Privacy | Educatly

Introduction to Our Identity

Welcome to Educatly, an ensemble comprising Educatly Limited in Ireland, along with our sister entities Educatly Limited in the Egypt, collectively referred to as "Educatly," "our," "us," or "we." Our mission extends beyond being an Educational network; we are dedicated to ensuring the transparency of your personal data, the very purpose of this privacy policy. Registered under the Ireland Information Commissioner’s Office, our registration number is 675774. This privacy policy, in conjunction with our Cookie Policy, Terms of Use, and where relevant, the privacy policy of your Education Provider, delineates the foundation for processing any Personal Data we gather from you through our services accessible via our website at http://educatly.com/ (termed "our Website"), or through the utilization of services provided through the Website. This includes:
- Educatly Chat,
- the Educatly widget located on an Education Provider’s website,
- and any of the Educatly Mobile Apps,
all of which are collectively referred to as the Platform. Should you have any inquiries, please feel free to reach out to our approachable team at support@educatly.com.

Terminology Explained

Ambassador refers to an individual representing an Education Provider, engaging with users on the Platform as the institution's emissary.
Business and Service Provider are understood as per their definitions in the CCPA.
End User denotes any individual interacting with or accessing the Platform, inclusive of Prospective Students, Ambassadors, administrators, and other staff associated with an Education Provider.
Consumer encompasses any End User, individual browsing the website, or applicant for a job.
Data Controller, Data Processor, Data Subject, and Supervisory Authority are defined in alignment with Data Protection Laws.
Data Protection Laws encompass Regulation (EU) 2016/679 (the GDPR), its implementing legislation and regulations including the Data Protection Act 2018 (the DPA), and state-specific regulations in the USA such as the California Consumer Privacy Act of 2018 (the CCPA), California Privacy Acts Right of 2023 (the CPRA), the Virginia Consumer Data Protection Act of 2023 (the VCDPA), Connecticut’s Data Privacy Act (CTDPA), the Utah Consumer Privacy Act (UCPA), among others, and any local amendments over time.
Education Provider is defined as any educational institution, like a college or university, that holds a subscription license for the use of the Platform.
Education Provider Staff includes any employee or authorized individual from an Education Provider with Platform access.
Partner signifies any third party hosting the Educatly widget on their site or any entity with a commercial tie to Educatly.
Personal Data refers to information that can identify or is related to a specific individual, also known as “personally identifiable information” or “personal information” in the realm of applicable Data Protection Laws.
Prospective Student is an individual showing interest in or applying to an Education Provider.
Educatly Chat is a feature within the Platform allowing End Users to navigate the Education Provider's website, which showcases profiles of Ambassadors and Education Provider Staff, facilitating communication between End Users and selected representatives.
Educatly Community is a component of the Platform enabling interaction in an open forum among End Users, Ambassadors, and Education Provider Staff.

Employment Candidates and Data Submission Guidelines

Employment Candidates

- For individuals applying for positions at Educatly, we assume the role of Data Controller for your personal information. Specific sections of this privacy policy are pertinent to how we handle your data.

Age Restrictions for Users

- To access and use our Platform, individuals must be at least 13 years old, or meet the higher age requirement mandated by their local jurisdiction, without needing parental consent. Access to certain functionalities of our Platform is limited to users older than 18. Verification of age may be necessitated, and for those under the age of consent, parental permission is mandated for Platform use.

Providing Your Data

- Your data is collected by us through various methods, including but not limited to:
- Filling out forms on our Website or Platform, or during interactions via phone, email, or other channels.
- Registering for an account on our Platform.
- Utilizing the services provided on our Platform.
- Reporting any issues encountered with our Platform.
- Participating in surveys we may offer.
- If you are providing information on behalf of someone else, it is imperative that you have their explicit consent prior to sharing their information with us.
- It is important to note that any mention of "your data" within this privacy policy encompasses information regarding third parties that you may provide.

Data Collection Overview

Data Gathering Methods

Our Data Collection Practices As the Sole Data Steward For Users and Site Visitors When Educatly initiates the collection of Personal Data to set up a Prospective Student account on Educatly, we act as the sole stewards of this data. We decide on the utilization of this Personal Data to optimize the service provided through our Platform, adhering strictly to the stipulations of Data Protection Laws.

