PREAMBLE

HIGHER ED INTERNATIONAL, LLC (“HEI”) is the data controller of the information that we collect in connection with our Services (as described in My Online Campus Terms of use, available at https://www.cambridgeprofessorsonline.com/. As such, HEI is responsible for, and controls, the collecting and processing of your Personal Information (as defined below) under this Privacy Policy.

Websites operated by HEI may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing Personal Information about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

1. PERSONAL INFORMATION

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. As data controller, HEI processes Personal Information which may include:

  • First Name
  • Last Name
  • Middle Name
  • Address
  • Email address
  • Mobile number
  • Nationality
  • Country of residence
  • Gender
  • Date of birth
  • Age
  • Billing (credit card) details
  • Password
  • IP Address
  • Reason for enrolling
  • Level of satisfaction with learning experience
  • Level of educational attainment
  • Educational records and qualifications, including higher and further education institutions attended, dates of attendance, degree programme titles, subjects and grades
  • Work history - including employer, job title, responsibilities, location and dates in role
  • Years of professional experience
  • School type of data subject
  • Course engagement and completion information

1.1. Social Networking Services

HEI may permit you to login to the Services with your login credentials from certain social networking sites (e.g., Facebook) (“SNS”). If you log in or otherwise associate your Account with your login credentials from such SNS, HEI may receive information about you from such SNS, in accordance with the terms and conditions (e.g., terms of use and privacy policy) of the SNS (“SNS Terms”). If you elect to share your information with these SNS, HEI will share information with them in accordance with your election. The SNS Terms of these SNS will apply to the information HEI discloses to them.

2. COLLECTION OF PERSONAL INFORMATION

We collect Personal Information in a variety of ways, including:

2.1 Online

- We collect Personal Information by providing (or in order to provide) our Services, for example, when you submit your details on the request information form on our website https://www.cambridgeprofessorsonline.com/ or paid traffic landing pages, create an account, enrol via our online enrolment form, or maintain an ongoing relationship with us.

- From you during your course of study or period of enrolment.

- We collect your IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website (together, “Technical Data”) from analytics providers such as Google.

- As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy at www.cambridgeprofessorsonline.com for further details.

2.2 Offline

- We collect Personal Information from you offline, such as when you contact us by phone or email and provide information to a member of our contact centre.

We need to collect Personal Information in order to provide our Sservices to you and in order to consider and maintain a relationship with you. If you do not provide the information requested, we may not be able to provide our Services or enrol you, or maintain a relationship with you. If you disclose any Personal Information relating to other people to us or to our service providers in connection with our Services, you represent that you have the legal authority to do so and to permit us to use such information in accordance with this Privacy Policy and with applicable law.

3. USE OF PERSONAL INFORMATION

We will only use your Personal Information when the applicable law allows us to and for the purposes of providing our Services to you. These uses include:

3.1 Providing the functionality of our Services and fulfilling your requests:

- To provide our Services’ functionality to you, such as arranging access to your registered account and purchased courses;

- To respond to your enquiries and fulfil your requests, for example, when you send us questions, suggestions, or complaints;

- To complete your transactions, and provide you with related assistance;

- To send administrative information to you, such as changes to our terms, conditions and policies;

- To allow you to send messages to another person if you choose to do so.

We will engage in these activities to manage our recruitment, enrolment, and support processes. The legal basis we rely on for processing this Personal Information until you have enrolled is consent under article 6(1)(a) of the General Data Protection Regulation ((EU) 2016/679) (GDPR). We will request both email and telephone contact details in order to ensure that any security administrative functions are robustly managed. Further, to provide verbal and written communication to ensure you are fully informed to enabling you to make the decision of aquiring our Services. Then once enrolled, we will rely on 6(1)(b) of the GDPR; processing is necessary for the performance of our contractual relation with you.

3.2 Providing you marketing materials:

- To send you marketing related emails, with information about our Services and other news about us or other programmes offered by our partners;

- We will engage in this activity with your explicit consent and you have the right to withdraw consent to marketing at any time by contacting us in accordance with the “Contacting Us” section below;

- You will receive marketing communications from us if you have previously authorized to receive such comnunications.

The legal basis we rely on for processing this Personal Information is consent under article 6(1)(a) of the GDPR.

3.3 Accomplishing our business purposes:

- For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;

- For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;

- For developing new services;

- For enhancing, improving, or modifying our current Services;

- For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;

- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users;

- For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.

The legal basis used for processing the above rely on No 1 – necessary for compliance with a legal obligation, for example, regulatory audits, article 6 (1)(c) of the GDPR; and No’s 2-7 - necessary for the purposes of a legitimate interest, article 6 (1)(f) of the GDPR.

