UK Privacy Policy

This Privacy Policy (“Policy”) applies your use of to this website https://astonuniversityonline.ca (the "Site") which is run by Aston University in conjunction with Keypath Education UK Limited trading as Keypath Education, a company registered in the UK with company number 09655335 (the “Company”) of Fig Offices 4th Floor, Friars House, Manor House Drive, Coventry CV1 2TE

This Policy also applies to any other contact you have with the Company through and/or on behalf of the partner universities you have specifically requested that the Company contact and liaise with on your behalf (each referred to as a “Partner” and together the “Partners”) as set out in this Policy and including use via our Partner Websites and other third party websites from time to time (“Third Party Websites”). See below for more information.

This Policy sets out what information the Company collects, why we collect it, what we do with it and who we share it with.

The Company as Data Controller

For the purposes of the Data Protection Act 1998 and the EU General Data Protection Regulation 2016/679 (and any replacement or successor legislation as amended from time to time), the Company is a Data Controller in respect of any personal data that the Company collects from you. Personal data is any information about you which relates to you and identifies you. Examples of “personal data” are set out below.

The Company as Data Processor

The Company also acts as a Data Processor in respect of any personal data it receives from and/or collects directly on behalf of each of our Partners. Further information on how your data is processed and for what purposes is set out below and further details will be provided by Partners directly from time to time (and you should ensure you read these carefully also).

What type of information does the Company collect and why?

When you visit our Site, we automatically collect standard internet and website log information and details of patterns about how website visitors behave.

The information we collect includes:

Your internet service provider name;
your operating system;
browser type and browser language;
domain name;
the Internet protocol (IP) address of your computer (or other electronic Internet-enabled device);
your access times;
the website that referred you to us; and
the Web pages you request and the date and time of those requests,
the links clicked

This allows us to find out which parts of the Site are popular or need changing to enhance your Site experience.

Our collection of Site user information may also involve the use of cookies and web beacons. We use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. Please see our Cookies Policy for more information on the cookies we use and the purposes for which we use them. https://astonuniversityonline.ca/cookiepolicy

The Site allows you to interact with the Company primarily through the request form set out on the Site. If you want to use the Company’s services to obtain further details about a Partner(s) or if you request further information about our services, you will need to provide us with some additional personal information eg name and email address so that we can liaise with you in order to deal with your request or query. If you do choose to provide us with your personal information, we will collect that information for our own use and for the purposes described in this Policy.

What type of personal information does the Company collect?

Where you choose to provide personal details to us, whether through the Site or otherwise, we may collect the following personal information from you:

details of your visits to the Site, which includes your IP address, traffic data and location data;
the reason for your contact, which may be an enquiry or a request;
information that you provide when you sign a “Request More Information” form, which may include the course you would like to study, your name, address, email address, telephone number, country of residence, nationality, relevant professional experience, relevant qualifications, intended start date;
information necessary for legal compliance; and/or
if you publicly post about us, or communicate directly with us, on a social media website, we may collect and process the data contained in such posts or in your public profile for the purpose of addressing any customer services requests you may have
information you volunteer to us.
information from social media activity (such as likes, shares and tweets) when you interact with us on social media;
information you provide if you report a problem with our Site or service

This information will be collected primarily from you as information voluntarily provided to us (primarily by telephone) or to our Partners, but we may also collect it where lawful to do so from (and combine it with information from) public sources, third party service providers, individuals who you have indicated have agreed for you to provide their personal information, government, tax or law enforcement agencies and other third parties. We may also collect personal information about you from your use of other Company websites or services.

How does the Company use information about you?

The Company may use information about you for purposes described in this Policy or as otherwise disclosed to you on our Site or with our services.

European data protection legislation sets out specific “lawful bases” for processing personal data. The table below sets out under which basis we process different information about you, and explains the purpose of that processing. It also sets out the specific rights you have in respect of that processing, which may depend on the basis we process it for.

Your Information

Basis of Processing

Purposes of processing

Source information originated from

Contact Information

(In example, including but not limited to):

Full name
Email address
Phone numbers
Address/Location
Contact preferences

The processing is necessary to take steps to enter into a contract with you.

To help us identify you.

To provide you with information and services you have requested.

To provide relevant information to you upon your request, to assist with the enrolment of courses and to facilitate flexible online learning.

To gain insight to provide you with better service.

Request for Information form.

Contact Preference form.

Information volunteered while speaking with an Admissions Advisor.

