Schedule A Demo

Privacy Policy

1. Introduction

EDMO is an online platform that allows students to apply to colleges and universities around the world. It supports students through every step of the way to enable them to make better decisions while saving time and money.

EDMO together with its affiliate iSchoolConnect Inc. is committed to conducting its business in accordance with all applicable data protection laws and regulations and in line with the highest standards of ethical conduct.

This policy sets forth the expected behaviours of EDMO employees and third parties in relation to the collection, use, retention, transfer, disclosure and destruction of any Personal Data belonging to a EDMO Data Subject.

Personal Data is any information (including opinions and intentions) which relates to an identified or Identifiable Natural Person. Personal Data is subject to certain legal safeguards and other regulations, which impose restrictions on how organisations may process Personal Data. An organisation that handles Personal Data and makes decisions about its use is known as a Data Controller while a Data Processor is responsible for processing personal data on behalf of the Data Controller. EDMO, as a Data Controller and Data Processor, is responsible for ensuring compliance with the Data Protection requirements outlined in this policy. Non-compliance may expose EDMO to complaints, regulatory action, fines and/or reputational damage.

EDMO’s leadership is fully committed to ensuring continued and effective implementation of this policy and ensures no mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Information sharing to subcontractors in support services, such as customer service is permitted. Any breach of this policy will be taken seriously and may result in disciplinary action or business sanction.

This policy has been approved by EDMO’s Founder, CEO Mr. Ashish Fernando.

2. Scope

This policy applies to the services offered by EDMO where a Data Subject’s Personal Data is processed

  • In the context of the business activities of EDMO.
  • For the provision or offer of goods or services to individuals (including those provided or offered free-of-charge) by EDMO.
  • In case of monitoring of behaviour of individuals which also includes activities such as persistent web browser cookies or dynamic IP address tracking to profile an individual with a view to analysing or predicting their personal preferences, behaviours and attitudes.

This policy applies to all Processing of Personal Data in electronic form (including electronic mail and documents created with word processing software) or where it is held in manual files that are structured in a way that allows ready access to information about individuals.

This policy has been designed to establish a worldwide baseline standard for the Processing and protection of Personal Data by all EDMO. Where national law imposes a requirement which is stricter than imposed by this policy, the requirements stated in national law must be followed. Furthermore, where national law imposes a requirement that is not addressed in this policy, the relevant national law must be adhered to.

If there are conflicting requirements in this policy and national law, please consult with the Privacy Officer for guidance.

The protection of Personal Data belonging to EDMO employees is not within the scope of this policy.

3. Definitions

Data Subject

A data subject is any person whose personal data is being collected, held or processed. Data subject refers to any individual person who can be identified, directly or indirectly, via an identifier such as a name, an ID number, location data, or via factors specific to the person’s physical, physiological, genetic, mental, economic, cultural or social identity.

Data Controller

A natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data

Data Processors

A natural or legal person, Public Authority, Agency or other body which Processes Personal Data on behalf of a Data Controller.

Process, Processed, Processing

Any operation or set of operations performed on Personal Data or on sets of Personal Data, whether or not by automated means. Operations performed may include collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Special Categories of Data

Personal Data pertaining to or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership; data concerning health or sex life and sexual orientation; genetic data or biometric data.

Consent

Any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the Processing of Personal Data relating to him or her.

Data Protection

The process of safeguarding Personal Data from unauthorised or unlawful disclosure, access, alteration, Processing, transfer or destruction. Data Protection Authority An independent Public Authority responsible for monitoring the application of the relevant Data Protection regulation set forth in national law.

Data Protection Authority

An independent Public Authority responsible for monitoring the application of the relevant Data Protection regulation set forth in national law.

Third Country

Any country not recognised as having an adequate level of legal protection for the rights and freedoms of Data Subjects in relation to the Processing of Personal Data.

Personal Data

‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’)

Profiling

Any form of automated processing of Personal Data where Personal Data is used to evaluate specific or general characteristics relating to an Identifiable Natural Person. In particular to analyse or predict certain aspects concerning that natural person’s performance at work, economic situations, health, personal preferences, interests, reliability, behaviour, location or movement.

