Privacy and Cookies Policy
Last Updated: June 18, 2024
EnrolHere Inc. (“EnrolHere,” “ApplyProof,” “TrainHub,” “ApplyBoost”, “we,” “us,” or “our”) provides users with the ability to investigate the process of becoming a student at certain schools around the world, including information respecting visa applications and program information. We also provide the ability to apply for admission to certain programs of such institutions through our recruitment partners, counsellors and our website and to access ancillary services and products related to the international student journey (collectively, the Services).
To do this, EnrolHere collects your personal data. This Privacy & Cookies Policy (Policy) sets out the manner in which EnrolHere collects, uses, discloses, and otherwise manages personal data.
The changes made to this Policy go into effect as at the date listed above and your continued use of EnrolHere's services and/or website after this date will be subject to our updated Policy.
What We Collect and How
How does EnrolHere collect my personal data?
We collect personal data directly from you, about you from third parties such as our marketing affiliates and service providers used to verify your identity and prevent fraudulent activity, other EnrolHere users and other EnrolHere clients or customers for the purpose of providing the EnrolHere Services to you or as part of a customer referral program, and through the use of cookies and metadata collected on our Website and the Services. At this time, use of our Services is only available to users who register for our Services.
We receive personal data about you from third parties, such as banking references, credit reporting agencies, affiliates, website hosts, live chat and online support service providers, other EnrolHere users, events vendors, and other third parties (e.g., entities that assist us in validating your identity, for risk assessment purposes, for fraud prevention, etc.). We may combine this information with other information that we collect about you.
We, and our third party service providers, automatically collect the following information about your use of our Website and our online Services through cookies, web beacons, log files and other technologies (subject to your consent where required by applicable law): your domain name, your browser type and operating system, web pages you view, links you click, your IP address, the length of time you visit our Website or use our Services, your activities on our Website, and the referring URL or the webpage that led you to our Website. Please see the section“Our Use of Cookies and other Tracking Mechanisms” below for more information.
What personal data does EnrolHere collect?
The types of personal data we collect about you depends on your particular interaction with our Website and our Services. In limited circumstances such as facilitating your application process to certain schools of interest, we may also need to collect sensitive personal data (e.g., personal information revealing racial or ethic origin, political opinions, religious or philosophical beliefs, trade union membership, generic or biometric data, health information). In the event that it is necessary to collect any sensitive data about you, where required by data protection laws we will gather your explicit consent to do so. The personal data collected is only shared with EnrolHere and our third-party service providers acting as data processors for the purpose of providing the Services you request and will not be shared or used by us for any other purposes.
We have set out in the table below the categories of personal data we generally collect about you, where permitted by applicable law:
Categories of Personal Data Collected | Specific Personal Data | Sensitive Personal Data | Source of Personal Data |
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Identifiers | Name, email address, phone number, billing or mailing address, IP address, date of birth. | National identification numbers and documents that may include your photograph and/or government identifier. | Directly from you, third parties on your behalf and as instructed by you, other EnrolHere users and customers, our service providers and affiliates. |
Financial Information | | Bank and credit account information, credit history as applicable. | Directly from you, third parties on your behalf and as instructed by you, recruitment partners, counsellors, other EnrolHere users and customers, our service providers and affiliates. |
Health Information | | Vaccination record, such as information about the date and type of vaccines you received and your personal health number. | Directly from you, third parties on your behalf and as instructed or permitted by you. |
Internet or Other Similar Network Activity | Other information collected through Cookies and other tracking technologies as listed above and as described in the section below entitled “Our Use of Cookies and other Tracking Mechanisms”. | | From you directly and our third party analytic tools and cookies usage (See the section below entitled “Our Use of Cookies and other Tracking Mechanisms”). |
Geolocation Data | Geolocation. | | Directly from you and/or [through your use of the Mobile Application] and/or our third party analytic tools and cookies usage (See the section below entitled “Our Use of Cookies and other Tracking Mechanisms”). |
Professional or Employment Information | Name and contact information, professional credentials and skills, educational and work history, salary, evaluations, references, interviews, certifications, disciplinary matters and other information of the type included on a resume, curriculum vitae or cover letter. | | Directly from you or when another party, such as a recruiter, counsellor, or external website, provides it to us. |
Other categories | Any other information that you choose to provide to us (e.g., when you send us an email/otherwise contact us). | | Directly from you, third parties on your behalf and as instructed or permitted by you. |
When We Collect Your Information and How We Use It
EnrolHere collects your personal data whenever you do any of the following and uses it as described:
Create an Account: To access certain features on the Website, you are required to create an account and provide your email address and password or sign in with Facebook or Google. Your login information is used to create your account, and otherwise provide and administer the service you requested.
