PRIVACY POLICY

QS Enrolment Solutions Privacy Policy
Last Updated [25 May 2018]

QS Enrolment Solutions provides a web-based customer service solution using an enquiry management platform and admissions management system (“the System”) to education institutions (“Clients”), and online survey service to Clients and to prospective or current students (“Students”). QS Enrolment Solutions is owned and operated by QS Enrolment Solutions (Australia) Pty Ltd (ACN 085 983 875), QS Enrolment Solutions Limited in the United Kingdom (Company no. 00640846) and QS Solutions Sdn Bhd in Malaysia (1096481-M). This Privacy Policy applies to these QS Enrolment Solutions entities (“we“, “us“, “our“). It governs how we collect, store, use or disclose personal information and how personal information is collected, stored, used or disclosed in or for the System.

This Privacy Policy explains how we collect, use and protect personal information in compliance with data protection and privacy laws that apply to QS Enrolment Solutions (“Privacy Laws”). We recognise the importance of your privacy and the rights you have to control how your personal information is collected and used.

1. WHO DO WE COLLECT PERSONAL INFORMATION ABOUT?

This Privacy Policy applies to those circumstances where QS Enrolment Solutions is controller of personal information only. This will be in situations where we process personal information of:
• our Client’s representatives in order to provide services to our Clients. Such information will include their use of the Systems and the services we provide to our Clients;
• individuals who opt in to receive certain surveys from us as described below in Section 2, subheading “Information collected via online surveys”; and
• in circumstances where an individual requests publications, webinars, reports and other content or materials from us.
Please note that we may process personal information in other circumstances as a processor on behalf of our Clients. If you would like to better understand how our Clients process personal data please visit their website.

2. WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE COLLECT IT?

Client information

When Clients contract with us to use our services, they provide us with information necessary to create their institution account and manage Student enquiries using QS Enrolment Solutions’ services. This includes the institution name, and the first name, surname, telephone number and email address of each Client employee or representative who the Client authorises as a user of the System where required.

Information collected via online surveys

We send invitations to participate in our online surveys to those Students whose names and contact information have been provided to us by our Clients. Other individuals, such as, application agents and Client authorised users, may also participate in our surveys. If you have received an email invitation to participate in an online survey, this means that you or one or more of our Clients has indicated to us that you have opted in to receive such email invitations. Should you wish to opt out of such emails, you may do so by clicking on the “unsubscribe” link that appears at the bottom of each email invitation.

You are not required to provide additional personal information in order to participate in a survey, although you may do so at your discretion.

The survey you receive may invite you to participate in a random drawing for a chance to win select prizing. Each such drawing is subject to specific rules, which are made available for you to review prior to entry. Should you choose to participate in a random drawing, you will be required to provide your full name and email address so that we may contact you in the event that you have been awarded a prize. This information will not be combined with your survey results, and we will not use this information for any purpose except to notify you in the event that you have won a prize.

By participating in a survey, you may also opt-in to receive future surveys from us. Should you choose to do so, we may send you emails in the future inviting you to participate in additional surveys. You may opt-out of such participation by clicking on the “unsubscribe” link that appears at the bottom of each email invitation.

Information collected if you request certain content or materials

We make whitepapers, webinars, reports and other content available on our website and other mediums, if you request this information. By providing your details, we will respond to your request to provide you with further information on our products and services. You can opt-out of such activity by clicking on the “unsubscribe” link that appears at the bottom of each email or by advising a staff member over the phone.

Information received from third parties

We collect personal information in the manner set out above. If we receive personal information about you from someone else other than as described above, we will take reasonable steps to ensure you are aware that we have collected such information and the circumstances of the collection. Where we receive information about you from a Client, such reasonable steps involve us obliging the Client to take steps to notify you that such information has been provided to us, where such notice is required by Privacy Laws.

