Effective Date: 23 November 2020
At EDU, a brand of Digital Education Holdings Limited, Villa Bighi, Chaplain’s House, Triq il-Marina, Kalkara KKR 1320, Republic of Malta (hereinafter “EDU”), we are committed to protecting the privacy of your personal data. This document sets out what data is collected, how it is processed and how it may be shared with third parties.
We take the protection of personal data very seriously, and comply strictly with the rules of data protection law, in particular the Maltese Data Protection Act (Act XX of 2018) and the General Data Protection Regulation (hereinafter “GDPR”). Our service will only collect personal data to the extent to which this is technically or contractually required or if the User has given his/her expressed consent.
- DATA PROCESSING ACTIVITIES WHEN VISITING OUR WEBSITE
- DATA COLLECTION FOR APPLICATION PURPOSES
- DATA COLLECTION FOR RECRUITMENT PURPOSES
- CONTACTING US
- ACCESS TO YOUR PERSONAL DATA
- DATA ERASUURE AND STORAGE PERIOD
- YOUR RIGHTS
- FINAL PROVISIONS
The person responsible (“Controller”) within the meaning of the GDPR is the natural or legal person which, alone or jointly with others, determines the purposes and means of the processing of personal data. The Controller, within the meaning of the GDPR for the personal data processed by this web site, is Digital Education Holdings Limited, Villa Bighi, Chaplain‘s House, Triq il-Marina, Kalkara, KKR 1320, Malta, telephone +356 2169 5955, e-mail firstname.lastname@example.org (hereinafter “we”).
- DATA PROCESSING ACTIVITIES WHEN VISITING OUR WEBSITE
When you visit our website, our server collects the following information from your device: browser type and version, operating system used, the previously visited web page, IP address and time of the page view.
We collect and process this data in order to ensure the trouble-free operation of our website and to detect, fend off and take any action to stop misuse of our services. Furthermore, we use the collected data for statistical purposes to evaluate, for example, by which devices and browsers our web site is accessed in order to improve and adapt our offer to our visitors’ needs on an ongoing basis.
This data processing is based on Article 6 par. 1 f GDPR. We will delete the afore-mentioned data no later than twelve months after they have been collected.
- DATA COLLECTION for application purposes
On our website, you can apply online for admission to our range of courses. To apply, it is necessary that you provide us with the following data:
- your first and last name;
- your gender;
- your name at birth;
- date and place of birth;
- contact details;
- proficiency in the use of English and German.
We need your first and last name, your gender, your birth name, your date and place of birth and your nationality to verify your identity without any doubt. We will use this information as the basis for your future participation in courses, practical training and certification. The date of birth is also used to determine whether you will be at least 18 years of age when you start your studies. The legal basis for processing these data is Article 6 par. 1 lit. b GDPR.
We need your address to send you further information regarding the application process or your studies, especially information that we can only send by post. We need your contact details to be able to exchange information with you at short notice, particularly for clarifying any questions in the application process. With your e-mail, you will also have access to your user account on our website. The legal basis for processing these data is Article 6 par. 1 lit. b GDPR.
We need the information on your language skills to decide in your suitability for the course of study you are interested in. The legal basis for processing these data is Article 6 par. 1 lit. b GDPR.
Furthermore, we collect information about your previous experiences (certificates, degrees, work experience, etc.) and relevant documents (graduation diploma(s), passport, letter of motivation, etc.) to process your application. The legal basis for processing these data is Article 6 par. 1 lit. b GDPR.
To process your application it is necessary that we receive all the above-mentioned data from you. The necessity of providing this data arises, among other things, from our study regulations and other regulations governing educational institutions. Without this data it is impossible to enter into contractual relations with us.
If you provide further information on our website on a voluntary basis, we will also process this information as part of your application process. The legal basis for processing these data is Article 6 par. 1 lit. b GDPR.
We keep the personal data associated with the user account stored until all contractual relationships between you and us have been conclusively settled and the respective applicable tax, commercial and other statutory law retention periods have expired.
When deciding on the success of applications, we neither use automated decision making nor profiling.