Personal Data Breach

A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise Processed.

Privacy Officer

An individual responsible for monitoring internal compliance, informing and advising on data protection obligations and act as a contact point for data subjects and the supervisory authority

Encryption

The process of converting information or data into code, to prevent unauthorised access.

Pseudonymisation

Data amended in such a way that no individuals can be identified from the data (whether directly or indirectly) without a “key” that allows the data to be re-identified.

Anonymization

Data amended in such a way that no individuals can be identified from the data (whether directly or indirectly) by any means or by any person.

4. Policy

4.1.1 Data Sources

Personal Data should be collected only from the Data Subject unless one of the following apply:

  • The nature of the business purpose necessitates collection of the Personal Data from other persons or bodies.
  • The collection must be carried out under emergency circumstances in order to protect the vital interests of the Data Subject or to prevent serious loss or injury to another person.

4.1.2 Data Subject Consent

EDMO will obtain Personal Data only by lawful and fair means and, where appropriate with the knowledge and Consent of the individual concerned. Where a need exists to request and receive the Consent of an individual prior to the collection, use or disclosure of their Personal Data, EDMO is committed to seeking such Consent.

4.1.3 Data Subject Notification

EDMO will, when required by applicable law, contract, or where it considers that it is reasonably appropriate to do so, provide Data Subjects with information as to the purpose of the Processing of their Personal Data.

The disclosures may be given orally, electronically or in writing. If given orally, the person making the disclosures should use a suitable script or form approved in advance by the Privacy Officer. The associated receipt or form should be retained, along with a record of the facts, date, content, and method of disclosure.

4.1.4 External Privacy Notices

Each external website provided by EDMO will include an online ‘Website Privacy Policy’ and an online ‘Website Cookie Policy’ fulfilling the requirements of applicable law.

All Privacy and Cookie Notices will be approved by the Privacy Officer prior to publication on any EDMO external website.

4.2 Data Use

4.2.1 Data Processing

EDMO uses the Personal Data of its Data Subjects for the following broad purposes:

  • To provide services to EDMO customers.
  • The ongoing administration and management of customer services

The use of a Data Subject’s information should always be considered from their perspective and whether the use will be within their expectations or if they are likely to object.

EDMO will process Personal Data in accordance with all applicable laws and applicable contractual obligations. More specifically, EDMO will not process Personal Data unless at least one of the following requirements are met:

  • Processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract.
  • Processing is necessary for compliance with a legal obligation to which the Data Controller is subject.
  • Processing is necessary in order to protect the vital interests of the Data Subject or of another natural person.
  • Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller.
  • Processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party (except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject, in particular where the Data Subject is a child).

There are some circumstances in which Personal Data may be further processed for purposes that go beyond the original purpose for which the Personal Data was collected. When deciding the compatibility of the new reason for Processing, guidance and approval must be obtained from the Privacy Officer before any such Processing may commence.

In any circumstance where Consent has not been gained for the specific Processing in question, EDMO will address the following additional conditions to determine the fairness and transparency of any Processing beyond the original purpose for which the Personal Data was collected:

  • Any link between the purpose for which the Personal Data was collected and the reasons for intended further Processing.
  • The context in which the Personal Data has been collected, in particular regarding the relationship between Data Subject and the Data Controller.
  • The nature of the Personal Data, in particular whether Special Categories of Data are being Processed, or whether Personal Data related to criminal convictions and offences are being processed.
  • The possible consequences of the intended further Processing for the Data Subject.
  • The existence of appropriate safeguards pertaining to further Processing, which may include Encryption, Anonymization or Pseudonymisation.

