Privacy Policy
(inc. cookies)
In this Policy, "CIEE", "we", "us" and "our", refer to CIEE Study Abroad London Ltd.
CIEE is committed to safeguarding information provided to us by any third parties ("you") (including its customers and all visitors to the website www.cieelondon.org (the "Website")) from which any individual can be identified, such as names, contact details and ID data ("Personal Information"). To the extent that any Personal Information is collected, it will be held in confidence in accordance with the Data Protection Legislation (as defined below). Please read the following Privacy and Cookies Policy which explains how we use and protect your information.
We will only use Personal Information which is provided to us, or otherwise obtained by us, as set out in this Policy. We will ensure that your Personal Information is handled in accordance with the "Data Protection Legislation" (meaning any law applicable from time to time relating to the processing of Personal Information and/or privacy as the same may be re-enacted, applied, amended, superseded, repealed or consolidated, including without limitation, the UK Data Protection Act 1998, (with effect from 25 May 2018) the General Data Protection Regulation (EU) 2016/679, and the Privacy and Electronic Communications (EC Directive) Regulations 2003, in each case including any legally binding regulations, directions and orders issued from time to time under or in connection with any such law).
By visiting and/or contacting us through the Website (or otherwise engaging with us), you acknowledge that we may collect, use and transfer your Personal Information as set out in this Policy. CIEE reserves the right to change this Policy from time to time and you should therefore check this page frequently to ensure that you are happy with any changes.
For the purposes of the Data Protection Legislation, CIEE are deemed to be the "data controllers" in respect of any Personal Information that you provide to us or we otherwise obtain about you.
This Privacy and Cookies Policy covers:
Personal Information that we collect from you
Personal Information that we receive from other sources
Sensitive Personal Information
What we do with your Personal Information
How we share your Personal Information
Our security measures and information about when we delete data
Transferring Personal Information outside of the EEA
Accessing and updating your Personal Information
Complaints
Our use of cookies
Changes to this Privacy and Cookies Policy
Our contact information
1. Personal Information That We Collect From You
When you engage with us (e.g. sending us emails, contacting us via telephone or visiting or making an enquiry through the Website), you may provide Personal Information about yourself including your name and contact details (e.g. your address, email address and telephone number) and your job title and CV where you apply for a role with us. Where you make use of our Website we may also collect information about your use of the Website (e.g. your IP address and choice of web browser). Some of this Personal Information is collected and processed so we can perform a contract with you, some for the purpose of legal compliance and some for the purposes of our legitimate business interests (namely to carry out and improve our business, analyze the use of our Website and services and support our staff and customers).
Where you apply for a job with us, we may collect from you and third parties (where relevant) additional Personal Information such as your CV and any references. Unless you agree that we can keep such information on file for future opportunities or we need to retain such information for compliance with our legal obligations, in the event that you are unsuccessful, we will only retain this Personal Information for as long as is reasonably necessary to process your application.
Where you provide Personal Information on behalf of another individual, you are responsible for notifying that individual that you have provided their Personal Information to us and directing them to this Policy as to how we will process their Personal Information.
2. Personal Information That We Receive From Other Sources
We may receive information from third parties who collect Personal Information from you and pass it on to us. For example: (i) our staff may give us emergency contact information as part of our emergency scenario planning and may give us details of their dependents and of other people in relation to their employee benefits arrangements; (ii) your employer may provide your Personal Information to us in connection with a service they provide to us or in connection with services that we provide to our customers; and (iii) we may receive information from past employers and others concerning your employment history where you apply for a job with us. Where this is the case the third party is responsible for informing you that they have shared your Personal Information with us, directing you to this Policy as to how we will process your Personal Information and obtaining any relevant consents from you to ensure you are happy with the ways in which your Personal Information will be used, but once we are holding it, we will only handle it in accordance with this Policy.
3. Sensitive Personal Information
"Sensitive Personal Information" is Personal Information concerning an individual's (i) racial or ethnic origin, (ii) political opinions, (iii) religious beliefs or other beliefs of a similar nature, (iv) membership of a trade union, (v) physical or mental health or condition, (vi) sexual life or orientation, (vii) commission or alleged commission of any offence or any proceedings for any offence committed or alleged to have been committed by him/her, the disposal of such proceedings or the sentence of any court in such proceedings.
Where you provide us with Sensitive Personal Information, you acknowledge that the provision of this information is entirely voluntary and subject to your express consent. Where necessary, we may also process such information in the establishment, exercise or defense of legal claims.
Where we do receive Sensitive Personal Information, we will only keep such information for as long as strictly necessary in order to comply with our obligations under the law.
4. What We Do With Your Personal Information
We will only use your Personal Information in order to (a) improve our Website and services, (b) comply with our own legal and regulatory obligations, (c) for our internal business processes, including providing support to our staff, and (f) where relevant, process your application for employment.
Where you have explicitly consented at the time we collected your Personal Information or where we otherwise have a right to do so, we may also use your Personal Information to let you know about any of our services that may be of interest to you and/or inform you about important changes or developments to our services by email.
Where you or your employer (or any other entity you work for) provides services to us, you and/or they may provide us with some of your Personal Information in connection with the provision of the services, such as your name, business contact details and other ID information. We will only process such Personal Information in connection with the provision of the services (such as using your contact details to discuss the services) and in accordance with this Policy. In addition, where necessary, we may also share your Personal Information with third parties in order to provide our services.
If you change your mind about us using your Personal Information in the ways described in this Policy, please let us know by contacting us bookings@ciee.org. You may also opt out of receiving marketing emails from us by following the instructions outlined in the email.
