External Privacy Notice

 

  1. This Notice

 

Summary – This Notice

This Notice explains how we Process Personal Data. This Notice may be amended or updated from time to time, so please check it regularly for updates.

 

This Notice is issued by each of the Controller entities listed in Section (Q) below (together, “ Unicaf Group”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including current, former and prospective students, visitors to our Sites, users of our Apps, other users of our services, and visitors to our premises (together, “you”). Each Controller listed in Section (Q) below is responsible for its own compliance with the laws to which it is subject, and no Controller is responsible for the compliance of any other Controller. Defined terms used in this Notice are explained in Section (R) below.

 

This Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Notice carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Notice.

 

  1. Collection of Personal Data

 

Summary – Collection of Personal Data

We collect or obtain Personal Data: when those data are provided to us (e.g., where you contact us); in the course of our relationship with you (e.g., your student records); when you make Personal Data public (e.g., if you make a public post about us on social media); when you download, install, or use any of our Apps; when you visit our Sites; when you register to use any of our Sites, Apps, or services; or when you interact with any third party content or advertising on a Site or in an App. We may also receive Personal Data about you from third parties (e.g., law enforcement authorities).

 

Collection of Personal Data: We collect or obtain Personal Data about you from the following sources:

 

  1. Creation of Personal Data

 

Summary – Creation of Personal Data

We create Personal Data about you (e.g., records of your interactions with us).

 

We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us. We may also combine Personal Data from any of our Sites, Apps, or services, including where those data are collected from different devices.

 

  1. Categories of Personal Data we Process

 

Summary – Categories of Personal Data we Process

We Process: your personal details (e.g., your name); demographic data (e.g., your age); your contact details (e.g., your address); records of your consents; payment details (e.g., your billing address); information about our Sites and Apps (e.g., the type of device you are using); details of your employer (where relevant); information about your interactions with our content or advertising; and any views or opinions you provide to us.

 

We Process the following categories of Personal Data about you:

 

 

  1. Sensitive Personal Data

 

Summary – Sensitive Personal Data

We do not seek to collect or otherwise Process Sensitive Personal Data. Where we need to Process Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.

 

We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

 

If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the Processing of those Sensitive Personal Data.

 

  1. Purposes of Processing and legal bases for Processing

 

Summary – Purposes of Processing and legal bases for Processing

We Process Personal Data for the following purposes: providing our Sites, Apps, and services to you; operating our business; communicating with you; managing our IT systems; health and safety; financial management; conducting surveys; ensuring the security of our premises and systems; conducting investigations where necessary; compliance with applicable law; improving our Sites, Apps, and services; fraud prevention; and recruitment and job applications.

 

The purposes for which we Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

 

Processing activity

Legal basis for Processing

  • Provision of educational services: providing teaching and other educational services; delivery of online courses; tracking participation; administration of tests and examinations; and production and maintenance of qualification / certification records.
  • The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or
  • We have a legitimate interest in carrying out the Processing for the purpose of providing educational services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
  • Provision of Sites, Apps, and related services: providing our Sites, Apps, or related services; providing promotional items upon request; and communicating with you in relation to those Sites, Apps, or related services.
  • The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or
  • We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, Apps, or services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
  • Operating our business: operating and managing our Sites, our Apps, and our services; providing content to you; displaying advertising and other information to you; communicating and interacting with you via our Sites, our Apps, or our services; and notifying you of changes to any of our Sites, our Apps, or our services.
  • The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or
  • We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, our Apps, or our services to you (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
  • Communications and marketing: communicating with you via any means (including via email, telephone, text message, social media, post or in person) to provide news items and other information in which you may be interested, subject always to obtaining your prior opt-in consent to the extent required under applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required.
  • The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or
  • We have a legitimate interest in carrying out the Processing for the purpose of contacting you, subject always to compliance with applicable law (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
  • Management of IT systems: management and operation of our communications, IT and security systems; and audits (including security audits) and monitoring of such systems.
  • The Processing is necessary for compliance with a legal obligation; or
  • We have a legitimate interest in carrying out the Processing for the purpose of managing and maintaining our communications and IT systems (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
  • Health and safety: health and safety assessments and record keeping; providing a safe and secure environment at our premises; and compliance with related legal obligations.
  • The Processing is necessary for compliance with a legal obligation; or
  • We have a legitimate interest in carrying out the Processing for the purpose of ensuring a safe environment at our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • The Processing is necessary to protect the vital interests of any individual.
  • Financial management: sales; finance; corporate audit; and vendor management.
  • We have a legitimate interest in carrying out the Processing for the purpose of managing and operating the financial affairs of our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
  • Surveys: engaging with you for the purposes of obtaining your views on our Sites, our Apps, or our services.
  • We have a legitimate interest in carrying out the Processing for the purpose of conducting surveys, satisfaction reports and market research (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
  • Security: physical security of our premises (including records of visits to our premises); CCTV recordings; and electronic security (including login records and access details).
  • The Processing is necessary for compliance with a legal obligation; or
  • We have a legitimate interest in carrying out the Processing for the purpose of ensuring the physical and electronic security of our business and our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
  • Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.
  • The Processing is necessary for compliance with a legal obligation; or
  • We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, breaches of our policies and applicable laws (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
  • Legal proceedings: establishing, exercising and defending legal rights.
  • The Processing is necessary for compliance with a legal obligation; or
  • We have a legitimate interest in carrying out the Processing for the purpose of establishing, exercising or defending our legal rights (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
  • Legal compliance: compliance with our legal and regulatory obligations under applicable law.
  • The Processing is necessary for compliance with a legal obligation.
  • Improving our Sites, Apps, and services: identifying issues with our Sites, our Apps, or our services; planning improvements to our Sites, our Apps, or our services; and creating new Sites, Apps,  or services.
  • We have a legitimate interest in carrying out the Processing for the purpose of improving our Sites, our Apps, or our services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
  • Fraud prevention: Detecting, preventing and investigating fraud.
  • The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); or
  • We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, fraud (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
  • Recruitment and job applications: recruitment activities; advertising of positions; interview activities; analysis of suitability for the relevant position; records of hiring decisions; offer details; and acceptance details.
  • The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); or
  • We have a legitimate interest in carrying out the Processing for the purpose of recruitment activities and handling job applications (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