Explore What Programs You Are Eligible To Apply To: You do not have to create an account to visit and browse certain features of our Website, such as to browse various schools and programs, read other content portions of the Website, or determine your eligibility for certain programs. If you choose to use our Website to discover programs you are eligible to apply for, we collect personal data such as your nationality, country of education, highest education, grading scheme, grade average, English/French exam score(s) and the disciplines or programs that you are interested in pursuing. EnrolHere uses this information to create a list of programs and schools to which you are eligible to apply.
Create a Student Profile and/or Apply to an Educational Program: To access certain features on In order to apply to an educational program, you (or the recruitment partner or counsellor acting as your legal representative) are required to create a student profile on our Website. The personal data we collect in your student profile helps us match you with schools and programs that fit your preferences and qualifications. This information may also be required by the school for the purposes of processing your application. This information may include your first and last name, email address, gender, date of birth, home and mailing address, passport details, marital status, emergency contact information, English or French language test score(s), educational preferences (such as preferred study destination and educational fields of interest), education history, volunteer experience, and other educational information. In some circumstances, schools may also require us to collect your personal health information, including COVID-19 vaccination status, as part of your application process.
Throughout the application process, you have the option to provide additional information such as documentation of awards and school projects. This information is not required to process your application but is recommended to enhance the success of your application.
We may use your profile information and other information about your use of the Website (such as search queries or other links you click on) to provide you with tailored school recommendations through the Website.
Use an ApplyStudent Email Account:We may create and provide you with an “ApplyStudent” email account to facilitate your communications with certain schools of interest. ApplyStudent email accounts are only used for applying to educational programs through EnrolHere. EnrolHere monitors the incoming and outgoing emails from ApplyStudent email accounts and may collect information from those emails so that you do not miss any important information regarding your application. You can disable the functionality of this email account by contacting us as set out below.
Use of Our Services for Visa Processing:We offer students the option of processing their student visas through EnrolHere. If you choose to use this service, we may collect personal data for the purposes of processing your visa application (if necessary), including passport details and information included on a visa application form.
Aiding in applying for student loans:EnrolHere offers users the option to procure student loans to assist with the financial requirements of studying abroad. If you choose to use this service, you may be asked to provide additional personal information for the purposes of applying for, securing, and processing your loan application. The additional personal information may include sensitive personal information and payment information, which will be shared with our financial partners. Impact assessments have been conducted on this service and we are committed to your personal information being handled with the highest level of security and privacy throughout the loan application process. EnrolHere will only share necessary information with our partners to provide this service to you where we have your explicit consent to do so.
Aiding with job searches:EnrolHere offers users the option of assistance in finding employment in the target destination. If you choose to use this service, you may be asked to provide additional personal information for the purposes of providing your resume and details to potential employers. The additional personal information may include sensitive personal information, which will be shared with our employment partners. Impact assessments have been conducted on this service and we are committed to your personal information being handled with the highest level of security and privacy throughout the employment application process. EnrolHere will only share necessary information with our partners to provide this service to you where we have your explicit consent to do so.