Adhoc feedback surveys/questionnaires.

Communications, Activities, Posts and Notes
(In example, including but not limited to):
Email communications
Text (SMS) communications
Telephony data and recordings
Advisor notes regarding communications and services being provided
if you publicly post about us, or communicate directly with us, on a social media website, we may collect and process the data contained in such posts or in your public profile for the purpose of addressing any customer services requests you may have

The processing is necessary to enter into and/or perform the contract we have with you

To ensure the quality of our services and interactions with you

To provide you with information and services you have requested

To assist with the enrolment of courses and to facilitate flexible online learning

Keypath’s voice and electronic communications systems

Information volunteered while speaking with an Admissions Advisor

Personal/Demographic Information
(In example, including but not limited to):
Age range
Access to Internet
Currency
Language(s) and first language
Previous and current employer, job title and employment status
Nationality

Education Plans and History
(In example, including but not limited to):

Education level
Degrees held, prior schools attended, transfer credits
Reason for study
English proficiency test information
Prior assessment information
Risk factors for completing course(s) and/or programme(s): Academic, Financial, Personal, Technical
Preferred course(s) and/or programme(s)
Planned enrolment details and/or time
The number of planned course(s) and/or programme(s) and you choose to enrol with
Financial plan for investment in course(s) and/or programme(s)
Course eligibility and prerequisite information;
Application details and status

The processing is necessary to take steps to enter into and/or perform the contract we have with the you.

To send you information about the course, programme and/or university which may be of interest based on the preferences you have indicated and deal with any queries on such information.

To assist with the enrolment of courses and to facilitate flexible online learning

Information directly sent by you to an Admissions Advisor.

Information volunteered by you while speaking with an Admissions Advisor

Where acting on behalf of our Partners we may also process details of:

Course(s) and/or programme(s) admittance and acceptance status;
Official student enrolment details, timing and status;
Module registration details, timing, status and outcome;
Financial records and payments for course(s) and/or programme(s);
Module assessment details and participation; and
Degree path plans (future modules necessary for graduation).

This processing is necessary for the purposes of you entering into a contract with a Partner (and subsequently having that contract performed).

On behalf of a Partner, to provide you with information and services you have requested from the Partner

To assist with the enrolment of courses and to facilitate flexible online learning

Information directly sent by you to an Admissions Advisor.

Information volunteered by you while speaking with an Admissions Advisor.

Information provided to us by the Partner.

Site, Enquiry Submission and Source Information
(In example, including but not limited to):

How did you hear about us?
IP address
Enquiry source provider
(ie: Google Adwords)
Enquiry source details (timestamp, keyword, campaign info, website, page and form identifier)
Site visit details (web usage, traffic statistics and location)
Information that you provide when you sign a “Request More Information” or Download a Brochure”’ form.
Information submitted through our “Refer a friend” form.

Course Performance Statistics
(In example, including but not limited to):

Course and/or programme enrolment pipeline status and dates
Course and/or programme retention rates and statistics

E-mail address, associated cookies data on browsing preferences and behaviour and contact preferences

This processing is necessary for our legitimate business interests.

To respond and/or deal with your request or enquiry and/or to provide information requested to you (including where that information has been requested by a third party through our “refer a friend” form).

To improve and enhance our website and enquiry sources and source providers.

To measure the efficacy of Keypath’s services and our university partner’s courses

To continuously improve Keypath’s services

We consider that we have a legitimate interest in assessing and improving our services, to benefit you in your receipt of any services from us.

To market to you by email or other electronic means where your details were collected prior to 25 May 2018 and where you have not objected to such communications.

To create lookalike audiences through social media to identify those with similar profiles who might also be interested in hearing from us about our services.

Keypath’s websites

Enquiry source provider’s website

Information volunteered while speaking with an Admissions Advisor

Marketing content and testimonials

Name
Contact Details
Course
Year Attended
Opinions
Image
Video

We process this personal data with your consent

For the purposes of posting agreed student testimonials (websites, brochures, emails etc) .

For marketing purposes.

Information provided directly through our Site.

Information directly sent by you to an Admissions Advisor.

Information volunteered by you while speaking with an Admissions Advisor.