4.2.2 Special Categories of Data

EDMO will only Process Special Categories of Data (also known as sensitive data where the Data Subject expressly consents to such Processing or where one of the following conditions apply:

  • The Processing relates to Personal Data which has already been made public by the Data Subject.
  • The Processing is necessary for the establishment, exercise or defence of legal claims.
  • The Processing is specifically authorised or required by law.
  • The Processing is necessary to protect the vital interests of the Data Subject or of another natural person where the Data Subject is physically or legally incapable of giving consent.
  • Further conditions, including limitations, based upon national law related to the Processing of genetic data, biometric data or data concerning health.

In any situation where Special Categories of Data are to be processed, prior approval must be obtained from the Privacy Officer and the basis for the Processing clearly recorded with the Personal Data in question.

4.2.3 Children’s Data

Children are unable to Consent to the Processing of Personal Data for information society services. Consent must be sought from the person who holds parental responsibility over the child. However, it should be noted that where Processing is lawful under other grounds, as mentioned above in section 4.4.2, Consent need not be obtained from the child or the holder of parental responsibility.

Should EDMO foresee a business need for obtaining parental consent for information society services offered directly to a child, guidance and approval must be obtained from the Privacy Officer before any Processing of a child’s Personal Data may commence.

4.2.4 Data Quality

EDMO will adopt all necessary measures to ensure that the Personal Data it collects and Processes is complete and accurate in the first instance, and is updated to reflect the current situation of the Data Subject.

  • The measures adopted by EDMO to ensure data quality include: Correcting Personal Data known to be incorrect, inaccurate, incomplete, ambiguous, misleading or outdated, even if the Data Subject does not request rectification.
  • Keeping Personal Data only for the period necessary to satisfy the permitted uses or applicable statutory retention period.
  • The removal of Personal Data if in violation of any of the Data Protection principles or if the Personal Data is no longer required.
  • Restriction, rather than deletion of Personal Data, insofar as:
    • A law prohibits erasure.
    • Erasure would impair legitimate interests of the Data Subject.
    • The Data Subject disputes that their Personal Data is correct and it cannot be clearly ascertained whether their information is correct or incorrect.

4.2.5 Digital Marketing

As a rule, EDMO will not send promotional or direct marketing material to an EDMO Data Subject through digital channels such as mobile phones, SMS texting, WhatsApp messaging, email and the Internet, without first obtaining their Consent. EDMO wishing to carry out a digital marketing campaign without obtaining prior Consent from the Data Subject must first have it approved by the Privacy Officer.

When you voluntarily send us electronic mail/fill out the form, we will keep a record of this information so that we can respond to you. We only collect information from you when you register on our site or fill out a form. Also, when filling out a form on our site, you may be asked to enter your name, e-mail address, or phone number. You may, however, visit our site anonymously. In case you have submitted your personal information and contact details, we reserve the rights to Call, SMS, Email, or WhatsApp about our products and offers, even if your number has DND activated on it.

Where Personal Data Processing is approved for digital marketing purposes, the Data Subject must be informed at the point of first Data Subject that they have the right to object, at any stage, to having their data Processed for such purposes. If the Data Subject puts forward an objection, digital marketing related Processing of their Personal Data must cease immediately and their details should be kept on a suppression list with a record of their opt-out decision, rather than being completely deleted.

It should be noted that where digital marketing is carried out in a ‘business to business’ context, there is no legal requirement to obtain an indication of Consent to carry out digital marketing to individuals provided that they are given the opportunity to opt-out.

4.2.6 Data Retention

To ensure fair Processing, Personal Data will not be retained by EDMO for longer than necessary in relation to the purposes for which it was originally collected, or for which it was further processed.

The length of time for which EDMO needs to retain Personal Data will be determined and set out in the Backup and Data Retention policy. This takes into account the legal and contractual requirements, both minimum and maximum, that influence the retention periods set forth in the schedule. All Personal Data should be deleted or destroyed as soon as possible where it has been confirmed that there is no longer a need to retain it.

4.2.7 Data Protection

EDMO will adopt physical, technical, and organisational measures to ensure the security of Personal Data. This includes the prevention of loss or damage, unauthorised alteration, access or Processing, and other risks to which it may be exposed by virtue of human action or the physical or natural environment.