For All Platform Users

Each time you visit our Website or engage with our Platform, we may gather specific data automatically, which includes:
- Information specific to your device, like the make and model, the operating system version, unique identifiers, and network details.
- Technical data about your computing device, such as the IP address, operating system, and browser type, aimed at system management and for analytical objectives.
- Records of your interactions with our Website, capturing the entire path of your navigation (URL clickstream) to, through, and from our site, inclusive of the date and time, duration of page visits, and interaction details like scrolling, clicking, and hovering over elements, alongside noting whether the interaction was via the Website or the Platform.
Beyond the scenarios highlighted, Educatly serves in the capacity of a Data Processor and Service Provider, with the Education Provider acting as the Data Controller.

As a Data Processor

Concerning the Platform's End Users, we gather contact details as outlined in a subsequent section (utilization and rationale for information use). Our collaboration with Education Providers helps pinpoint the specific Personal Data to be collected from End Users and the purpose behind it. In this context, Educatly functions as the Data Processor, with the Education Provider being the Data Controller.
When Education Providers entrust us with the Personal Data of their Ambassadors and End Users, we process such information, which could encompass:
- Contact details like phone numbers and email addresses,
- IP addresses,
- Nationality,
- Field of study,
- Personal interests,
- Educational attainment,
- Any pertinent data shared by the Education Provider,
- Other forms of Personal Data voluntarily shared by End Users while interacting with the Platform, including, but not limited to, widget interactions and Educatly Events participation.
Educatly refrains from seeking special category Personal Data for Platform operations. Despite the possibility of such data being shared in open communications, we advise against sharing sensitive personal information.

Information shared with other sources

Collaborative Data Integration

- From Educational Institutions and Service Vendors: To enhance the functionality and accessibility of our Platform for users, Educatly integrates data from educational entities and taps into the analytics expertise of service providers. This integration supports various aspects of platform interaction, including user support and experience enhancement.
- Third-Party Collaborations: We partner with companies specializing in customer experience to gather insights through user interviews, among other methods. Such collaborations may result in the sharing of your Personal Data with Educatly to better understand user preferences and experiences. Notifications will be provided before any such data sharing occurs. Additionally, our platform's infrastructure is supported by certified cloud service providers, ensuring robust and secure service delivery.
- Social Media Dynamics: By linking your social media accounts through specific credentials or engaging with our Platform via third-party services, you acknowledge the potential sharing of information from these social media accounts with our platform.
- Partner Interactions: Engaging with Educatly through partner sites may lead to mutual data sharing, indicating a collaborative effort to enhance your platform experience.

Principles Guiding Data Utilization

- Rationale Behind Information Utilization: The processing of personal information within Educatly adheres to stringent legal bases as mandated by data protection laws. Each interaction involving personal data is grounded in:
- Consent: Your voluntary agreement to data use, which can be retracted as per outlined procedures.
- Contractual Necessities: The essential use of information for contract initiation or fulfillment.
- Regulatory Compliance: Utilizing data as required by legal obligations.
- Balanced Interests: Employing information to fulfill legitimate organizational objectives without infringing on individual data rights.
- Defensive Measures: The application of data in legal defenses or claims.
- Within the scope of our platform's operation, whether acting independently or in conjunction with education providers, Educatly responsibly manages the data shared by you and about others, always aiming to enrich the platform experience and adhere to established data use principles.