- DATA COLLECTION for RECRUITMENT purposes
In practical terms, candidates can apply for a position with EDU via an online application system. Candidates can apply either for a specific vacancy or for a position through the open applicant pool. Application information may be stored in the databases of our third-party service providers which may also be located outside the European Economic Area (EEA). Nevertheless, your personal data will be used solely by DEH Group and will not be disclosed or sold to third parties, except in the event that your data may need to be disclosed to a third party as indicated above.
Your information will be used by one or more companies within the DEH Group to assess your application, check references, verify your information and carry out credit, security and other background checks and, potentially, to contact you about a position. If you are employed, your information may also be used for employment administration purposes.
The personal data of any candidate will generally be kept for up to one year after the last update performed by a candidate. This also applies If you give your preference for a particular job. All candidates are encouraged to update their data when appropriate.
- CONTACTING US
If you send us a message by e-mail, we will save your message along with the sender details (your name, e-mail address, and any additional information added by your e-mail programme) in order to be able to answer it and also to respond to possible subsequent questions. For reception, storage and sending of e-mails, we use an e-mail provider who acts for us as a processor in accordance with Article 28 GDPR.
This data processing is based on our legitimate interest to answer your request and handle possible follow-up requests from you (Article 6 par. 1 f GDPR). We will erase the information collected from your message no later than twelve months after the last communication with you on your request, subject to the provision in the following paragraph.
If you provide us with a legally relevant declaration on an existing contractual relationship with us, the legal basis for the processing, irrespective of the means of transmission, is also Article 6 par. 1 lit. b GDPR. In such a case, we will delete the data associated with your declaration as soon as all mutual claims from the contractual relationship have been finally settled and the respective applicable tax, commercial and statutory retention periods have expired.
When you visit our shop, we place a cookie on your device. This is a small text file that we use to recognise your device when you return to our shop for a later visit.
With the help of the cookie we can also analyse certain user behaviour, e.g. which products you are looking at, how long you stay on our site and when and how often you return to our shop. We will delete a cookie no later than twelve months after your last visit to our shop.
This data processing is carried out on the basis of our legitimate interest to align our product range better to the wishes of our shop visitors and to optimise the shop functions and the efficiency of advertising measures (legal basis: Article 6 par. 1 f GDPR).
- ACCESS TO YOUR Personal Data
We do not share your personal data with strangers. personal data about you is in some cases provided to our trusted partners in order either to make providing the service to you possible or to enhance your customer experience. We share your data with:
- Google Hosting;
- Cloudways Hosting;
- Google Analytics;
- Google Tag Manager;
- Facebook Pixel;
- Hubspot Chat;
- Aquity Scheduling/Square Space;
The purpose for using the above listed third parties is given in the paragraphs below. Please note that the service providers referenced by an asterisk (*) are more likely than others to transfer personal data to territories outside the EEA. We may need to transfer your personal information outside of the EEA to provide you with the services and products you require or as necessary for our legitimate interests. This will most likely occur when our third-party providers are based outside the EEA. We always strive to select third-party providers with appropriate safeguards in place in conformity with EU law to ensure the confidentiality and security of your personal information.
In particular, where it is anticipated that data may be transferred or processed outside the EEA, we strive to ensure that the relevant applicable Standard Contractual Clauses are in conformity with the European Commission’s decisions 2001/497/EC, 2004/915/EC and 2010/87/EC with regard to data transfers to controllers and processors outside the EEA. We further actively encourage users to refer to the privacy policies of the third parties with whom we interact and to seek advice whenever necessary.
We use Google Analytics, a web analytics service of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (hereafter “Google”).
Google places a cookie on your device. With this cookie, Google can collect information about how you use our website. This information is transmitted to a server in the US, where it is evaluated by Google and made available to us. The legal basis is Article 6 par. 1f GDPR, namely our legitimate interest in the evaluation and optimisation of our internet site.
We use Google Analytics with activated IP anonymisation. This means that your IP address will usually be shortened within the geographic scope of the GDPR so that the IP can no longer be traced back to you. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there. The IP address provided by your browser will not be merged with other data provided by Google.
Google Tag Manager*
This website uses the services of MailChimp for sending newsletters and the analysis of advertising campaigns. The provider is Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.
MailChimp is a service with which, among other things, the dispatch of newsletters can be organised and analysed. If you enter data for the purpose of newsletter subscription (e.g. e-mail address), it will be stored on MailChimp’s servers in the USA.