5. How We Share Your Personal Information
Where it is necessary for the performance of our contract with you or for our internal business processes, we may share your Personal Information with certain third parties, such as our professional advisors, service providers, regulatory bodies, auditors, technology providers and any duly authorized agents or related, associated or affiliated companies of the foregoing for the same purposes.
By submitting your Personal Information to us, you acknowledge that such third parties may receive and process your Personal Information. We ask all third parties to treat your Personal Information securely and in accordance with this Policy and will take reasonable steps to enforce this. We will never sell your data.
In addition, it may be necessary to disclose your Personal Information if we are under a duty to disclose your Personal Information in order to comply with any legal obligation (such as anti-money laundering or anti-terrorist financing obligations), carry out an internal investigation, enforce our Terms and Conditions on our Website and any other agreement, or protect the rights, property, or safety of CIEE, our group companies and our customers, directors, employees or other personnel.
In exceptional circumstances, if we are sold or merged with another company we may disclose your information to a potential buyer, including your Personal Information and other information concerning your relationship with us, so that they can continue to provide the services you have requested.
6. Our Security Measures And Information About When We Delete Data
We will only keep your Personal Information for as long as we reasonably require and, in any event, only for as long as the Data Protection Legislation allows.
Unfortunately, the transmission of information via the internet is not completely secure and, although we will take steps to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted via the Website; any transmission is therefore at your own risk.
Some of our premises use CCTV for the purpose of crime prevention, however, this is under the control of a third party and therefore you should consult any notices they display and their privacy statements for more information.
7. Transferring Personal Information Outside Of The EEA
Any Personal Information provided to CIEE will be transferred to and stored on our secure servers. Our servers are based outside the EEA. We take steps to protect your Personal Information from unauthorized access and against unlawful processing, accidental loss, destruction and damage.
Accordingly, in processing your Personal Information, it will be necessary for us to transfer your Personal Information outside the European Economic Area ("EEA") to our staff and our third-party service providers. It may also be accessed by staff operating outside the EEA who work for us or for one of our suppliers or group companies. This includes people engaged in, among other things, the provision of support services to us. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Policy and the Data Protection Legislation when it is processed in, or otherwise accessed from, a location outside the EEA. This means that we will only transfer your Personal Information to third parties based outside the EEA if that party (a) is situated in a country that has been confirmed by the European Commission to provide adequate protection to Personal Information, (b) has agreed (by way of written contract incorporating the "model clauses" as approved by the European Commission or by some other form of data transfer mechanism approved by the European Commission) to provide all protections to your Personal Information as required by the Data Protection Legislation or (c) we have your explicit consent to do so. Where any transfer takes place under a written contract, you have the right to request a copy of that contract and may do so by contacting us at bookings@ciee.org. For the avoidance of doubt, in the event that the UK is no longer a part of the EEA, references in this paragraph to the EEA shall mean the EEA and the UK.
By submitting your Personal Information to us, you acknowledge this transfer, storing or processing of your Personal Information.
8. Accessing And Updating Your Personal Information
You have the right to ask us not to process your Personal Information for marketing or research purposes. If you have given us your express consent, or where we otherwise have the right to do so, we may use your Personal Information for marketing purposes. If we intend to disclose your Personal Information to any third party for marketing purposes, we will seek your explicit consent prior to any such transfer. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your Personal Information. You can also exercise the right at any time by contacting us at bookings@ciee.org.
You are entitled to know some details about the Personal Information we hold about you and how that information is processed. If you would like to request this, please contact us at bookings@ciee.org and we will provide you with the information to which you are entitled.
You can also ask us to: (a) make any changes to ensure that any Personal Information we hold about you is accurate and up to date; (b) erase or stop processing any Personal Information we hold about you where there is no longer a legal ground for us to hold it; or (c) in some circumstances, transfer any information we hold about you to a specified third party. If you wish to exercise any of these rights, please contact us at bookings@ciee.org.
9. Complaints
Should you have any queries or complaints in relation to how we use your Personal Information, please contact us at bookings@ciee.org. Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner's Office regarding such issues.
Our Website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their related policies. Please check these policies before you submit any Personal Information via these websites.
10. Our Use Of Cookies
A cookie is a small file that is sent to your browser from a web server and is stored on your computer. Cookies help us to analyze web traffic and identify which pages of our Website are being used. Our Website also uses cookies to respond to you as an individual so that it can tailor its operations to your needs by gathering and remembering information about your preferences. We only use this information for statistical analysis purposes and then it is removed from our systems.
A cookie in no way gives us access to your computer or any information about you, other than information about how you use the Website and the Personal Information you choose to share with us (including Personal Information you automatically share with us by way of your browser settings).
You will normally see a message on our Website before we store a cookie on your computer which describes the types of cookies we use and what information they might collect. We may also use banners and pop-ups from time to time to give you options around cookie use.
You can also manage cookie use via your browser settings (this will allow you to refuse the setting of all or some cookies) and your browser provider may ask you to confirm your settings. Note, however, that if you block all cookies (including essential cookies) via your browser settings you may not be able to access all or parts of our Website.
We use is Google Analytics to record anonymous interactions on the website. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. Learn more about Google’s partner services and how to opt out of tracking of analytics by Google.
You can also find more information about cookies generally here: www.allaboutcookies.org.
11. Changes To This Privacy And Cookies Policy
CIEE may amend this Policy at any time without notice. By continuing to use the Website and making use of our services you acknowledge that we shall process your Personal Information in accordance with the updated Policy. If you are not happy with any changes that we make, you should not use or access (or continue to use or access) the Website and/or our services. Any changes to this Policy will be posted on the Website.
12. Our Contact Information
If you have any questions (including relating to transfers of your Personal Information outside the EEA), please feel free to contact us by email at: bookings@ciee.org