4. PURPOSE

We will only use your Personal Information for the purposes for which we collected it, as mentioned herein.

5. COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy available at www.cambridgeprofessorsonline.com.

6. DISCLOSURE OF PERSONAL INFORMATION

We may share your Personal Information with the parties set out below, for the purposes listed above. We disclose Personal Information:

  • To partnering institutions that provide course content to HEI.
  • To our third-party service providers (including but not limited to third parties as well as any subsidiary (as defined in section 1159 of the Companies Act 2006 ("CA 2006")) or subsidiary undertaking (as defined in section 1162 of the CA 2006) or any holding company (as defined in section 1159 of the CA 2006) or parent undertaking (as defined in section 1162 of the CA 2006) from time to time of HEI and any subsidiary or subsidiary undertaking from time to time of a holding company or parent undertaking of HEI), to facilitate services they provide to us. These can include providers of services such as website hosting, data analysis, course delivery, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services. Any third-party service providers that we disclose Personal Information to will have entered into a fully GDPR-compliant data processing agreement with HEI.

7. OTHER USES AND DISCLOSURES

We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

  • To comply with applicable law. This can include laws outside your country of residence.
  • To respond to requests from public and government authorities. These can include authorities outside your country of residence.
  • To cooperate with law enforcement. For example, when we respond to law enforcement requests and orders.
  • For other legal reasons. This may include (i) To enforce our terms and conditions; and (ii) To protect our rights, privacy, safety or property, and/or that of you or others.
  • In connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.

8. SECURITY

We will use appropriate organisational, technical and administrative measures to protect Personal Information within our organisation. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

We have additionally 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.

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

9. CHOICES AND ACCESS

9.1 Withdrawal of consent:

You gave consent to receive personalised information about online courses or programmes by your preferred method. You may withdraw your consent:

- To receiving email marketing from us. If you no longer want to receive marketing-related emails from us on a going-forward basis, unsubscribe by following the instructions contained in each such email or by contacting us at info@cambridgeprofessorsonline.com.

- To receiving other types of marketing communications from us regarding other online programmes or courses offered through HEI or its partners. If you no longer want to receive marketing-related communications from us on a going-forward basis, you can unsubscribe by contacting us at info@cambridgeprofessorsonline.com.

- To change the preferred method of contact. Should you wish to change your preferred method, contact us at info@cambridgeprofessorsonline.com.

We will try to comply with your request(s) as soon as reasonably practicable.

9.2 Access, change or delete your Personal Information

Under GDPR, you have the right to:

- Withdraw consent where that is the legal basis of our processing;

- Access your Personal Information that we process;

- Rectify inaccuracies in Personal Information that we hold about you;

- Be forgotten, that is your details to be removed from systems that we use to process your Personal Information;

- Restrict the processing in certain ways;

- Obtain a copy of your data in a commonly used electronic form; and

- Object certain processing of your Personal Information by us.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information.

Please note that we need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a payment, you may not be able to change or delete the Personal Information provided until after the completion of such transaction). Further information regarding retention periods can be found below.

10. RETENTION PERIOD

We retain Personal Information for as long as needed or permitted in light of the purposes for which it was obtained and consistent with applicable law, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint.

The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you and provide Services to you (for example, for as long as you are a student of ours);
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

We will retain personal information for no more than six years from the date on which you cease to have access to your last module.

11. USE OF SERVICES BY MINORS

Our Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under eighteen (18).

12. JURISDICTION AND CROSS-BORDER TRANSFER

Your Personal Information is stored and processed in the United States of America. We share your data within the HEI Group and this will involve transferring your Personal Information outside the European Economic Area (EEA). It may also be processed outside the EEA by third party service providers. Any international data transfers will take place in full compliance with the GDPR and any relevant UK legislation.

Please contact us if you want further information on the specific memorandum used by us when transferring your Personal Information out of the EEA.

13. UPDATES TO THIS PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on our services. Your use of the Services following these changes means that you accept the revised Privacy Policy.

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.

14. CONTACTING US

HIGHER ED INTERNATIONAL, LLC, incorporated and registered in Dallas, Texas with Tax ID 84-4924320 and whose registered office is at 2200 Ross Avenue, Suite 3800, Dallas, Texas USA is the company responsible for, and controls, the collecting and processing of your Personal Information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at info@cambridgeprofessorsonline.com. Because email communications are not always secure, please do not send sensitive information in your emails to us.

15. ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EEA

If you are located in the EEA, you also may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs.

We would however, appreciate the chance to deal with your concerns before you approach the data protection authority for your country or region, so please contact us in the first instance.