This Policy applies as between you, the User of this Web Site and Graduate Advantage the owner and provider of this Web Site. This Policy applies to our use of any and all Data collected by us in relation to your use of the Web Site and any Services or Systems therein.
We respect your privacy and are committed to protecting your personal data. This policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Changes to this Policy and your duty to inform us of changes
This Policy may be updated at any time. This version was published on 11th June 2018 and historic versions can be obtained by contacting us.
The data protection law in the UK changed on 25 May 2018 and you will be able to exercise your rights under the new legislation from that date.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means collectively the personal information and credentials used by Users to access Material and / or any communications System on the Web Site;
“Content” means any text, graphics, images, audio, video, software, data compilations and any other form of information capable of being stored in a computer that appears on or forms part of this Web Site;
“Data Protection Laws” means Directive 95/46/EC and Directive 2002/58/EC, in each case as transposed into domestic legislation of each Member State of the European Economic Area and in each case as amended, replaced or superseded from time to time, including without limitation by the EU General Data Protection Regulation 2016/679 of the European Parliament and of the Council (“GDPR“) and/or other applicable data protection or national/federal or state/provincial/emirate privacy legislation in force, including where applicable, statues, decisions, guidelines, guidance notes and codes of practice issued from time to time by courts, any supervisory authority and other applicable authorities;
“Graduate Advantage” means Graduate Advantage, SW310, Aston University, Aston Triangle, Birmingham, B4 7ET;
“Service” means collectively any online facilities, tools, services or information that Graduate Advantage makes available through the Web Site either now or in the future;
“System” means any online communications infrastructure that Graduate Advantage makes available through the Web Site either now or in the future. This includes, but is not limited to, web-based email, message boards, live chat facilities and email links;
“User” / “Users” means any third party that accesses the Web Site and is not employed by Graduate Advantage and acting in the course of their employment; and
“Web Site” means the website that you are currently using (www.graduateadvantage.co.uk) and any sub-domains of this site unless expressly excluded by their own terms and conditions.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Graduate Advantage may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity data which includes first names, maiden names, last names, usernames or similar identifier, marital status, title, date of birth and gender.
- Contact data which includes addresses (including billing and delivery addresses), email addresses and telephone numbers.
- Technical data which includes internet protocol (IP) addresses, your 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.
- Operating data which includes usernames, passwords, your interests, preferences, feedback and survey responses.
- Usage data which includes information about how you use our website and its services.
- Marketing and Communications Data which includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
How we will use your personal data
We have set out below, in a table format, a description of the ways in which we plan to use your personal data and the legal basis which we rely on to do so. We have also identified our legitimate interests where appropriate.
Please be aware that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please do not hesitate to contact us if you require details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will ask for your consent before sending you direct marketing. You will receive marketing communications from us if you have requested information from us, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will not share your personal data with any third party outside Aston University for marketing purposes.
You can ask us to stop sending you marketing messages by contacting us at any time.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like to request an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Changes of Business Ownership and Control
Graduate Advantage may, from time to time, expand or reduce its business and this may involve the transfer of control of certain divisions to other parties. Data provided by Users will, where it is relevant to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Data for the purposes for which it was supplied by you.
In the event that any Data submitted by Users will be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your Data deleted or withheld from the new owner or controller.
Your legal rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
When you contact us to exercise your data subject rights:
- You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
- We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
- We will respond to all valid requests within one month unless otherwise provided for by law, including if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.