Introduction

Welcome to the ExploreX Privacy Policy. This policy outlines your rights under the Data Protection Act 2018 and the UK General Data Protection Regulation. Ensuring the accuracy and currency of your personal data is important to us. If there are any changes to your personal data during your relationship with us, please notify us promptly. To make it easier for you to navigate, this Privacy Policy is provided in a layered format, allowing you to choose the specific areas you are interested in and gather the relevant information. Please note that ExploreX reserves the right to update this Privacy Policy periodically at our discretion. Any changes to the policy will be posted on this page. 

Table of contents

• Important information about this Privacy Policy
• Purpose of this Privacy Policy
• Who is ExploreX?
• Legal basis for processing your personal data
• When do we collect your Personal Data?
• Categories of Personal Data we collect
• Why we use your Personal Data?
• How we look after your Personal Data?
• How long do we retain your Personal Data?
• Sharing your Personal Data
• Processing and Transferring your Personal Data
• Your rights as a data subject
• Complaints
• Contact Details: Data Protection Officer

Important information about this Privacy Policy

It is important that you read this Privacy Policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

ExploreX website may have links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites or links and are not responsible for their privacy policy. When you leave our website, we encourage you to read the privacy notice of every website you visit. This privacy policy applies to ExploreX website https://www.explorex.co.uk/ and ExploreX Ltd. If you have any questions or concerns about our use of your personal information, please contact us using the contact details provided at the bottom of this Privacy policy.

Purpose of this Privacy Policy

This Privacy Policy provides information regarding the types of personal data we may gather from you, the purposes for which we process your data, and the security measures we employ to safeguard it. At ExploreX, we highly value your privacy and are dedicated to protecting your personal information. This Privacy Policy details our identity, the methods by which we collect, share, and utilize your personal data, and the options available to you for managing your privacy rights. It pertains to all individuals who use https://www.explorex.co.uk/ and are associated with ExploreX Ltd.    

Who is ExploreX?

ExploreX operates as a “data controller,” which signifies that we are accountable for determining the methods by which we collect and utilize personal information concerning you. As a data controller, we have an obligation under data protection laws to inform individuals who provide personal data to us, whether directly or through a third party, about the details outlined in this Privacy Notice. ExploreX is a registered limited company operating in the United Kingdom, engaging in education agency and recruitment services. Our office is situated in London, United Kingdom, at the following addresses.

Main Office                                                            
94, Longbridge Road
London- IG11 8SF
United Kingdom

Branch Office
101, 3^rd Floor, Whitechapel High Street
London E1 7RA
United Kingdom

Legal basis for processing your personal data

The Company is a multinational organization and acknowledges that data protection laws may vary across different countries. However, we have outlined below various reasons for which we may collect and process your personal data, including-

Consent

In specific circumstances, we may collect and process your data with your explicit consent, such as when you actively opt-in to receive marketing materials from us. When gathering your personal data, we will strive to collect only the necessary information required to provide our services effectively.

Parental Consent

Depending on the national and, at times, state laws, you may be considered a “minor” or “child” concerning the ability to enter into contracts or provide consent for the collection and processing of your personal data. This indicates that you have not yet reached the legally recognized age of consent. In many countries, including Australia, New Zealand, Canada, Singapore, and the USA, the legal age of consent is commonly set at 18 years. In Europe, it is typical for the legal age of consent to be 16 years, and 13 years in the UK for receiving marketing information. As part of our commitment to safeguarding your rights, if the law identifies you as a “minor” or “child,” we require the consent of your parents or guardians to directly collect and process your data through online services.

Explicit Consent

• Explicit Consent refers to the situation where you are given the choice to agree or disagree with the collection, usage, or disclosure of your personal information.
• If it becomes necessary for us to gather special categories of data from you in order to provide the services you require or fulfil our legal obligations, we will only do so with your explicit consent, in accordance with social protection laws specific to your country or region, or for statistical reporting purposes as requested by authorized entities.
• The special category data that we may request from you includes information such as your racial or ethnic background, as well as your passport or birth certificate, as these details are essential to meet enrolment or visa requirements. Additionally, we may need to collect health-related information (such as medical examination reports and immunization history) in order to provide you with additional support.