In addition, we process all such data for the following additional purposes:

for internal record keeping;
to enable us to contact you by e-mail, text or phone for any of the above reasons;
where necessary as part of any restructuring of the Keypath Group; and for compliance with legal, regulatory and other good governance obligations;
to convert personal information into pseudonymous and or anonymous data and use it (normally on an aggregated statistical basis) for research and analysis to improve Company and Group performance. and
to measure the efficacy of Keypath’s services and our Partner’s courses and to continuously improve Keypath’s services

In each case, we consider the processing of your personal data for the above additional purposes is necessary for our legitimate business interests. The Company has assessed its legitimate interests (as set out above), has balanced those interests against your individual rights and considers that the processing undertaken is necessary and proportionate to those rights in respect of providing and improve its services.

This list may be updated from time to time as business needs and legal requirements dictate. Some of the personal information that the Company maintains will be kept in paper files, while other personal information will be included in computerised files and electronic databases as set out in more detail below.

Does the Company share personal information with third parties?

We may share your information where necessary to facilitate the purposes set out above. We have provided further details of the parties with whom we may share your personal data below. The Company will not sell your information.

We may disclose your personal information to third parties if we are under a duty to disclose or share your personal information, in order to comply with any legal regulations or good governance obligations, or in order to enforce or to protect our rights, property, or safety, or that of other persons with whom we have a business relationship, or to purchasers or prospective purchasers in relation to a disposal of our business or assets.

We may use third party service providers to support our provision of the service. This could include:

Office applications and email and other IT managed service providers (including cloud hosting and support);
Website analytic/testing providers;
Search engine optimisation (SEO) enquiry source providers
SEO link-building partners (based in USA/Canada/Australia/EU)
Banner ad/click-through enquiry source providers
Marketing service enquiry source providers whom we refer to as Pay Per Insertion vendors (PPI) (based in USA/Canada/Australia/EU)
Marketing and advertising agencies and their relevant systems (based in USA/Canada/Australia/EU)
Media management tools
Marketing and email automation
Webinar, meeting, communication and chat services
Social media businesses (including Facebook)

We may also share your personal data with other, less direct, business functions, including (without limitation) IT support, hosting our data on cloud platforms, legal, accounting, audit, consulting and other professional service providers, and providers of other services related to our business. Portions of our services may be provided by organisations with which the Company has a contractual relationship, including subcontractors, and, accordingly, your personal information may be disclosed to them. We only provide these organisations with the information that they need to be able to perform their services.

These companies use information about you to perform their functions on our behalf. We may disclose specific information upon lawful request by government authorities, law enforcement and regulatory authorities where required or permitted by law and for tax or other purposes. Your personal information may also be made available to third parties or partners where necessary as part of any restructuring of the Company or sale of the Company’s business or assets. Personal information may also be released to external parties in response to legal process, and when required to comply with laws, or to enforce our agreements, corporate policies, and terms of use, or to protect the rights, property or safety of the Company, our employees, agents, customers, and others, as well as to parties to whom you authorise the Company to release your personal information.

Sharing information with the Keypath Group (“the Group”)

We may share personal information (and anonymised information) within the Group as needed for reasonable management, analysis, planning and decision making, including in relation to taking decisions regarding the expansion and promotion of our product and service offering, order or customer request fulfilment and for use by those companies for the other purposes described in this Privacy Policy.

Third Party Websites

The Site includes links to the following third party websites:

Some of your personal information from your browsing session may be transferred to such third party websites. Where our website contains links to websites operated by third parties (for example advertisers or affiliates of the website owner), you may provide your personal data to the owners of such third party websites without realising that the use of your data by the third party is not governed by this Policy. You should always check the privacy policies of third party websites before submitting your personal information. Please see our Cookies Policy for more information.

Please note that our Partners will have their own privacy policies and they will be different from ours.

Sharing of your personal information with Partners

In addition to processing your personal information on behalf of our Partners, we may also collect and share your personal information with our Partners for the purposes of the Company and its Partners collaborating in order to develop, deploy and deliver courses to facilitate flexible online learning. For example, we may share the following information:

your name, address, email address, telephone number and/or country;
your preferred course(s) and/or programme(s);
duration of your preferred course(s) and/or programme(s);
enrolment details and/or time
demographic information collected prior to applying at Partner University;
educational history and planning information collected prior to applying at Partner University
the number of course(s) and/or programme(s) you choose to enrol with; and
financial investment in course(s) and/or programme(s).
demographic
Programme of interest
Country of residence (we often highlight the UK-INTL split)
Nationality
Job title or employer, career history or CV if provided in advance for admissibility feedback
Motivation for enrolment
Reason for cancelling the programme
Reasons for not continuing the application process

Will your personal information be transferred abroad?