3. WHY DO WE COLLECT PERSONAL INFORMATION?

The information we collect is used to provide our services which include:
• enabling you or the Client whom you represent to access and use the System in order to fulfil our contract with the Client. The legal basis for doing so will be our legitimate interests which are not overridden by the interests, rights or freedoms of individuals;
• delivering content and materials and any communications to individuals if requested to do so. This is based on consent obtained from the individual;
• conducting online surveys with individuals who have opted in to receive such surveys. This is based on consent obtained from the individual;
• awarding Students with prizing, where applicable, if a Student has chosen to participate in a random drawing and is selected as the winner, based on consent obtained by the university;
• providing content and materials such as webinars or whitepapers as requested by the individual. This is based on consent obtained from the individual;
• operating, supplying, maintaining and improving our services and the System. This is conducted on the basis of our legitimate interests which are not overridden by the interests, rights or freedoms of individuals;
• ensuring compliance with our contractual and other legal obligations to Clients. This is based on our legitimate interests which are not overridden by the interests, rights or freedoms of individuals and legal obligations to which we are subject;
• otherwise administering our relationship with you, and Clients including by responding to enquiries and feedback. This will be based on our legitimate interests which are not overridden by the interests, rights or freedoms of individuals;
• to resolve a problem or support issue for a relevant Client. This will be based on our legitimate interests which are not overridden by the interests, rights or freedoms of individuals;
• to protect the rights, property or personal safety of any Client or Client’s authorised user, a Student, any member of the public, or to protect our interests. This will be based on our legitimate interests which are not overridden by the interests, rights or freedoms of individuals or to exercise our legal rights;

(“Main Purposes”)

If you are an authorised user of a Client and you do not wish for us to collect the information described above or stored in the System, we may not be able to fulfill our Main Purposes or supply the services (including access to and use of the System) to you or the Client whom you represent/are employed by.

4. WHO DO WE DISCLOSE PERSONAL INFORMATION TO?

We disclose your personal information only in compliance with applicable Privacy Laws and our agreements with the Client with whom you are associated, for one of the Main Purposes, unless you have consented to a different use or that is otherwise allowed by the Privacy Laws.

We share personal information in the following circumstances:
• when directed or as agreed by the Client that provided (or whose authorised user provided) the information to us (“relevant Client“);
• to our third party service providers to permit them to provide features and services on our behalf (see Third Party Services section);
• within our corporate group (i.e., QS Enrolment Solutions Limited, QS Enrolment Solutions (Australia) Pty Ltd or QS Solutions Sdn Bhd as appropriate) for Client reporting and business administration purposes;
• as may be required by law or as ordered by a court, in which event we shall notify the relevant Client and shall work with them to seek to limit the scope of the required disclosure; or
• in the event of a reorganisation, merger, sale, assignment, bankruptcy or other disposition of our business, in which case the transferred information will remain subject to the terms of this Privacy Policy or a privacy policy in substantially similar terms.

We may use or disclose information that is not personal information, including aggregated, de-identified data, for a variety of purposes subject to applicable law, including:
• to share results with the applicable Client and to inform creation of future marketing campaigns for the applicable Client;
• to develop and improve our products and for customizing the product experience for each user; and
• to demonstrate the effectiveness of QS Enrolment Solutions, including in our marketing materials, industry and Client reports.

We will, if practicable, allow you to use a pseudonym or to not identify yourself (unless this is impractical or against the law). In many instances, if you do not provide us with certain personal information we may not be able to provide you (including a Client) with the relevant product, service or information.

5. USAGE INFORMATION AND TRACKING TECHNOLOGIES

When a Client or any of its authorised users use the System, our servers automatically collects the Internet Protocol (“IP“) address associated with the user’s computer. We may also collect additional information such as the login timestamp, the user’s browser type and version, and the operating system of the user’s computer. This information is logged to help us to diagnose technical problems and to administer the System.

To collect information about an individual user’s use of the System, we use cookies. Please see our Cookies policy here.

We and our third party service providers operating QS Enrolment Solutions services on our behalf, also use pixel tags (also known as “clear GIFs” or “web beacons”.) A pixel tag is a tiny image, typically just one pixel – that can be placed on a Web page or in an email to tell us when you have displayed that page or opened that email.

6. THIRD PARTY SERVICE PROVIDERS

We use third party service providers to facilitate delivery of the QS Enrolment Solutions services and the System on our behalf, and may share personal information with those parties as is reasonably necessary for delivery of those services.

Some of those third party service providers, or the services they provide (including, customer services, IT services, maintenance services, analytics, email management and delivery, database management, and improvement services), may be based around the world. We take care to work with service providers who we consider maintain adequate standards of data security compliance.

Our online surveys are hosted on the SurveyGizmo platform. We recommend that you read the SurveyGizmo privacy policy which can be located by clicking on the following link: Terms of Use and Privacy Policy.