The minimum set of security measures to be adopted by EDMO should conform to the standards mentioned in the ‘Information Security Management System’. A summary of the Personal Data related security measures is provided below:

  • Prevent unauthorised persons from gaining access to data processing systems in which Personal Data are processed.
  • Prevent persons entitled to use a data processing system from accessing Personal Data beyond their needs and authorisations.
  • Ensure that Personal Data in the course of electronic transmission during transport cannot be read, copied, modified or removed without authorisation.
  • Ensure access to Personal Data is governed through appropriate logical and physical access controls. Ensure that Personal Data is protected against undesired destruction or loss.
  • Ensure that Personal Data is not kept longer than necessary.

4.2.8 Data Subject Requests

The Privacy Officer will establish a system to enable and facilitate the exercise of Data Subject rights related to:

  • Information access.
  • Restriction of Processing.
  • Data rectification.
  • Data erasure.

If an individual makes a request relating to any of the rights listed above, EDMO will consider each such request in accordance with all applicable Data Protection laws and regulations. No administration fee will be charged for considering and/or complying with such a request unless the request is deemed to be unnecessary or excessive in nature.

Data Subjects are entitled to obtain, based upon a request made in writing to the Privacy Officer and upon successful verification of their identity, the following information about their own Personal Data:

  • The purposes of the collection, Processing, use and storage of their Personal Data.
  • The source(s) of the Personal Data, if it was not obtained from the Data Subject;
  • The categories of Personal Data stored for the Data Subject.
  • The recipients or categories of recipients to whom the Personal Data has been or may be transmitted, along with the location of those recipients.
  • The envisaged period of storage for the Personal Data or the rationale for determining the storage period.
  • The use of any automated decision-making, including Profiling.
  • The right of the Data subject to:
    • Object to Processing of their Personal Data.
    • Lodge a complaint with the Data Protection Authority.
    • Request rectification or erasure of their Personal Data.
    • Request restriction of Processing of their Personal Data.

All requests received for access to or rectification of Personal Data must be directed to the Privacy Officer, who will log each request as it is received. A response to each request will be provided within 30 days of the receipt of the written request from the Data Subject. Appropriate verification must confirm that the requestor is the Data Subject or their authorised legal representative. Data Subjects shall have the right to require EDMO to correct or supplement erroneous, misleading, outdated, or incomplete Personal Data.

If EDMO cannot respond fully to the request within 30 days, the Privacy Officer shall nevertheless provide the following information to the Data Subject, or their authorised legal representative within the specified time:

  • An acknowledgement of receipt of the request.
  • Any information located to date.
  • Details of any requested information or modifications which will be provided to the Data Subject, the reason(s) for the refusal, and any procedures available for appealing the decision.
  • An estimated date by which any remaining responses will be provided.
  • An estimate of any costs to be paid by the Data Subject (e.g. where the request is excessive in nature).
  • The name and Data Subject information of the EDMO individual who the Data Subject should contact for follow up.

It should be noted that situations may arise where providing the information requested by a Data Subject would disclose Personal Data about another individual. In such cases, information must be redacted or withheld as may be necessary or appropriate to protect that person’s rights.

4.2.9 Law Enforcement Requests & Disclosures

In certain circumstances, it is permitted that Personal Data be shared without the knowledge or Consent of a Data Subject. This is the case where the disclosure of the Personal Data is necessary for any of the following purposes:

  • The prevention or detection of crime.
  • The apprehension or prosecution of offenders.
  • The assessment or collection of a tax or duty.
  • By the order of a court or by any rule of law.

If EDMO processes Personal Data for one of these purposes, then it may apply an exception to the Processing rules outlined in this policy but only to the extent that not doing so would be likely to prejudice the case in question.