We may transfer your personal information outside of the EEA to the other members of the Group or to Partners or third parties for the purposes set out above, to facilitate the provision of our services and to address and/or resolve specific product or service issues you have raised with us, where we have been unable to identify the appropriate solution from within the UK. This includes to third party service providers who add and deliver content, tools and resources as part of the courses we deliver. Some transfers of personal information to third party recipients have been explained above.

Where personal information is transferred outside of the European Economic Area (“EEA”), whether within the Group or to Partners or third parties (as set out in this notice), EU and UK data protection laws will not apply but steps will be taken to protect your personal information in that instance consistent with applicable law.

What choices does the Company offer you with regard to direct marketing?

Subject to your consent if required by applicable law, we may use your personal information to provide you with direct marketing information about our products and services as well as those of third parties, and we may permit those third parties to send their own direct marketing to you.Our direct marketing may be by email, telephone, post or SMS or such other method(s) as may become relevant.

We will ensure that any direct marketing from us and which is sent by electronic means will provide a simple means for you to stop further communications, in accordance with applicable law. For example, in emails, we may provide you with an “unsubscribe” link, or an email address to which you can send an opt-out request. In addition, if we need your consent for direct marketing communications under applicable law, and if you provide your consent, you will be able to change your mind at any time.

You may manage your consent preferences in respect of direct marketing activities by emailing contact@keypath.uk.com, or write to:

Keypath Education

Fig Offices

4th Floor, Friars House

Manor House Drive

Coventry CV1 2TE

www.keypath.uk.com

What safeguards are in place to protect your personal information?

We use a variety of security measures to maintain the safety of your personal information. Your personal information is processed, stored and protected by firewalls and intrusion detection systems, plus industry standard encryption. Nevertheless, whilst we take efforts to safeguard your personal information which are consistent with relevant laws, the nature of the internet is such that we cannot guarantee absolutely the security of any personal information you disclose online.

Your Privacy Rights

Your right	What does it mean?
Right of access	Subject to certain conditions, you are entitled to have access to your personal information which we hold (this is more commonly known as submitting a “data subject access request”).
Right of data portability	Subject to certain conditions, you are entitled to receive the personal information which you have provided to us and which is used by us by automated means, in a commonly-used machine readable format.
Rights in relation to inaccurate personal or incomplete data	You may challenge the accuracy or completeness of personal information which we use about you. If it is found that personal information is inaccurate, you are entitled to have the inaccurate data removed, corrected or completed, as appropriate. If you believe any personal information we have about you is incorrect, please contact us at contact@keypath.uk.com
Right to object to or restrict our use of your personal information	Subject to certain conditions, you have the right to object to or ask us to restrict the use of your personal information.
Right to have personal information erased	Where we are using your personal information with your consent (and subject to certain conditions), you are entitled to have your personal information erased (also known as the “right to be forgotten”), e.g. where you think that the information we are using is inaccurate, or the use is unlawful.
Right to withdrawal	You have the right to withdraw your consent to any use for which you have previously given that consent.

Please contact us if you would like to exercise any of these rights or if you have any concern about how your personal information is processed at contact@keypath.uk.com and we will try to resolve your concerns.

If you consider that we are in breach of our obligations under data protection laws, you may lodge a complaint with the Information Commissioner’s Office:

https://ico.org.uk/global/contact-us/

You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the GDPR.

Keeping you informed

We will keep your details on record until we have completely dealt with your request or enquiry and then for 4 years unless otherwise requested or agreed upon with the University Partner you have requested information from, in accordance with data protection and other applicable legislation.

Applicant, enrolment and student details will be kept for the duration that we provide services to the university partner you have requested information from unless otherwise requested or agreed upon with the University Partner.

Changes to this Policy

We keep this Policy under regular review. We may change this Policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. The date at the top of this Policy will be updated accordingly.

We encourage you to check the date of this Policy when you visit the Site for any updates or changes. We will notify you of any modified versions of this Policy that might materially affect the way we use or disclose your personal information.

This Policy only extends to the personal information processed by us and does not, therefore, extend to your use of, provision of data to and collection of data on any website not connected to us to which you may link by using the hypertext links within this website including Third Party Websites.

If you have any questions about this Policy, please contact us at contact@keypath.uk.com or write to:

Keypath Education

Fig Offices

4th Floor, Friars House

Manor House Drive

Coventry CV1 2TE

Accredited • Respected • Valued