Types of Information Collected	Use Justification	Lawful Basis
All End Users
First name, surname, email, phone number, academic and preference information in your profile	To provide you with access to our Platform and any other information which you request from us and to notify you of changes to our Platform.	Contract performance
First name, surname, email, phone number, academic and preference information in your profile	To enable you to communicate with Ambassadors using the Platform and other End Users via Educatly Community (if applicable).	Contract performance
First name, surname, email, phone number, academic and preference information in your profile	To send automated product communications to support the operation and your use of the Platform	Contract performance
First name, surname, email, phone number, academic and preference information in your profile	To send automated product re-engagement communications for marketing purposes	Legitimate interest
First name, surname, email, phone number, academic and preference information in your profile	To send automated product re-engagement communications for marketing purposes	Legitimate interest
Information we collect about you (as detailed above)	To administer and improve the Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes in a pseudonymised manner. To conduct and facilitate user experience research, including to gauge feedback on new products and features in early stages of development, to determine whether those new products and features would be of sufficient value to users. To ensure the content on our Platform is presented in the most effective manner for you and your computer or mobile device.	Legitimate interest (to improve the Platform and report internally on usage and gain insight on user basis at a statistical level)
Conversation history and information, including First name and Surname, submitted when interacting with End Users and Ambassadors (as applicable). Conversations can also be ‘tagged’ to group conversations under certain topics.	To allow End Users to interact as part of the Platform. To enable the Education Provider to analyse Ambassador conversations. To provide a high-level summary of the conversational data to the Education Provider. To enabled Education providers	Contract performance Legitimate interests to allow the Education kProvider to assess the type of questions being asked and the quality and appropriateness of the responses.
Ambassadors
Your first and last name; photo; phone number, email address, encrypted password; country/city/location, country flag; languages spoken; academic history (and previous high school; degree/university degree; degree level (undergraduate/postgraduate); current area of study; university year (1st, 2nd etc.); Occupation; and Hobbies, interests and societies; and an ‘about me’ free text selection.	To provide a public bio of the Ambassadors in order for End Users to find the appropriate person to interact with.	Contract performance
Customer Staff and Other Customer End User:
First and last name email address, encrypted password; (If applicable) Mobile phone number; Country; Degree level. Chat conversations and interactions with Ambassadors. Education Providers may request additional Personal Data to be processed for use of the Platform.	To enable Education Provider End Users to engage with the Platform.	Contract performance Legitimate interest to ensure the database is accurate and up to date and communicate with End Users.
First name, surname, email, the degree and level of study you are interested in and your country of origin. Customers may request additional Personal Data to be processed for use of the Platform.	To enable Customers to market products and services that they believe will be of interest to you.	Consent (you have the right to unsubscribe at any time by contacting the Customer).

We will not share your Personal Data (or any other data you provide us with) to third parties for any purpose other than those listed in our sub-processors page. We will not sell your data to any third parties.

Disclosure of your information

We may also disclose your personal information to third parties in the following circumstances

Purpose of disclosure and third party(s) to which disclosure might be made	Use Justification
Educatly may share certain Personal Data with Education Providers and Partners where the third party acts as a Data Processor. Such Personal Data may include: Personal Data submitted in the creation of a Educatly account (such as name, email, etc); any Personal Data submitted via the Platform, services such as the widget, and Educatly Events.	Contract performance Legitimate interest (to allow our Service Providers to provide the necessary services)
We may disclose your Personal Data to our Service Providers to assist us in performing any contract we enter into with them or you, including providing the Website and the services it enables, analytics providers, and/or a member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries	Contract performance Legitimate interest (to allow our Service Providers to provide the necessary services)
If Educatly or substantially all of its assets are acquired by a third party, personal information about Education Providers will be one of the transferred assets.	Legitimate interest (to sell our company or assets), Consent (for sensitive Personal Data)
If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation or to protect the rights, property, or safety of Educatly, our Education Providers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection. For End Users – in the event you are in a breach of our Acceptable Use Policy or where we are under a lawful obligation to share your Personal Data, we might share it with the Education Provider, including conversation history.	Legal obligation.
We may disclose your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with proceedings or investigations anywhere in the world where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.	Legal obligation

Duration of Personal Data Retention

Retention Period of Your Personal Data

We will preserve the data mentioned for the time necessary to ensure your access to our Platform, to resolve any specific issues that may occur, or as required by law or any appropriate regulatory authority.
When Educatly is in the role of Data Controller, you have the option to delete your account. Once you do so, your Personal Data will be swiftly and securely eradicated.
There may be a need to retain some Personal Data for a more extended period to align with Educatly's compliance with legal standards and internal procedures, including the retention of your email address for opting out of marketing communications if you choose to no longer receive marketing. If data is utilized for more than one purpose, we will retain the data until the time limit of the more extended purpose is reached and discontinue its use for the purpose that expires sooner.
We limit access to your personal information to only those individuals who require it for relevant purposes. Our data retention timelines are determined by our business needs, and any information no longer necessary will be either irreversibly anonymized, with the anonymized data possibly being retained, or securely destroyed.

