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Hotcourses Group Privacy Notice

Last updated 6 November 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?

Cookies are small text files that are placed on your computer by websites you visit. They are simple text files which can be read using the Notebook program. When you visit a site that uses cookies for the first time, a cookie is downloaded onto your computer. The next time you visit that site, your computer checks to see if it has a cookie that is relevant (that is, one containing the site name) and sends the information contained in that cookie back to the site.

The site then ’knows’ that you have been there before, and in some cases, tailors what pops up on screen to take account of that fact. For instance, it can be helpful to vary content according to whether this is your first ever visit to a site or not.

Complete University Guide puts cookies onto your computer to make your interaction with our website smother. We collect information about how you browse the website and remember your preferences. Cookies also provide us with information on the number of website visits, pages viewed, how long people stayed on the website or how they accessed our website. This helps us improve our site.

We also use targeting cookies to deliver interest-based advertising on behalf of universities and partners. This helps us to keep our service to you free. 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 statistical information with third parties, such as universities.

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.

Cookie name Purpose Life Time 
cookieconsent_dismissed Records dismissal of cookie consent banner 1 year
CUGAUTH Authentication cookie, identifies the user after a successful login  Session 

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.

Cookie name Purpose Life Time
__gads Advertising cookie from DFP for performance measurement and advert
limiting
2 years
__utma  Used to distinguish users and sessions 2 years 
__utmb

Used to determine whether a session should be counted as a new session
or a continuation

30 minutes 
__utmc Used to determine whether a session should be counted as a new session
or a continuation 
Session 
__utmt Rate limiting on logging to GA  10 minutes 
__utmz Records how a user reached the site  6 months 
__ga Used to distinguish users  2 years 
_gat_insights    Rate limiting on logging to Insights GA  1 minute 
_gat_piktov3 Rate limiting on logging to Piktochart's GA  1 minute 
_gid Used to distinguish users  1 day 

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).

Cookie name Purpose Life Time
lastSubject            Set by subject tables and profiles' "League Table Performance" page,
used to default graphs shown on performance tab to the last subject
the user viewed
30 minutes   
lastUser Encrypted email address used on the last successful login, used to
autofill login forms
30 days
noSurvey

Records dismissal of survey bars

3 months 

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.

Cookie name    Type Purpose
Admedo Targeting Ad targeting
DFP  Targeting/Performance     Ad targeting, reporting and duplication
Facebook

Social media

Browser identification and last logged in user 
Google Social media Preferences and browser/session/user identifiers 
Piktochart Strictly necessary Cloudflare security cookie
Twitter Social media GA, authorisation, preferences, browser identifiers  
Vengage Performance GA, others  
Youtube   Social media Preferences, targeting, and browser/session/user identifiers


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.

If you wish to find more information on cookies, please visit https://ico.org.uk/your-data-matters/online/cookies/ 

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. 

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. 

We will not share your data for marketing purposes with anyone. We may use third party applications like Typeform 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.

How we process your data

We will only use your name and email address to answer your question and contact you if you are one of the draw winners. Your postal address will be used to validate your residency and send a prize if you are one of the winners.

Your data will be collected and stored on our email system and it will be deleted 1 month after the draw closing date.

Only authorised staff will have access to your personal information.

Your personal information will not be used for any other purpose, nor be shared with any other organisation.