Using TrainHub:You will have the ability to access our course content and provide voluntary personal information so we can register you as an individual taking the course. As a certificate of completion may be issued, we will keep a record of you having registered and/or completed the course offering.
Post On Our Website or Social Media Channels (including direct messages):You have the ability to post information (e.g. questions, comments and opinions) through EnrolHere's services or on social media platforms, such as Facebook, LinkedIn, or Instagram, as well as send us direct messages via these platforms. Please be advised that any personal data that you voluntarily post to any public forum will be available to other individuals and you should exercise caution when posting any personal data. Content you post on sites owned by third parties (such as social media platforms) is subject to the privacy policies of those third parties.
Register to Take Any Courses:You will have the ability to access our course content and provide voluntary personal data so we can register you as an individual taking the course. As a certificate of completion may be issued, we will keep a record of you having registered and/or completed the course offering.
Interact with Live Chat and Online Support Services:We provide online support services powered by third parties (e.g., Zendesk, Sendbird) on our Website, including a live chat functionality. These support services enable us, and the service providers we work with, to communicate instantly with you and to provide additional information or answer any questions.
Your information is collected with the aim of operating the online support services and analyzing the use of those services. It may include your first and last name, phone number, email address, IP address, and other data communicated while using the support services. In addition, the support services may collect browsing and usage data in the pages where they are installed, even if you do not actively use them. Live chat conversations may also be logged for quality assurance and training purposes.
By using the support services on our Website, you explicitly consent to the collection and use of your information. You are solely responsible for the information you choose to submit while using the support services.
Purchase Products and Services Relating to the International Student Journey:You have the ability to purchase products and services relating to the international student journey through our online store, which is hosted by Shopify. When you purchase a product or service through our online store, Shopify will collect certain information from you, including your name, billing address, email address, phone number and payment information in order to assist us in completing your transaction, processing your payment, communicating with you about your purchase and arranging electronic delivery of your test voucher. We do not store credit card information entered through our online store; rather, Shopify, who is PCI DSS compliant, facilitates secure payment processing. By using our online store, you are subject to Shopify’s Terms of Service and Privacy Policy. Information that a user submits to our online store will be transmitted to and shared with third parties that may be located in countries outside the country in which the user resides, in order to provide services to the user, including but not limited to transaction processing and fraud prevention.
Communicate with Us:When you contact us with a comment, question or complaint, you may be asked for information that identifies you (such as your name, address and a phone number) along with additional information we need to help us promptly answer your question or respond to your comment or complaint. We may also retain this information to assist you in the future and to improve our customer service, products, service offerings, events and promotions.
Provide Information to Third Parties With Whom We Work: We may obtain personal data about you through your legal representative, or a recruitment partner(s) or counsellor(s) who you are working with and who are using our services to process your application to schools. Occasionally, EnrolHere will obtain information about you from third parties, such as mailing list providers and third-party service providers. Third-party providers are responsible for obtaining consent to provide personal data to us.
Payment Processing and Transaction Tracking:EnrolHere uses, with your consent, third party PCI certified payment service providers including but not limited to Western Union, Flywire or Stripe. When you directly make a payment using these payment service providers, you are subject to their privacy policies. They are independent of EnrolHere and EnrolHere is not responsible for their privacy practices.
Our applications are designed to directly connect our users securely, transparently and cryptographically to the PCI certified payment processor. This helps ensure we maintain the privacy of your financial transactions. The payment processor provides EnrolHere with a transaction number and status. This information is often required for visa applications as proof of program payment as well as a demonstration of student commitment to their selected program. EnrolHere maintains a list of payment processors and other third party service providers that we may use to process payments to independent service providers and/or third party contractors that we retain in connection with delivery of the Services.