Locales of Personal Data Storage

Storing Your Personal Data

- Your Personal Data is preserved, handled, and secured by Educatly alongside our sanctioned Service Providers across the United States, Europe, and Ireland. Additionally, your Personal Data might be stored in various locales deemed essential for the efficacious functioning and provision of our Platform services, or as mandated by legal statutes.
- Despite the potential variation in privacy regulations across different regions, Educatly, together with our partners and Service Providers, pledge to safeguard Personal Data in alignment with the mandates of this privacy policy, upholding conventional industry practices and employing legitimate legal frameworks and contractual commitments that enforce robust data protection, even surpassing the minimal legal stipulations of certain jurisdictions.
- Educational entities operating beyond the borders of the European Economic Area may be governed by distinct local data privacy laws. We provide an exhaustive directory of our external Service Providers, including insights into their privacy policies [on our website], subject to periodic updates. Your continued engagement with our Platform signifies your accord with the Service Providers delineated herein. Upon revision of our Service Providers' roster, you will be accorded a notification and a grace period of 30 days to review and either consent to the updates or opt to cease using our Platform.

Your rights

General Data Protection Regulation (GDPR) Under the GDPR and DPA, you have various rights in relation to your Personal Data. Ambassadors, Education Provider employees and Students should contact the Education Provider in the first instance as their Data Controller. All other End Users should contact Educatly in the first instance as their Data Controller at support@educatly.com. The Data Controller is primarily responsible for ensuring you can exercise these rights and the Data Processor, shall assist the Data Controller to effectively exercise your rights. You have the following rights in relation to your Personal Data.

Rights	Details
Right to access	You have the right to access Personal Data held by the Controller(s), including a description of your data. Personal Data processed can be found in the profile section of your Educatly account, while further information is available on request.
Right to rectification/correction	You have the right to rectify any details to ensure that your personal information is accurate. In order to assist with this, you should notify the Data Controller of any changes to the personal information that you have provided by sending a request to rectify your Personal Data where you believe the Personal Data collected is inaccurate or incomplete.
Right to erasure/ ‘Right to be forgotten’	Asking the Data Controller(s) to delete all of your Personal Data will result in the deletion of your Personal Data held by that Data Controller without undue delay (unless there is a legitimate and legal reason why the Data Controller is unable to delete certain Personal Data, in which case you will be informed of this in writing).
Right to restriction of processing	You have the right to ask the Data Controller to stop processing your Personal Data at any time in certain circumstances. Such a request will result in the Data Controller restricting its processing of such data.
Right to data portability	You have the right to request that the Data Controller provides you with a copy of all of your Personal Data and to transmit your Personal Data to another Data Controller in a structured, commonly used and machine-readable format, where it is technically feasible to do so where such processing is based on consent or pursuant to contractual performance.
Right to complain	You have the right to lodge a complaint to a Supervisory Authority such as the Information Commissioner’s Office in the Ireland (see (https://www.oic.ie). Although we encourage Education Providers to engage with us in the event they have any concerns or complaints.

Educatly typically does not impose any fees for processing your requests to exercise your rights as outlined previously. Nonetheless, should your requests become excessive, repetitive, or clearly groundless, we reserve the right to levy an administrative charge to handle such requests or decide not to fulfill them. Providing a copy of your Personal Data that is subject to processing will incur no cost for the first instance; however, subsequent requests for additional copies may attract reasonable fees reflective of administrative costs.
Should you request the cessation of processing or the deletion of your Personal Data, it is likely to impede your ability to use Educatly's Platform, specifically those services that necessitate the Personal Data you wish to have removed, ultimately possibly preventing your use of the Platform entirely.
In the event you enact any of your rights mentioned, the Data Controller might inform third parties who have been privy to your Personal Data about your request. Yet, these third parties may maintain the right to hold and process such Personal Data for their own purposes.

