Education owned company, is the principle company and the Data Controller in the Hotcourses Group of companies (Hotcourses India PVT, Hotcourses Pty Ltd (Australia), Hotcourses 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
  • Recommending things 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 whether registered or not, including people responding to surveys, competitions and writing reviews.

Keeping your information safe and private is very important to us. All our services are designed with privacy and security in mind.

Collecting and using your personal data

You can browse our websites without providing any personal information. However, to use some of our enhanced functionality will 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.
  • If you are making a payment to Hotcourses or one of our partner providers, you will be asked for you card and billing details.

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, Hotcourses Insights, and the Hotcourses Enrolment Matching 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 of 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. Your IP address and location information is stored anonymously, and not associated with any other personal details. 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 or not 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 EU. We employ a range of technology and procedures to ensure that this data is secure, including where appropriate, 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 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. For example, we will retain your email address for as long as you are subscribed to one of our newsletters.

Personal data is deleted in accordance with our internal retention policy. All identifiable personal data is deleted five years following your last interaction with this website. 

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 Hotcourses Privacy Manager.

In line with the GDPR regulations, 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 you 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 to your online profile. If you need further information, you can make a Subject Access Request by contacting your Hotcourses contact or the Hotcourses 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 either through your Hotcourses contact or the Hotcourses Privacy Manager.  

The right to erasure

You have the right to be forgotten at any point by contacting the Privacy Manager or emailing delete@thecompleteuniversityguide.co.uk. 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 right 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 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 explanation when replying back 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.

Sharing your data with partners

We work with range of learning providers that advertise courses on our platforms and have agreements and procedures in place to ensure your personal data is protected through the service you receive from us.

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. 

We have data sharing agreements in place with these learning providers to make sure they apply security operational and technical measures when processing your personal information.

In the future, if all or part of the Hotcourses Group business may be sold, acquired, or merged with another business. Under these circumstances, we may share the personal data we hold with the third-parties involved.

Links to other websites

On our website 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 Hotcourses Privacy Notice details

The date of the most recent version will appear on the top of the 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 question regarding your personal data, please contact the Privacy Manager at the address below:

Privacy Manager
Hotcourses Ltd
First Floor, Bedford House, Fulham Green
69-79 Fulham High Street

privacy@hotcourses.com

If you feel we have been intrusive to your privacy or misused your data you have the right to complain to the ICO https://ico.org.uk/make-a-complaint/

IP Addresses and Cookies

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer.

What is a Cookie?

A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer browser from a website's computer and is stored on your computer's hard drive. Each website can send its own cookie to your browser if your browser's preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. Many websites do this whenever a user visits their website in order to track online traffic flows.

What Type of Cookies Do We Use?

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties, such as universities during clearing, for this purpose.

How Can Cookies be Managed/Blocked?

Users have the opportunity to set their devices to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time. The last of these means that certain personalised features cannot then be provided to that user and accordingly they may not be able to take full advantage of all of the website's features. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences. Alternatively, you may wish to visit https://www.aboutcookies.org/, which contains comprehensive information on how to do this on a wide variety of desktop browsers.

During the course of any visit to our site, the pages you see, along with a cookie, are downloaded to your computer. Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site.

Third Party Cookies

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

To find out which third party cookies are stored on your computer and possibly to remove them, please visit http://www.youronlinechoices.com/uk/ to opt out.

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. If you are under 18 years of age and want to register with Complete University Guide services, you must obtain consent from a parent or guardian. You may also discuss this privacy policy with them.

What personal data do we collect?

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

  • Full name
  • Email address
  • Expected year of entry (optional)
  • Preferred study level (optional)
  • Preferred subject (optional)
  • Country of residence (optional)

Once registered, the following additional profile fields can be completed:

  • Why you are using the site (for example, student living in the UK, student living outside the UK, parent or guardian, etc)
  • Your interests (undergraduate degrees, career choices, etc)
  • Expected year to complete studying
  • Preferred universities (up to three)
  • Preferred subjects (up to three)
  • Postal address

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 making an enquiry to a university
  • Download a PDF guide
  • Initiate counselling services with Hotcourses’ parent company IDP
  • Ask a question of the Complete University Guide HE experts

Consent options

As part of the registration process, you have the choice to opt-in to the following:

  • Newsletters from the Complete University Guide
  • Newsletters specific to league table publication from Complete University Guide
  • Clearing emails from Complete University Guide
  • University updates from third-party partners
  • Clearing course updates from third-party partners

Data sharing

Your contact details are shared with education institutions where you have made an enquiry or prospectus request to that institution. 

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