The purpose of this document
Hands On Education Consultants Co.,Ltd. (“Hands On”, “us” or “we”) is committed to maintaining the privacy and security of your personal data. This Privacy Notice explains how we collect, use, share and protect your personal data.
Hands On is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. Where we act as a data controller, we are required under data protection legislation to notify anyone who provides personal data to us, either directly or through a third party, of the information contained in this Privacy Notice.
It is important that you read this Privacy Notice so that you are aware of how and why we are using your personal data. By using our services (for the purpose of this Privacy Notice, including processing applications, recommending accommodation, finding flight tickets and insurance), you agree and consent to the terms of this Privacy Notice.
What is personal data?
Personal data is any information about an individual from which that individual can be identified, whether separately or in combination with other information. Your name, address, phone number and bank account number are examples of personal data.
It does not include data where the identity has been permanently removed (anonymous data).
Data protection principles
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform a contract we have entered into with you.
- Where we need to comply with a legal obligation in connection with your use of our services.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests in connection with your use of our services.
- Other circumstances where you explicitly consent to us using your personal data.
We may also use your personal data in the following situations, to the extent required or permitted by law, which are likely to be less common:
- Where we need to protect your vital interests (or someone else’s interests).
- Where it is needed in the public interest or for official purposes.
Situations in which we will use your personal data
Enquiries
When you request information or make enquiries about any of our services or programmes, we may use the personal data you provide in order to fulfil your request or respond to your enquiry. It is in our legitimate interests to use your personal data in this way so that you receive the information you have requested.
Applications
If you make an application to study at one of our partner institutions we may collect the following categories of personal data about you:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
- Date of birth.
- Gender.
- Nationality and country of residence.
- Passport number.
- Visa information and immigration status.
- Education history.
- Employment history.
- Funding information.
It is in our legitimate interests to collect and use the above information in order to consider and process your application.
We may also ask you to disclose information regarding any criminal convictions you may have as part of your application. We need to use this information in order to comply with our legal obligations for processing your application.
Study and accommodation
If we enter into a contract with you relating to study or accommodation, we may collect additional personal data relating to you including:
- Bank account details.
- Billing address.
- Credit card or other payment information in order to process your payments.
This information, together with the personal data provided to us above at application stage, will be used by us to perform the contract we have entered into with you.
We will also collect further personal data relating to your visa application and immigration status as we have a legal obligation to use this information for performing our contract with you.
During your studies we will collect information about your academic experience and progression. This is in order to fulfil our contract with you but it is also in our legitimate interests to use this personal data in order to monitor the provision of our service to you.
We may also collect personal data about your health in order to make appropriate arrangements and reasonable adjustments for you regarding your welfare, attendance or accommodation. We use this information in order to perform our contract with you but it also may be in your vital interests for us to do so.
We may also collect personal data about you if you are named as an emergency contact for an individual. We use this information as it is in the vital interests of such individual.
Marketing
Where you have explicitly consented to do so, we may use your personal data to inform you of special offers and new or existing services that we believe may be of interest to you or to send surveys or questionnaires so that we can learn more about your needs and interests.
If you would prefer that we do not send such communications to you, please see the “Your rights as a data subject” section below.
Internal business purposes
We also may use your personal data for our internal business purposes. This is in our legitimate interests in order to operate as a business and monitor and improve the services we provide. Where possible we will anonymise this information. Please contact us using the contact details below if you would like more information.
If you fail to provide personal data
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you or we may be prevented from complying with our legal obligations that allows you to use our services.
When and how we share your personal data with others
We may, to the extent as permitted by applicable law, share your personal data with third parties where required by law, where it is necessary to perform our contract with you or where we have a legitimate interest in doing so in connection with your use of our services.
Such third parties may include the following:
- Our service providers: We may share your personal data with other companies that perform certain services on our behalf. These services may include processing payments, providing customer service and marketing assistance, performing business and sales analysis and supporting our website and IT functionality. These service providers may be supplied with or have access to your personal data solely for the purpose of providing these services to us or on our behalf. Hands On is the data controller and will remain accountable for your personal data.
- Our business partners: We may share your personal data with our university partners or with your sponsor with whom we have a contract relating to your programme of study in order to allow you to enroll or study your programme.
- Parents and guardians: If you are under 18, we may share your personal data with your parents or guardians in order to perform our contract, comply with our legal obligations and if it is in your or your parents or guardians’ vital interests.
- Other entities in the Hands On International group: We may share your personal data with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganization or group restructuring exercise or for system maintenance support and hosting of data.
- Regulators: We may need to share your personal data if required by a regulator or to otherwise comply with law.
- Others: We may share your personal information with other third parties such as in the context of the possible sale of our business in connection with your use of our services. We may also need to share your personal data in order to permit us to pursue available remedies or limit damages we may sustain in connection with your use of our services.
If you are a citizen or resident in China, and wish to contact our China Representative:
Shanghai Kaibo Management & Consulting Co., Ltd, 29D, Building B, No. 1188, Kai Xuan North Road, Putuo District, Shanghai, People’s Republic of China. To find out more about how we handle the data of Chinese citizens please see our privacy notice here https://www.kic.org.cn/privacy/
Transfer of your personal data to other countries
You agree that as we are an international business with employees, entities and service providers all over the world, we may need to transfer the personal data you provide to us to other countries which may be outside Thailand in connection with your use of our services. We will take appropriate steps to ensure that your personal data is handled as described in this Privacy Notice. These steps will include appropriate contractual mechanisms. Please contact us using the contact details below if you would like more information.
The security of your personal data
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, service providers, business partners, agents and other third parties who have a legitimate need to know. They will only process your personal information on our instructions or as otherwise agreed and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Our storage and retention of your personal data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Please contact us using the contact details below if you would like more information.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your use of our product/service..
In some circumstances we may anonymise your personal data so that it can no longer be associated with you permanently, in which case we may use such information without further notice to you.
Your rights as a data subject
Under certain circumstances, by law you have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal 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. 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) in connection with your use of our services 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.
If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us in writing using the contact details below or complete the form attached to this Privacy Notice.
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.
Your right 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 below. 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.
Data Protection Officer
We have appointed a data protection officer (DPO) to oversee compliance with this Privacy Notice. If you have any questions about this Privacy Notice or how we handle your personal information, please contact the DPO using the contact details as follows:
Contact details
Name of DPO: Rachael Convery
Email address: dpo@kaplaninternational.com
Postal address: 4th Floor Bridge House, 4 Borough High Street, London SE1 9QQ, United Kingdom
Changes to this Privacy Notice
We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information. Your continued use of our services after we notify any change in this Privacy Notice indicates your consent to the new Privacy Notice.