Sign Up for Marketing Email and Other Communications:We may offer you the ability to sign up to receive EnrolHere marketing and promotional communications through the Website, on third party websites (including through social media sites), or educational events and information sessions. In these circumstances, we collect certain personal data (such as first and last name, email address or mobile phone number) which we use to send you email and other communications containing EnrolHere updates, tips, and other content that may be of interest to you. You can opt out of receiving promotional email from us by following the “opt-out” or “unsubscribe” instructions provided in your email or text message, or by contacting us as set out below. Please note that you may continue to receive messages from us regarding your application or other transactional and account-related electronic messages from us.
Participate in Our Surveys and Customer Research:From time to time, we may offer you the opportunity to participate in one of our surveys or other customer research. The information obtained through our surveys and customer research is used in an aggregated, non-personally identifiable format. We use this information to help us understand our customers and to enhance our product and service offerings, promotions, and events.
Sign Up for Contests and Promotions:When you participate in a contest or promotion, we may collect your name, address, phone number, email address, and other information you provide. We use this information to administer your participation in the contest or promotion. If non-identifiable data is used for research purposes, then the limitation of liability and indemnity clauses if any contained within the Terms and Conditions are waived with respect to any harms suffered or liabilities incurred as a result of any research activities.
Improve our services and develop new products:EnrolHere uses information to improve our services and to develop new products, features, and technologies that benefit our users, our students, and our institutional partners.
Apply for Employment at EnrolHere:In connection with a job application or related inquiry regarding potential employment with EnrolHere, you may provide us with certain personal data about yourself (such as that contained in a resume, cover letter, or similar employment and education-related materials). We use this information for the purpose of processing and responding to your application for current and future career opportunities.
Apply To Become an EnrolHere Recruitment Partner:In connection with applying to become a potential recruitment partner with EnrolHere, you may provide us with certain personal data such as your first name, last name, address, email address, personal data about your education and employment background and banking data. We use this information for the purpose of processing and responding to your application to become an EnrolHere Recruitment Partner and for paying you as needed using third party payment processors.
Apply To Become an EnrolHere Counsellor:In connection with applying to become a potential counsellor with EnrolHere, you may provide us with certain personal data such as your first name, last name, address, email address, personal data about your education and employment background and banking data. We use this information for the purpose of processing and responding to your application to become an EnrolHere Counsellor and for paying you as needed using third party payment processors.
You are responsible for providing accurate and up-to-date information.
Your Rights
You have certain rights relating to your personal data, subject to local data protection laws. Appendix 1 describes some of these rights in detail and explains how you can exercise them. Depending on the applicable laws, these rights may include the right to:
- Be informed of how your personal data is used, collected, or shared;
- Access your personal data;
- Correct or rectify inaccuracies;
- Erase your personal data (‘be forgotten’);
- Restrict our processing of your personal data;
- Obtain and reuse your personal data;
- Object to the processing of your personal data;
- Not to be subject to a decision based solely on automated-processing, including profiling;
- Withdraw your consent; and
- Right to report or complain.
You may access, update and correct inaccuracies in your personal data in our custody or control at any time, subject to limited exceptions prescribed by law. Simply log into your account, go to your account profile, and make the necessary changes.
You can also request access, corrections or updates other personal data in our records by contacting us as set out below. We may request certain personal data for the purposes of verifying the identity of the individual seeking access to their personal data records.
You may request your data be withdrawn (forgotten); this type of request can be performed assuming EnrolHere is in a legal position to fulfill such a request. You must not have an active study application where financial or billing records are or may be in process should an application to a third-party service be engaged. Should EnrolHere be able to comply with your request, only the personal data you provided will be forgotten. Non-personal data (“Metadata”) will be maintained regardless.
Should you wish to lodge a concern or complaint to EnrolHere, please contact us as set out below. We will respond to your concerns in a reasonable time, typically within 10 business days
Please note that these rights are not absolute. In some cases, we may refuse a request to exercise particular rights if complying with it means that we are not able to meet our contractual obligations and provide our Services to you. We will keep you informed as to the actions that we can take when you make your request.