 

 

  1. Disclosure of Personal Data to third parties

 

Summary – Disclosure of Personal Data to third parties

We disclose Personal Data to: legal and regulatory authorities; our external advisors; our Processors; any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business; and any third party providers of advertising, plugins or content used on our Sites or our Apps.

 

We disclose Personal Data to other entities within  Unicaf Group, for legitimate business purposes and the operation of our Sites, Apps, or services to you, in accordance with applicable law. Our staff and agents may be permitted to access appropriate information about students, when they have a legitimate reason to do so.

 

In addition, we disclose Personal Data to:

 

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

 

  1. International transfer of Personal Data

 

Summary – International transfer of Personal Data

We transfer Personal Data to recipients in other countries. Where we transfer Personal Data from the EEA to a recipient outside the EEA that is not in an Adequate Jurisdiction, we do so on the basis of Standard Contractual Clauses.

 

Because of the international nature of our business and the educational services we provide, we transfer Personal Data within  Unicaf Group, and to third parties as noted in Section (G) above, in connection with the purposes set out in this Notice. For this reason, we transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

 

Where we transfer your Personal Data from the EEA to recipients located outside the EEA who are not in Adequate Jurisdictions, we do soon the basis of Standard Contractual Clauses. You are entitled to request a copy of our Standard Contractual Clauses using the contact details provided in Section (Q) below.

 

Please note that when you transfer any Personal Data directly to a  Unicaf Group entity established outside the EEA, we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Notice.

 

  1. Data security

                                                        

Summary – Data security

We implement appropriate technical and organisational security measures to protect your Personal Data. Please ensure that any Personal Data that you send to us are sent securely.

 

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

 

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

 

  1. Data accuracy

                                                        

Summary – Data accuracy

We take every reasonable step to ensure that your Personal Data are kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.

 

We take every reasonable step to ensure that:

 

From time to time we may ask you to confirm the accuracy of your Personal Data.

 

  1. Data minimisation

                                                        

Summary – Data minimisation

We take every reasonable step to limit the volume of your Personal Data that we Process to what is necessary.

 

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Notice.

 

  1. Data retention

 

Summary – Data retention

We take every reasonable step to ensure that your Personal Data are only retained for as long as they are needed in connection with a lawful purpose.

 

We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows:

 

  1. we will retain Personal Data in a form that permits identification only for as long as:
  1. we maintain an ongoing relationship with you (e.g., where you are a student participating in our educational services); or
  1. your Personal Data are necessary in connection with the lawful purposes set out in this Notice, for which we have a valid legal basis (e.g., you have contacted us to express an interest in learning more about participation in our educational courses),

plus:

  1. the duration of:
  1. any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data are relevant); and
  1. an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim),

and:

  1. in addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.