7. YOUR RIGHTS IN RELATION TO YOUR INFORMATION

Subject to applicable Privacy Laws, individuals have the following rights in relation to the personal information we process:
• The right to request access to it
• The right to request us to rectify, update, or erase it
• The right to request us to restrict our using it, in certain circumstances
• The right to object to our using it, in certain circumstances
• The right to withdraw your consent (if you have provided it to us)
• The right to data portability
• The right to opt out from our using it for direct marketing

Individuals may exercise any of these rights by contacting us at onlinesupport@qs.com. For your protection, we may require you to confirm your identity before satisfying the request you have made.

Individuals may opt-out of receipt of emails, or other commercial messages delivered by us on behalf of our Clients by clicking on the “unsubscribe” button that appears on the bottom of each email. Individuals may also contact the Client whose information they have received to request further access to, modification of, or deletion of their information provided to us by the Client.

8. SECURITY

We are committed to protecting the security, integrity and confidentiality of the data we hold through the use of physical and technical safeguards. We use SSL (this is a standard security technology for establishing an encrypted link between a web server and a browser) and server authentication technology to protect data when the System is accessed using a supported web browser.

We host the data that we collect in secure server environments that use a firewall and other industry-standard technology in an effort to prevent interference or access from outside intruders. The Internet, however, is not perfectly secure and we are not responsible for security breaches not reasonably within our control.

9. DATA RETENTION

We retain information gathered through the online surveys and from managing customer service enquiries at the sole discretion of our Clients, and in accordance with our contractual obligations with those Clients. We delete personal information collected from a Client and their associated individuals when the Client’s agreement with us terminates and the relevant Client has complied with all of its obligations as a consequence of termination, other than as required by law. We may retain de-identified information for the purposes described in section 4 above.

10. DISCLOSURE OF INFORMATION TO OUTSIDE JURISDICTION OF COLLECTION

Information we collect or receive is stored in the EU or Australia, and may be processed in the UK, Australia and Malaysia. In addition, where we have engaged third party service providers they may store personal information in locations around the world. You understand that the privacy laws in other countries may not provide the same level of protection as the privacy laws of the country in which the personal information was collected. However, this does not change our commitments to safeguard your privacy.

We comply with applicable Privacy Laws when transferring personal information and ensure that your personal information is protected by implementing appropriate safeguards, such as a European Commission adequacy decision , the EU-US Privacy Shield Certification or the European Commission Standard Contractual Clauses.

11. CONTACT

If you have any concerns or complaints about how we handle your personal information, or if you have any questions regarding this Privacy Policy, please contact our appointed Data Protection Officer, Simon Pennington on simon@qs.com, or contact your closest office:

Australia: Level 2, 452 Flinders Street, Melbourne, Victoria 3000 AUSTRALIA or email onlinesupport@qs.com.

Malaysia: Level 5-Unit 1, Block D (4), Menara TH Sentral, Plaza Sentral, Jalan Stesen Sentral 5, 50470 Kuala Lumpur MALAYSIA or email onlinesupport@qs.com.

United Kingdom: 44 Featherstone Street, London, EC1Y 8RN UNITED KINGDOM or email onlinesupport@qs.com.

In most cases we will ask that you put your request in writing to us. We will investigate your complaint and will use reasonable endeavors to respond to you in writing within a reasonable period after receiving the written complaint. If we fail to respond to your complaint within a reasonable period or if you are dissatisfied with the response that you receive from us, you may have the right, depending on the jurisdiction, to make a complaint to the applicable regulator. In Australia, the applicable regulator is the Office of the Australian Information Commissioner. In the United Kingdom, the applicable regulator is the Information Commissioner’s Office. In Malaysia, the applicable regulator is the Personal Data Protection Commissioner. You also have the right to seek a remedy from a national court.

12. UPDATES TO THIS POLICY

As QS Enrolment Solutions services evolve, we may make changes to this Privacy Policy. The “last updated” note at the top of this page indicates when this Privacy Policy was last revised.

We reserve the right to change this Privacy Policy at any time and notify you by posting an updated version of the policy within our online surveys. If at any point we decide to use your personal information in a manner materially different from that stated at the time it was collected, we will notify you by email or via a prominent notice within the online surveys, and where necessary we will seek your prior consent (either directly or by contacting the Client with whom you are associated).

Changes to this Privacy Policy will become effective when we post the revised Privacy Policy within the System, or otherwise in accordance with the requirements of Privacy Laws.