We are not responsible for the privacy practices of our third-party service providers and recommend that you review their privacy policies carefully. We may communicate with our third-party service providers, to the extent permitted by law, when you make a request based on your personal data rights that involves the data collected by our third-party service providers. We will keep you informed on the status of your request in such cases.
Contact Us, Questions, Updating Your Info, Opting Out
If you are an EnrolHere Services customer and would like to update your personal data, please log into your "My Account" in order to update certain information or contact us through the contact information below. If you are not an EnrolHere Services customer, but have provided us with personal data or if your personal data was provided to us by third parties, and you would like to update your personal data, you may contact us through the phone number or email address listed below. From time to time, we may email you or send you with special offers; you may opt-out of those offers by using a link provided in the email, or by contacting us as noted below.
Please contact our Data Privacy Officer if:
- You have any questions or comments about this Policy
- You wish to access, update, and/or correct inaccuracies in your personal data and are unable to do it yourself, or
- You otherwise have a question or complaint about the manner in which we or our service providers treat your personal data.
You may contact our Data Privacy Officer by email at [email protected] or [email protected] or by mail at the following address:
EnrolHere Inc.
101 Frederick Street, Suite 600
Kitchener, ON N2H 6R3
Canada
Toll-Free Phone: 1-844-972-7759
AApplyProof
101 Frederick Street, Suite 600
Kitchener, ON N2H 6R3
Canada
Toll-Free Phone: 1-844-972-7759
Appendix 1: Additional Terms for EEA and UK Customers
The information below is required pursuant to EEA law regarding privacy and data protection. The terms below apply to our EEA and UK customers and various utilities, in addition to the terms in the rest of this Policy.
For the purposes of the General Data Protection Regulation ("GDPR"), the data controller is EnrolHere (or "it"). Frederick Chaves, Suite 600, Kitchener, ON N2H 6M3, Canada. If you have any questions about this Policy, please contact our Data Protection Officer (DPO) at [email protected].
If you are unhappy about how we are processing your data or how we have responded to a request or complaint, you have the right to make a complaint to your local supervisory authority.
WHEN DO WE SHARE YOUR PERSONAL DATA?
The table headed "How and Why We Share Your Information" in the main part of the Policy under the heading "WHEN DO WE SHARE YOUR INFORMATION", lists how we may share your information with, which include transfers for reasons of legal compliance and necessarily in order to provide you with our Services.
You should be aware that when sharing your information, it may be transferred to, and stored at, a destination outside the EEA or the UK, as applicable.
Please note that where data is transferred outside of the EEA, non-EEA countries may not offer the same level of protection for personal data as is available in the EEA. EnrolHere will take various measures to ensure that your data is treated securely, which may include, but not be limited to:
- accessing the security measures used at any party your personal data is transferred to;
- having suitable contract terms in place that oblige a data processor to only process in accordance with our instructions;
- having monitoring, reporting and resolution procedures in place with regard to ongoing security; and
- only transferring your data as appropriate pursuant to Article 46-49 of GDPR, including Standard Contractual Clauses adopted by the European Commission (Article 46.2).
Please contact us at [email protected] if you require more detailed information about international transfers of your personal data, and the particular safeguards used.
LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA
We process your personal data based on the following legal bases, as recognised by and in compliance with the applicable data protection laws:
- the processing is necessary to perform our contract with you (i.e. the Terms and Conditions that apply as applicable with respect to EnrolHere Services, for the provision of our Services);
- you are obliged to provide us with personal data as it is necessary to enter into and perform our contractual agreements. In the event that you do not wish to provide us with your personal data for the purposes outlined above in the "How and why we use your information" section, we will not be able to perform our contractual agreement with you;
- the processing is in EnrolHere's legitimate interests, and these interests are not overridden by your interests or rights in the processing of your personal data. This may include processing your data for prevention of fraud/abuse activity, internal research and analytics assessment, for purposes of communication with you, and informing you about new products and services we are offering or to promote new products and services of other parties who we think may be of interest to you; etc;
- when we process your data based on our legitimate interests described in the purposes outlined above in the "How and why we use your information" section, we determine if such processing is necessary and we carefully consider the impact of our processing activities on your fundamental rights and freedoms. On balance, we have determined that such processing is necessary to fulfill our legitimate interests and the processing which we conduct does not adversely impact on these rights and freedoms;
- you have given your consent to the processing;
- the processing is necessary to meet a legal obligation which applies to EnrolHere;
Sometimes we process data about you which the law considers to fall within special categories (see section "What data do we process about you?" for more details) in which case, we use one of the following grounds:
- the processing is necessary for the establishment, exercise or defence of legal claims;
- you have freely given your informed, specific consent to the processing; or
- the processing is necessary for reasons of substantial public interest, based on applicable law.