MailChimp allows us to analyse our advertising campaigns. Among other things, it can be determined whether a message has been opened and which links have been clicked. We also collect technical information (e.g. time of retrieval, IP address, browser type and operating system). This information cannot be assigned to the respective recipient. It is used exclusively for statistical analysis of campaigns. The results of these analyses can be used to adapt future campaigns to the interests of the recipients better.
Data processing is based on your consent (Art. 6 para. 1 lit. a DSGVO) or our legitimate interests (Art. 6 para. 1 lit. f DSGVO) to improve our offers. You can revoke this consent at any time. The legality of the data processing operations that have already taken place remains unaffected by the revocation.
The data stored by you with us for the purpose of newsletter subscription will be stored by us until you unsubscribe from the newsletter and will be deleted both from our servers and from the servers of MailChimp after unsubscribing from the newsletter. Data stored by us for other purposes (e.g. e-mail addresses for the member area) remain unaffected by this.
To run online interviews, EDU uses the video conference tool appear.in, a service of Video Communication Services AS, Gate 1 no. 101, 6700 Måløy, Norway (“Appear.in”). With your participation in the admissions process, you agree that we share your personal data (e.g. your name and e-mail address) with Appear.in to operate the online classroom. You can revoke your consent at any time by, for example, sending an e-mail to email@example.com.
- DATA ERASURE AND STORAGE PERIOD
The data we store shall be deleted as soon as it is no longer needed for the purposes for which it is being stored and the law does not prescribe a statutory duty for the data to be retained. In the event that user data is not deleted on the grounds that it is still required for other or legally admissible reasons, its processing shall be restricted. This means that the data shall be blocked and shall not be processed for other purposes. This applies, for instance, for user data that has to be kept for reasons pertaining to trade or tax law.
In accordance with the pertinent legal provisions, such data shall be stored for 6 years (commercial books, inventories, opening balance sheets, annual financial statements, trade letters, accounting records, etc.) and 10 years (accounts, records, situation reports, accounting records, trade or business letters, documents relevant for taxation, etc.).
- Your rights
With regard to your personal data we process, you have the following rights:
- You have the right to obtain a confirmation from us as to whether we process personal data concerning you. If this is the case, we will inform you about the personal data stored about you and the further information in accordance with Article 15 par. 1 and 2 GDPR.
- You have the right to have your inaccurate personal data rectified without undue delay. Taking into account the purposes of processing, you also have the right to request the completion of incomplete personal data, including by means of providing a supplementary statement.
- You can demand the erasure of your personal data concerning you under the conditions of Article 17 par. 1 GDPR without undue delay, as far as their processing is not necessary according to Article 17 par. 3 GDPR.
- You may demand that we restrict the processing of your data if one of the requirements of Article 18 par. 1 GDPR applies. In particular, you can request restriction instead of erasure.
- We will communicate any rectification or erasure of your personal data and a restriction of processing to all recipients to whom we have disclosed your personal data unless this proves impossible or involves a disproportionate effort. We will also inform you about these recipients if you request it.
- You have the right to receive the personal data which you provide to us in a structured, commonly used and machine-readable format. You may also request that we transmit the data to another controller without hindrance, where technically feasible.
- As far as data processing is based on your given consent, you have the right to, withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of the data processing based on consent before its withdrawal.
- You have the right to object to the processing of your personal data on grounds relating to a particular situation. In accordance with Article 6 par. 1 f DPRG, this right is subject to any legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data, in particular where the data subject is a child.
- If you exercise your right to object, we will no longer process the personal data in question unless we can demonstrate compelling legitimate grounds for processing that override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
- In case we process personal data for direct marketing purposes (e.g. newsletter), you may, at any time, object to processing of your personal data for the purpose of such advertising, with the result that we will no longer process your data for these purposes;
- If you believe that the processing of your personal data is in breach of the GDPR, you may lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement. This does not exclude other administrative or judicial remedies.
- FINAL PROVISIONS
The data we store will be deleted as soon as they are no longer needed for the purpose for which they are being stored and the law does not prescribe a statutory duty for the data to be retained. If user data are not deleted on grounds that they are still required for other or legally admissible reasons, their processing shall be restricted. This means that the data shall be blocked and shall not be processed for other purposes. This applies, for instance, for user data that have to be kept for reasons pertaining to trade or tax law.