Contractual obligations

• In certain circumstances, we will need to collect your personal data to meet our contractual obligations to you.
• We will collect this data so that we can make an offer to you to study or enrol with us or to work with us.
• We will use this data to establish a contract that sets out your obligations as a student or employee and our obligations as the provider of the study services or employment to you.

Legal compliance

If the law requires us to, we may need to collect and process your data for a number of reasons, for  example to:

• Prevent fraud
• Meet the needs of immigration authorities
• Meet the requirements of universities
• Comply with Consumer Protection law

Legitimate interest

In specific situations, we collect your personal data as part of undertaking our legitimate interests in a way which might reasonably be expected as part of running our business and, which does not materially impact your rights, freedom or interests. It might include-

• Staying in touch with you for purpose of staying in touch with ex-students as part of an alumni programme
• Keeping you informed regarding Company highlights and news

When do we collect your Personal Data?

• When you visit any of our website pages, (here we just collect transaction-based data).
• When you apply to register or open an online account via our website or marketing campaigns.
• When you complete our online or paper/PDF application forms.
• When you engage with us on social media.
• When you contact us by any means with queries, comments etc.
• When you book any kind of appointment with us. 
• When you book to attend an event. 
• When you’ve given a third-party permission to share with us the information they hold about you.
• When you attend a university, campus or office, which may have CCTV systems operating for the security of Students, Visitors and Staff. These systems may record your image during your visit.
• When you engage with our online marketing tools, and attend our online admission sessions through tools such as Zoom etc.
• For employees, we collect your personal data throughout the period of your employment with the Company

Categories of Personal Data we collect

a. Your contact and other details i.e. your

• Name, Gender, Date of birth, Religion, Nationality, Ethnicity, Sexual orientation, Marital status, Medical information, Disability information, Postal address (can be a postal box number and/or a street address), Social media contacts, Telephone number/s (mobile and landline), Email address, Next of kin’s details, etc.

b. Identity and Immigration documentation i.e. your

• Passport, Driving licence, National Insurance Number, Identity card, Visa details, Birth certificate, Marriage certificate, TB Certificate, COVID-19 status, Criminal Convictions and offences, etc.

c. Your financial details i.e. your

• Funds details, Sources of funds, Bank details, including statement, etc.

d. Your educational and work history inclusive of but not limited to your

• Current and past qualifications, Grades, Institution/s you studied at, Most recent study experience, Work experience details

e. Details of your interactions with us, such as-

• We collect details of enquiries and comments you make in the web pages you visit or when you contact us by email, telephone or in person

• Information gathered by the use of ‘cookies’ in your web browser. (Learn more about our ‘Cookies Policy’.

f. Additionally, for employment purposes-

• Social security (or equivalent) details, Next of Kin details, Health information, Your image, voice and written contributions.
• As you interact with our website and other platforms made available by the company, we may automatically collect technical data about your equipment, browsing actions and patterns.

Why we use your Personal Data?

In order to provide you with the information and services you need, we may sometimes combine the data we have about you. This is done as part of our legitimate interest to ensure that you receive the appropriate and optimal service.

If you wish to modify how we utilize your data, you can find detailed information in the ‘What are my rights?’ section below.

If you choose not to share your personal data with us or decline certain contact permissions, it may impact our ability to provide some or all of the services you have requested. In such cases, we will reach out to you to confirm your request.

The purposes for which we use your personal data include:

I. Operating and managing our business to deliver the best possible service for queries, admissions, visa applications, etc. This is based on our legitimate business interests.

II. Responding to your queries and fulfilling your requests.

III. Maintaining a record of communications with you. We do this to fulfil our contractual obligations to you, comply with legal requirements, and serve our legitimate interests in providing the best service.

IV. Protecting our business and you from fraud and other unlawful activities. We may also monitor your browsing activity on our websites to promptly identify and resolve any issues and safeguard the integrity of our platforms. We do all of this as part of our legitimate interest.

V. Ensuring the safety of our students, visitors, staff, premises, and assets. In some of our offices, we operate CCTV systems that capture images for security purposes. We do this based on our legitimate business interests.

VI. Processing payments and preventing fraudulent transactions. This is carried out to protect our legitimate business interests and to help safeguard you from fraud.

VII. With your consent, we will use your personal data preferences to keep you informed about relevant services and events through email, web, text, social media, and telephone.