If you would like more information about the legal bases used to process your information, or prefer we rely on alternative interests referred to above, please contact us.
In cases where we have asked for, and you have given, your consent to our processing of your personal data, you have the right to withdraw such consent at any time. You can do this by contacting our DPO at [email protected].
DO YOU HAVE TO GIVE US YOUR PERSONAL INFORMATION?
In most cases, providing your personal data to us is optional; however, if you do not provide it, you will not be able to use our Services. For example, we need details such as your name, address and bank account details so that we can make payments to you and receive payments from you. In other cases, you have a choice over whether we collect your personal data; for example, you can turn off cookies on your browser and we will not place any cookies on your device or computer (although in this case you may not be able to use all parts of our website).
PROFILING AND AUTOMATED DECISION MAKING
We use automated decision making as part of the EnrolHere Services. We use these tools as a measure of fraud prevention and for purposes of security and risk assessment relating to the performance of the EnrolHere Services:
- automated tools are incorporated in our process of approval of your application; based on the information you provide, the tool may advise if additional information is required for the purpose of approval of your application.
- automated tools are incorporated in our process of approval of certain schools or programs or such tools may advise if additional information is required for the purpose of eligibility or determine eligibility.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
EnrolHere will only retain your personal data while it is needed to fulfill the intended purpose for which was collected or as otherwise permitted or required by law or contract (which may be more than when we terminate our information of our relationship with you).
Typically, personal data is maintained during the time you are engaged in the institutional program you applied to, or for up to a year following our last contact with you. We may retain your personal data for:
- legitimate business purposes, such as auditing, account recovery;
- if required by applicable federal, state, provincial or other laws;
- to prevent fraud or future abuse; or
- by contract with a partner and/or institution.
All retained personal data is treated in accordance with this Policy.
If you request that your personal data be removed from our databases and/or systems, it may not be possible to completely delete all your personal data due to technological and legal constraints. However, we will take such steps as are reasonable to securely destroy the information or to ensure that the information is de-identified and/or anonymized as required.
Should you request additional services from EnrolHere which are subject to this Policy, you will be authorizing the retention of data collection and/or processing purposes as a result.
ApplyForm document(s) will be retained for as long as they are needed for the intended purpose, or as required by law or contract (which may extend beyond the termination of our relationship with you).
The entity, student or institutional partner which has uploaded the documents(s) or verification may request premature deletion of uploaded files. This is most likely to occur in the case where a content correction or update is required.
YOUR RIGHTS UNDER GDPR
You have several rights in relation to your personal data which are described in more detail below. You can exercise your rights at any time by contacting us at [email protected].
Accessing your data
You can ask us to:
- Confirm whether we are processing your personal data.
- Give you a copy of that personal data.
- Provide you with other information about your personal data such as what data we have, what we use it for, who we disclose it to, whether we transfer it outside of the EEA and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we carry out any automated decision making or profiling. We aim to give you all this information in this Policy, although if anything is unclear, please contact our Data Protection Officer at [email protected].
You do not have to pay a fee for a copy of your personal data unless your request is unfounded, repetitive or excessive, in which case we will charge a reasonable amount in the circumstances. We will let you know of any charges before completing your request.
