Purpose of this Document

Explore is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. Where we act as a data controller, we are required under data protection legislation to notify anyone who provides personal data to us, either directly or through a third party, of the information contained in this privacy notice (“Privacy Notice”).

You are being provided with a copy of this privacy notice because you use or have expressed an interest in our platform and the services offered therein. The notice makes you aware of how and why your personal data will be used, and how long it will usually be kept for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR) and UK data protection legislation.

For the purposes of the relevant data protection legislation, the data controller is Explore Higher Ed Limited (company no. 08989432), with registered address at 85 Great Portland Street, London, England, W1W 7LT. So when we mention “Explore”, “we”, “us” or “our” in this Privacy Notice, we are referring to this company which is responsible for processing your data. We will not sell your personal data (or any other data you provide us with) in any circumstances.

Data Protection Principles

• Used lawfully, fairly and in a transparent way
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
• Relevant to the purposes we have told you about and limited only to those purposes
• Accurate and kept up to date
• Kept only as long as necessary for the purposes we have told you about
• Kept securely

The kind of information we hold about you

We collect, store and use the following personal data via our website:

• The IP address of the device you used to access our website
• Website browsing and engagement data
• Any information that you share as part of completing an inquiry, live chat, contact form or event form on our website
• Any personal data that you provide to us as part of a survey on our website

In connection with your account on the Explore platform, we will collect, store, and use the following categories of personal information about you:

• Your contact and personal information including name, title, name of university, city, state and country, telephone number, and personal or work email address
• Any information you provide to us during any activity carried out and/or uploaded through Explore
• The IP address of the device you used to access the Explore platform

How is your personal information collected?

• You
• The college or university where you work
• If your organisation links their customer relationship management to our platform, we may also receive information from that system
• From our specialist data research partners, paid for databases and publicly available resources such as LinkedIn

How we will use information about you

• Communicate with you about the Explore platform, products and services, events, webinars, schools, universities, courses or other programs and the application process
• To share such collected personal information with schools and students to allow them communicate with you
• To improve the function of the website
• Keep records related to our processes
• Comply with legal or regulatory requirements

Communications & Legitimate Interests

If you are university staff, the contact information you provide to us, including your name, email address, and role, may be shared with schools or students who have expressed an interest in your institution. This is to enable them to contact you directly regarding study opportunities and courses offered by your institution. We may also provide you with additional and/or promotional information using the contact details that you have provided to us.

You can ask to stop receiving these communications by email at any time by clicking on the unsubscribe links. We will not sell your personal data (or any other data you provide us with) in any circumstances.

You, and we, also have legitimate interests in our processing of your data to directly submit and track transcripts, reference letters, and other application documents.

We also may use your personal data for our internal business purposes. This is in our legitimate interests in order to operate as a business and monitor and improve the products and services that we provide. Where possible we will anonymise this information. Please contact us using the contact details in this Privacy Notice if you would like more information.

If you fail to provide personal information

If you fail to provide information, such as your email address, we will not be able to create a user profile for you on our platform and we may not be able to communicate with you regarding our products or services.

Automated technologies or interactions

As you interact with our website and our platform, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

Explore uses cookies to distinguish you from other users. This helps us provide you with a good experience when you use our website. Please note that it is possible to disable cookies being stored on your computer by changing your browser settings. However, our website may not perform properly or some features may not be available to you if you disable cookies.

Why might you share my personal information with third parties?

We will only share your personal information with the following third parties:

• Third party providers such as accountants, auditors and advisers, in order to fulfil our legal, regulatory and other obligations
• Entities in our group of companies for administrative support, reporting, restructuring, system maintenance or data hosting
• If we sell part, or all, of our business to another company, all of the information we have collected about you will be sold with it
• New partner companies, where sharing is necessary for delivering services

All third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Our website may contain links to third party websites. If you follow a link to any of those third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third-party websites.

The personal information we process may be processed by staff operating outside of the EEA who work for us or for one of our business partners or service providers. Please contact the Data Protection Officer for further details on the specific safeguards applied to the export of your personal information outside the EEA.

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. Details of these measures may be obtained from the Data Protection Officer.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

We will retain your personal information in line with our retention schedule in order to provide continued services, to conduct statistical and other analyses of our services, to develop and augment our algorithms and processes, and to ensure that we can respond to any queries raised within a reasonable period. After this period, we will securely destroy your personal information in accordance with our data retention policy.

Rights of access, correction, erasure, and restriction

• Request access to your personal information (commonly known as a “data subject access request”)
• Request correction of the personal information that we hold about you
• Request erasure of your personal information
• Object to processing of your personal information where we are relying on a legitimate interest
• Request restriction of processing of your personal information
• Request the transfer of your personal information to another party

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Officer in writing.

Data protection officer

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO.

Email address: dpo@explore.study

If you are an EU national or resident in an EU country, we have a representative in the EU who you can write to: Explore Higher Ed Limited, 145 City Road, London, England, EC1V 1AZ, Attn: General Counsel. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, however we would welcome the opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to this information

We may make changes to this notice from time to time. We will post any changes to our site, or let you know by sending you an email.