Last updated 7 June 2019
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.
IDP Connect, an IDP Education owned company, is the principle company and the Data Controller in the IDP Connect 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
- Providing advertising and promotional opportunities for education providers
- Providing features to enable users to directly contact education providers
- Recommending things which 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 we 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.
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.
- 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, IDP Connect Insights, and the IDP Connect Enrolment Matcher Tool to do this.
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.
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 UK. We employ a range of technology and procedures to ensure that this data is secure, including 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 it 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
Personal data is deleted in accordance with our internal retention policy. All identifiable personal data is deleted three years following your last interaction with this website, for users registering from within the UK, and after two years for international markets.
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 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 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 into your online profile, if you require a permanent record you can download this information in PDF format from our website. Alternatively you can make an offline Subject Access Request by contacting the 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 through the Privacy Manager.
The right to erasure
You have the right to be forgotten at any point by contacting the Privacy Manager or emailing email@example.com. 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 rights 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 by updating your profile in the application or by 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.
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 the Privacy Notice
The date of the most recent version will appear on the top of this page. From time to time we may update 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
If you have any questions or complaints regarding your personal data, please contact the Privacy Manager at the address below:
First Floor, Bedford House, Fulham Green
69–79 Fulham High Street
If you feel the Privacy Manager has not dealt with your enquiry promptly or correctly, you have the right to complain to the ICO https://ico.org.uk/make-a-complaint/
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 are cookies?
Cookies are small text files placed on to your computer by the websites you visit. They help improve your experience and allow website-owners to analyse visits.
We use retargeting services on behalf of education institutions partners to show you advertising that you may be interested in, based on your interactions on our sites. When you are visiting other websites, such as a news service, you may see one of these ads.
Retargeting works by analysing the areas you look at online – such as course subjects or university locations – and creating targeted online advertising campaigns on behalf of our advertising clients. The content of the adverts will specifically support your educational journey, with a particular focus on the types of subjects and institutions which you have previously viewed on our websites.
Cookies and Smart Pixel technologies support our retargeting services which are delivered via partners such as Admedo, Adroll, Facebook and Instagram.
How can cookies be managed/blocked?
You can set your device to accept all cookies, to notify you when a cookie is issued, or not to receive cookies at all. If you choose not to receive cookies you may not be able to take full advantage of the website's features and we may not be able to personalise your experience on site. Each internet browser is different, so check the ‘Help’ menu of your browser to find out how to change your cookie preferences. More information on cookies is available from the Information Commissioner’s Office https://ico.org.uk/your-data-matters/online/cookies/
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|
These cookies allow us to recognise and count the number of visitors to our sites and see how users move around the sites. This information helps us to improve our websites, for example, by ensuring that users can easily find what they are looking for.
|Cookie name||Purpose||Life Time|
|__gads||Advertising cookie from DFP for performance measurement and advert
|__utma||Used to distinguish users and sessions||2 years|
Used to determine whether a session should be counted as a new session
|__utmc||Used to determine whether a session should be counted as a new session
or a continuation
|__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|
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
|lastUser||Encrypted email address used on the last successful login, used to
autofill login forms
Records dismissal of survey bars
Third party cookies
|DFP||Targeting/Performance||Ad targeting, reporting and duplication|
|Browser identification and last logged in user|
|Social media||Preferences and browser/session/user identifiers|
|Piktochart||Strictly necessary||Cloudflare security cookie|
|Social media||GA, authorisation, preferences, browser identifiers|
|Youtube||Social media||Preferences, targeting, and browser/session/user identifiers|
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
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 our parent company, IDP
- Ask a question of the Complete University Guide HE experts
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
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 our parent company, IDP, which operates our physical counselling services.
Contacting institutions by telephone
At certain times, we offer the ability for you to contact institutions directly by telephone, using a dedicated 0333 number provided by our telecommunications partner, Telecoms World. The telephone number you are calling from and the duration of the call are recorded with Telecoms World. Anonymised data on the number and duration of calls may be shared with the relevant institution in order to measure the effectiveness of their campaigns. Your actual telephone number will not be shared or used for any other purposes beyond statistical analysis.
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.
Next page: Acceptable Use Policy