PRIVACY POLICY

PRIVACY POLICY

1. Introduction

1.1    We are committed to safeguarding the privacy of https://gdc-education.org/ visitors, service users, individual customers and customer personnel.
1.2    This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3    We use cookies and similar technologies on our website. As not all the cookies are strictly necessary for the provision of https://gdc-education.org/, we will ask you to consent to our use of cookies when you first visit our website. You may read our Cookies Policy here.

2. Credit

2.1    This document was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).

3. The personal data that we collect

3.1    In this Section 3 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
3.2    We may process data enabling us to get in touch with you (“contact data“). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you and/or your parents.
3.3    We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our parents.
3.4    We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data“). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
3.5    We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.

4. Photographic and Filming Policy

4.1 Taking, storing and using images
This section is providing information about how GDC Education use images of our students enrolled at Universidad Catolica de Valencia (UCV) to study the Dentistry Degree in English.
Any student who wishes to limit the use of their images should contact GDC Education at info@gdc-education.org. GDC Education will respect the wishes of students wherever reasonably possible, and in accordance with this policy.

4.2 Use of student images in GDC Education’s publications
Unless the student requested otherwise, GDC Education will use images of its students to keep GDC Education’s community updated on the activities of our students and for marketing and promotional purposes, including:

  • GDC Education’s website and, where appropriate, via GDC Education’s social media channels, e.g. Facebook, Instagram, YouTube;
  • In the educational and promotional shooting of GDC Education and its services;
  • In the online, press and other external advertisements for GDC Education. Such external advertising would not normally include students’ names;
  • Testimonials given by students would not normally include students’ full names unless students decide to introduce themselves with their full names.

The source of these images will predominantly be GDC Education’s staff, UCV, a professional photographer used for marketing and promotional purposes, or occasionally students. GDC Education will only use images of students in suitable dress and the images will be stored securely.

4.3 Sharing of students’ images
When our students participate in events and activities organized by GDC Education or by the UCV, e.g. workshops, visiting speakers, Graduation Ceremony, GDC Education may share photos of our students with the press. Occasionally, visiting speakers ask for permission to use photographs taken by or for GDC Education during their visit (e.g. to accompany reporting of their visit in the media, including social media). GDC Education may agree to permit such usage, where it is appropriate and in the broader interest of GDC Education.

4.4 Security of students’ images
GDC Education takes appropriate technical and organizational security measures to ensure that images of students held by GDC Education are kept securely and protected from loss or misuse, and in particular will take reasonable steps to ensure that members of staff only have access to images of students held by the GDC Education where it is necessary for them to do so.
GDC Education does not take responsibility for the possible use that third parties make use of the images in the future.

4.5 Disposal of images
Photographs that are out of date or no longer usable will be destroyed appropriately by shredding and deletion of the electronic version or archived.

4.6 Students’ rights
In the event that the students do not agree with the use of their image at GDC Education, they will have to inform about it to GDC Education team at info@gdc-education.org. Our students have the right to withdraw consent at any time by emailing info@gdc-education.org but understand that withdrawing consent may not affect the material that has already been used.
Our students have the right to obtain information about the personal data we have stored (Art. 15 GDPR), the right to have data corrected or deleted (Art. 16 and17 GDPR), the right to limit the processing of data (Art. 18 GDPR) and the right to revoke your consent (Art. 7 para. 3 GDPR).

We hope students will feel able to support GDC Education in using students’ images to celebrate the students’ achievements, including academic and co-curricular activity; to promote the work of the GDC Education team; and for important purposes such as safeguarding and promoting the welfare of students, identification and security.

5. Purposes of processing and legal bases

5.1    In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.
5.2    Operations – We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
5.3    Publications – We may process account data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is consent.
5.4    Relationships and communications – We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.
5.5    Direct marketing – We may process contact data, account data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent OR our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.|
5.6    Research and analysis – We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is consent OR our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
5.7    Record keeping – We may process your personal data for [the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
5.8    Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
5.9    Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
5.10  Legal claims – We may process your personal data where necessary for [the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
5.11   Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

6. Providing your personal data to others

6.1    We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
6.2    Your personal data held in our website database will be stored on the servers of our hosting services providers identified at https://www.hostinger.com/privacy-policy
6.3    In addition to the specific disclosures of personal data set out in this Section 6, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

7. International transfers of your personal data

7.1 In this Section 7, we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom and the European Economic Area (EEA).
7.2 The hosting facilities for our website are provided by Hostinger International Ltd based in Cyprus, which is a member of the EU and offers an adequate level of protection for the Personal Information of EU Member State residents.
7.3 Hostinger affiliates and service providers (such as third-party data centres, servers, website design, administration services, online traffic and website analysis, statistics, direct marketing services, mailers, messengers, etc.), that store or process our data as well as personal data of our users on Hostinger’s behalf are each contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.
For data transfer outside the EU or EEA to be compatible with the requirements of GDPR, our web hosting provider have concluded with the data processors and/or sub-processor relevant agreements on such data transfers outside EU or EEA, which comply with the European Commission approved standard contractual clauses for data transfers from data controllers in the EU to data processors and/or controllers established outside the EU or European Economic Area (EEA).
You may read our web hosting provider Privacy Policy here.
7.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

8. Retaining and deleting personal data

8.1    This Section 8 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
8.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
8.3    We will retain your personal data as follows:
(a)    contact data will be retained for a minimum period of 6 years following the date of the most recent contact between you and us, and for a maximum period of 10 years following that date;
(b)    account data will be retained for a minimum period of 1 year following the date of closure of the relevant account, and for a maximum period of 3 years following that date;
(c)     transaction data will be retained for a minimum period of 6 years following the date of the transaction, and for a maximum period of 10 years following that date;
(d)    communication data will be retained for a minimum period of 6 years following the date of the communication in question, and for a maximum period of 10 years following that date;
(e)    usage data will be retained for 2 years following the date of collection; and
8.4     Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

9. Your rights

9.1    In this Section 9, we have listed the rights that you have under data protection law.
9.2    Your principal rights under data protection law are:
(a)    the right to access – you can ask for copies of your personal data;
(b)    the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c)     the right to erasure – you can ask us to erase your personal data;
(d)    the right to restrict processing – you can ask us to restrict the processing of your personal data;
(e)    the right to object to processing – you can object to the processing of your personal data;
(f)     the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g)    the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h)    the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
9.3    These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
9.4    You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.

10. About cookies

10.1    A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
10.2    Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
10.3    Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

11. Cookies that we use

You may see the types and list of cookies that we use on our Cookies Policy.

12. Cookies used by our service providers

12.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
12.2  We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy.

13. Managing cookies

13.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can, however, obtain up-to-date information about blocking and deleting cookies via these links:
(a)    https://support.google.com/chrome/answer/95647 (Chrome);
(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c)     https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e)    https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
(f)     https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
13.2  Blocking all cookies will have a negative impact on the usability of many websites.
13.3  If you block cookies, you will not be able to use all the features on our website.

14. Amendments

14.1  We may update this policy from time to time by publishing a new version on our website.
14.2  You should check this page occasionally to ensure you are happy with any changes to this policy.

15. Our details

15.1  This website is owned and operated by GDC Education Ltd.
15.2  GDC Education Limited, company number 11835900 and registered address at Flat 137, Barratt House, 20 Prince Regent Road, Hounslow, UK.
15.3  You can contact us:
(a)    by telephone, on the contact number +34 961 941 710 published on our website; or
(b)    by email, using the email address info@gdc-education.org published on our website.

16. Data protection officer

16.1  Our data protection officer’s contact details are: info@gdc-education.org.