 

During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

 

Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will, to the extent required by applicable law, either:

 

 

  1. Your legal rights

 

Summary – Your legal rights

Subject to applicable law, you may have a number of rights, including: the right not to provide your Personal Data to us; the right of access to your Personal Data; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Data; the right to object to the Processing of your Personal Data; the right to have your Personal Data transferred to another Controller; the right to withdraw consent; and the right to lodge complaints with Data Protection Authorities. In some cases it will be necessary to provide evidence of your identity before we can give effect to these rights.

 

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

 

 

Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Data:

  • the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf; and
  • the right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes.

 

This does not affect your statutory rights.

 

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Notice, or about our Processing of your Personal Data, please use the contact details provided in Section (Q) below. Please note that:

 

  1. Cookies and similar technologies

 

Summary – Cookies and similar technologies

We Process Personal Data by using Cookies and similar technologies. For more information, please see our Cookie Policy.

 

When you visit a Site or use an App we will typically place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We Process Personal Data through Cookies and similar technologies, in accordance with our Cookie Policy.

 

  1. Terms of Use

 

Summary – Terms of Use

Our Terms of Use govern all use of our Sites, our Apps, and our services.

 

All use of our Sites, Apps, or services is subject to our Terms of Use. We recommend that you review our Terms of Use regularly, in order to review any changes we might make from time to time.

 

  1. Direct marketing

 

Summary – Direct marketing

We Process Personal Data to contact you with information regarding Sites, Apps, or services that may be of interest to you. You may unsubscribe for free at any time.

 

We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites, Apps, or services that may be of interest to you. If we provide Sites, Apps, or services to you, we may send information to you regarding our Sites, Apps, or services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us, subject always to obtaining your prior opt-in consent to the extent required under applicable law.

 

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Sites, Apps, or services you have requested.

 

  1. Details of Controllers

 

Summary – Details of Controllers

There are several UNIC Group entities that act as Controllers for the purposes of this Privacy Notice.

 

For the purposes of this Notice, the relevant Controllers are:

 

Controller entity

Contact details

 Unicaf  Limited.

Address: Old Larnaca Airport, P.O. Box 42572, 6500 Larnaca, Cyprus

Phone: + 357 24747500

Email: info@unicaf.org

 

UNICAF University Limited (Zambia)

Address: Plot no.3, Fairview, Masansa Close, Off Bwinjimfumu Road, Lusaka Province, Zambia, P.0.Box: 35868

Phone: +260 211250522

Email: info@unicaf.org

 

UNICAF Ltd. (Malawi)

Address: Area 25, Lilongwe, P.O.Box 2235, Lilongwe

Phone: +265 1755 333

Email: info@unicaf.org

 

UNICAF University Ltd. (Uganda)

Address: Plot no. 56/60, Ambassador House 1st Floor, Suite 4A, Kampala, Uganda

Phone: +256 414 669086

Email: info@unicaf.org

 

UNICAF Educational Services (Nigeria)

Address: Plot 10 Peace Avenue, Oshorun Heritage Estate, Off Channels TV Avenue, Isheri North, Lagos State

Phone: +234 07000 UNICAF (864223)

Email: info@unicaf.org

 

UNICAF Online Kenya Ltd.

Address: West Park Suites,

7th Floor, Ojijo Road,

opp. Parklands Police Station

Nairobi, Kenya

Phone: +254 730 775 000

Email: info@unicaf.org

 

UNICAF Ltd. (Mauritius)

Address: Wing A level 5 BPML, Cybertower 1, Ebene

Phone: +230 4890999

Email: info@unicaf.org

 

UNICAF LMITED EGYPT

Address: 3 Amman Square , Dokki , Giza , Egypt

Phone: +202 33379475

Email: info@unicaf.org

 

UNICAF LIMITED (RWANDA)

Address: 18 AVE. #290, P.O. BOX 5000, RUBIRIZI

KIGALI, RWANDA

Phone: +250 780007353

Email: info@unicaf.org

 

UNICAF UNIVERSITY ZIMBABWE (PRIVATE) LIMITED

Address: 99 Jason Moyo, 4th Street,4th floor,

Harare – Zimbabwe

Phone: +263 242 254440-2

Email: info@unicaf.org

 

UNICAF LIMITED (UK)

Address: Charles House 359, Easter Avenue, Gants Hill, Ilford, Essex, UK IG2 6NE

Email: info@unicaf.org

 

 

 

Our Data Protection Officer is contactable using the details set out above.

 

  1. Definitions

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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