Correcting your personal data
You can ask us to correct any personal data which is inaccurate or incomplete (in most cases you will be able to make these changes yourself by logging into your account). This is free of charge.
If we have shared the personal data with anyone else, we will tell them about the correction wherever possible.
If we cannot action a request to correct your personal data, we will let you know and explain why this is.
Erasing your personal data
This right is sometimes referred to as “the right to be forgotten”. This is not an absolute right but you have the right to have your data erased, free of charge, in certain circumstances.
You can ask for your personal data to be erased where:
- it is no longer necessary for the purpose for which it was originally collected or processed;
- we are processing your personal data based on your consent, and you withdraw that consent;
- you object to the processing of your personal data and we do not have an overriding legitimate interest for continuing;
- it has been unlawfully processed;
- it must be erased to comply with a legal obligation;
- it was processed to offer information society services to a child.
There are some exceptions to this right. If one of these applies, we do not have to delete the personal data.
If we have shared your personal data with third parties, we will tell them about the erasure of your data unless this is impossible or would involve disproportionate effort.
Please note, in connection with such requests, that personal data may be either deleted or retained in an aggregated manner without being linked to any identifiers or personal data, depending on technical commercial capability.
Accessing your data
You can ask us to:
- Confirm whether we are processing your personal data.
- Give you a copy of that personal data.
- Provide you with other information about your personal data such as what data we have, what we use it for, who we disclose it to, whether we transfer it outside of the EEA and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we carry out any automated decision making or profiling. We aim to give you all this information in this Policy, although if anything is unclear, please contact our Data Protection Officer at [email protected].
You do not have to pay a fee for a copy of your personal data unless your request is unfounded, repetitive or excessive, in which case we will charge a reasonable amount in the circumstances. We will let you know of any charges before completing your request.
Correcting your personal data
You can ask us to correct any personal data which is inaccurate or incomplete (in most cases you will be able to make these changes yourself by logging into your account). This is free of charge.
If we have shared the personal data with anyone else, we will tell them about the correction wherever possible.
If we cannot action a request to correct your personal data, we will let you know and explain why this is.
Erasing your personal data
This right is sometimes referred to as “the right to be forgotten”. This is not an absolute right but you have the right to have your data erased, free of charge, in certain circumstances.
You can ask for your personal data to be erased where:
- it is no longer necessary for the purpose for which it was originally collected or processed;
- we are processing your personal data based on your consent, and you withdraw that consent;
- you object to the processing of your personal data and we do not have an overriding legitimate interest for continuing;
- it has been unlawfully processed;
- it must be erased to comply with a legal obligation;
- it was processed to offer information society services to a child.
There are some exceptions to this right. If one of these applies, we do not have to delete the personal data.
If we have shared your personal data with third parties, we will tell them about the erasure of your data unless this is impossible or would involve disproportionate effort.
Please note, in connection with such requests, that personal data may be either deleted or retained in an aggregated manner without being linked to any identifiers or personal data, depending on technical commercial capability.
Restricting the processing of your personal data
You can ask us to restrict the processing of your personal data in some circumstances, free of charge. This is not an absolute right. If processing is restricted we can store the personal data and retain enough information to make sure the restriction is respected unless you consent or the processing is necessary in relation to a legal claim or to protect the rights of another person or for reasons of important public interest, but we cannot further process your personal data.
You can restrict the processing of your personal data in the following cases:
- if you contest the accuracy of your personal data, we will restrict processing until we have made sure the personal data is accurate;
- if you object to our processing pending the verification of whether or not our legitimate interests override your interests, rights and freedoms or in connection with legal proceedings;
- if the processing is unlawful but you do not want us to erase your personal data;
- if we no longer need the personal data but you require the data to establish, exercise or defend a legal claim.
If we have disclosed the data to a third party, we will inform them about the restriction unless it is impossible or would require a disproportionate effort. We will tell you if we decide to lift a restriction on processing your personal data.