State of California, USA – Resident Rights

If you are a resident of the State of California, USA, you have the rights outlined in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. If there are any conflicts between this section and any other provision of this Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at support@educatly.com.
You have the following rights under the USA state-specific legislation:

Rights	Details
Right to access	You have the right to access Personal Data held by the Business, including a description of your data. Essential Personal Data held by the Business can be found in the profile section of your Educatly account, while further information is available on request. The categories of sources from which Personal Data was collected. The business or commercial purpose for collecting your Personal Data. The categories of third parties with whom we have shared your Personal Data. The specific pieces of Personal Data that we have collected about you. If we have disclosed your Personal Data for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient.
Right to correct inaccurate information	You have the right to rectify any details to ensure that your personal information is accurate. In order to assist with this, you should notify the Business of any changes to the personal information that you have provided by sending a request to rectify your Personal Data where you believe the Personal Data collected is inaccurate or incomplete.
Right of deletion	Asking the Business to delete all of your Personal Data will result in the deletion of Personal Data held by that Business without undue delay (unless your Personal Data is required to provide you with the Platform or complete a transaction or other action you have requested). If your deletion request is subject to one of these exceptions, your deletion request may be denied, in which case you will be informed of this in writing.
Right to know what data is being sold or shared and to whom	We do not sell personal information to any third parties.
Right to Opt-out of Sale and data sharing	You have the right to request that the Business does not sell or share your Personal Data to third parties.
Right to Opt-out of automated decision making	We do not utilise automated decision making.
Right to limit disclosure and use of sensitive information	You have the right, at any time, to direct the Business that collects sensitive personal information about you to limit its use of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services.
Right of no retaliation	We will not discriminate against you for exercising your rights. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA and CPRA.

Subject Access Request/Valid Request

To assert the rights mentioned prior, you must dispatch a Subject Access Request/Valid Request to us, which should (1) furnish ample details for us to confirm your identity as the individual whose Personal Data we have gathered, and (2) clearly articulate your request, allowing us to accurately interpret, assess, and address it. A request that fulfills these conditions will be recognized as a "Valid Request." Requests failing to meet these stipulations may not receive a response. The Personal Data supplied in a Valid Request will be employed solely to affirm your identity and to fulfill your request. Holding an account is not a prerequisite for submitting a Valid Request.
In instances where you choose to exercise your right to know or to have your Personal Information erased through an Authorized Agent, that agent is required to provide documented authorization to represent you, and you might need to validate your identity and residency. Requests made through Authorized Agents that adhere to the aforementioned guidelines will be regarded as Valid Requests.
Our commitment is to address your Valid Request within a 30-day timeframe upon receipt, aligning with the stipulations of the GDPR and DPA, and within 45 days under the CPPA/CPRA. No fee will be levied for processing a Valid Request unless it is characterized as excessive, recurrent, or without a sound basis. Should your Valid Request necessitate a fee, we will inform you of the cost and provide a rationale prior to fulfilling the request.
Valid Requests can be submitted to us via email at support@educatly.com

Cookies

Educatly, alongside our external partners like those specializing in analytics, employs cookies and various tracking methods (for instance, web beacons, device identifiers, and pixels) to enhance functionality and to recognize users across multiple services and devices. To learn more, please refer to our Cookie Policy, which also provides instructions for managing or opting out of these cookies and tracking tools.

External Websites

Our website occasionally includes hyperlinks to external sites. It's important to understand that these sites have their own privacy guidelines, and Educatly does not bear any responsibility for their privacy practices or the handling of your personal information. Always review these privacy guidelines before providing personal details to these external sites.

Policy Updates

We reserve the right to amend this privacy policy. Should there be any substantial modifications, we will clearly announce these on this page or through alternative communication methods, such as email or notifications through the Platform. Your continued engagement with the Platform and the Website implies agreement to any updates to this privacy policy.

Contacting Us

For any inquiries or to exercise your rights as previously described, please get in touch with us at support@educatly.com. Your feedback is greatly appreciated, and we are open to suggestions that could help enhance and clarify our privacy policy.

Privacy Policy