VIII. Protecting your vital interests in cases where you are unable to provide consent.

IX. Hiring and managing employees and contractors. This is done as part of our contractual agreement with you.

X. Sending you communications that are required by law or necessary to inform you about changes to the services we provide. For example, updates to this Privacy Notice.

XI. These service-related messages will not include any marketing content and do not require prior consent when sent via email or text message. It is necessary to keep you informed in order to comply with our legal obligations.

XII. Complying with our contractual or legal obligations to share data with law enforcement when necessary. For instance, if a court order requires us to disclose your personal data to law enforcement agencies or courts of law.

How we look after your Personal Data?

We understand the importance of data security and will handle your data with the highest level of caution and regard, implementing necessary measures to safeguard it. Our websites and apps ensure secure access to all transactional areas through the use of ‘https’ technology. Your personal data is securely restricted and protected, and sensitive information such as health records is safeguarded using password protection and encryption. Paper copies of data are stored securely, and access is managed according to the Company’s access protocols.

How long do we retain your Personal Data?

We retain personal data for necessary durations, considering legal obligations and any potential litigation. Factors like data quantity, sensitivity, risks, processing purposes, and legal requirements determine the retention period. We have a secure records management program for paper-based and electronic records. Personal data is stored safely and only as long as necessary, then deleted or anonymized.

Sharing your Personal Data

We share Personal Data with trusted third parties, such as College/University Partners. We have clear guidelines in place to protect your privacy, including sharing only necessary information, stating the purpose, and requiring privacy protection. If their services end, they must securely delete or anonymize your data. They are also required to notify us of any breaches. These measures ensure your data is handled according to our privacy standards.

The types of third parties we work with include

Educational Agent Groups, IT companies supporting our websites, Cloud storage companies, Customer Relationship Management application providers, Educational establishments, Educational professionals, Regulatory authorities, Accommodation providers, Estate services, Online webinar providers, Insurers, Financial service providers, Travel service providers, Solicitors, British Council, Turnitin etc.

How do third party partners use your Personal Data?

When you use a service from one of our chosen partners, your data will be collected and used by them under the terms of their own separate privacy policies.

Why do we share your Personal Data?

We share your personal data with trusted third parties in specific circumstances, including: obtaining your explicit consent for direct marketing, collaborating with academic professionals, addressing fraudulent activities, complying with legal requests from authorities, and business transfers. These measures ensure your data is handled securely while fulfilling our obligations.

Processing and Transferring your Personal Data

• We have operations in different geographic regions; therefore, we will sometimes need to share your personal data across national boundaries and borders i.e. outside the European Economic Area (EEA).
• If we do transfer your personal data across an international border, we have procedures in place to ensure your data receives the same protection as if it were being processed inside your country of residence for instance an EEA member-country or Australia or Asia or Canada or the USA etc.

Your rights as a data subject

Under certain circumstances, by law you have the right to-

Request access to your personal data

You can request access to your personal data, this is 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

You can send us a request to make corrections (if there is any error) of your personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal data 

Request for erasure is commonly known as “right to be forgotten” – 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 exercised your right to object to processing (see below).

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. You also have the right to object where we are processing your personal information for direct marketing purposes.

Request the restriction of processing of your personal data 

This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal data to another party

This is also known as “right to data portability”. 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.

Request to withdraw consent

In circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us using the contact details in this Privacy Notice. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

If you wish to exercise any of the rights set out above, please contact us to the provided contact details at the end of this policy. For any of the request above:

No fee usually required

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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information 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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month 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.

Complaints

If you have any concerns or complaints regarding the handling of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), which is the supervisory authority for data protection matters in the UK (www.ico.org.uk). However, we kindly request that you give us the opportunity to address your concerns before contacting the ICO by reaching out to us initially. If you need further information or clarification, we are more than happy to provide you with additional details. When filing a complaint about a suspected breach of this Privacy Notice or our legal obligations regarding privacy, please provide us with as much information as possible related to your complaint. This will enable us to address your concerns promptly and effectively. We take all privacy complaints seriously and will carefully evaluate them with the objective of resolving any issues in a timely and efficient manner. Your cooperation during this process by supplying any relevant information that may be required is greatly appreciated.

Contact Details: Data Protection Officer

If you wish to exercise any of the rights set out above, please contact our Data Protection Officer.

Mr. Mahabub Abdul in writing with full details of your request. 
Email: info@explorex.co.uk Telephone: +44 (0) 2034884291