4.2.10 Data Protection Training

All EDMO employees that have access to Personal Data will have their responsibilities under this policy outlined to them as part of their staff induction training. In addition, EDMO will provide regular Data Protection training and procedural guidance for their staff. The training and procedural guidance set forth will consist of, at a minimum, the following elements:

  • The Data Protection Principles set forth in this document
  • Each employee’s duty to use and permit the use of Personal Data only by authorised persons and for authorised purposes.
  • The need for, and proper use of, the forms and procedures adopted to implement this policy.
  • The correct use of passwords, security tokens and other access mechanisms.
  • The importance of limiting access to Personal Data, such as by using password protected screen savers and logging out when systems are not being attended by an authorised person.
  • Securely storing manual files, print outs and electronic storage media.
  • The need to obtain appropriate authorisation and utilise appropriate safeguards for all transfers of Personal Data outside of the internal network and physical office premises.
  • Proper disposal of Personal Data by using secure shredding facilities.
  • Any special risks associated with particular departmental activities or duties.

4.2.11 Transfers between EDMO Entities

For EDMO to carry out its operations effectively across its various entities, there may be occasions when it is necessary to transfer Personal Data from one EDMO entity to another, or to allow access to the Personal Data from an overseas location. Should this occur, the EDMO entities sending the Personal Data remains responsible for ensuring protection for that Personal Data.

4.2.12 Transfers to Third Parties

EDMO will only transfer Personal Data to, or allow access by, third parties when it is assured that the information will be processed legitimately and protected appropriately by the recipient. Where third party Processing takes place, EDMO will first identify if, under applicable law, the third party is considered a Data Controller or a Data Processor of the Personal Data being transferred.

Where the third party is deemed to be a Data Controller, EDMO will enter into, in cooperation with the Privacy Officer, an appropriate agreement with the Controller to clarify each party’s responsibilities in respect to the Personal Data transferred.

Where the third party is deemed to be a Data Processor, EDMO will enter into, in cooperation with the Privacy Officer, an adequate Processing agreement with the Data Processor. The agreement must require the Data Processor to protect the Personal Data from further disclosure and to only Process Personal Data in compliance with EDMO instructions. In addition, the agreement will require the Data Processor to implement appropriate technical and organisational measures to protect the Personal Data as well as procedures for providing notification of Personal Data Breaches.

When EDMO is outsourcing services to a third party (including Cloud Computing services), they will identify whether the third party will Process Personal Data on its behalf and whether the outsourcing will entail any Third Country transfers of Personal Data.

The Privacy Officer shall conduct regular audits of Processing of Personal Data performed by third parties, especially in respect of technical and organisational measures they have in place. Any major deficiencies identified will be reported to and monitored by EDMO’s management.

4.2.13 Complaints Handling

Data Subjects with a complaint about the Processing of their Personal Data, should put forward the matter in writing to the Privacy Officer. An investigation of the complaint will be carried out to the extent that is appropriate based on the merits of the specific case. The Privacy Officer will inform the Data Subject of the progress and the outcome of the complaint within a reasonable period.

If the issue cannot be resolved through consultation between the Data Subject and the Privacy Officer, then the Data Subject may, at their option, seek redress through mediation, binding arbitration, litigation, or via complaint to the Data Protection Authority within the applicable jurisdiction

4.2.14 Breach Reporting

Any individual who suspects that a Personal Data Breach has occurred due to the theft or exposure of Personal Data must immediately notify the Privacy Officer providing a description of what occurred. Notification of the incident can me made via email on datacompliance@ischoolconnect.com.

The Privacy Officer will investigate all reported incidents to confirm whether or not a Personal Data Breach has occurred. If a Personal Data Breach is confirmed, the Privacy Officer will follow the relevant authorised procedure based on the criticality and quantity of the Personal Data involved. For severe Personal Data Breaches, the EDMO management will initiate and chair an emergency response team to coordinate and manage the Personal Data Breach response.

5. Policy Maintenance

All inquiries about this policy, including requests for exceptions or changes should be directed to the Privacy Officer via email datacompliance@ischoolconnect.com.

5.1 Publication

This policy shall be available to all EDMO employees through the EDMO Policy Portal https://ischoolconnect.com/privacy-policy. or via alternative means as deemed appropriate by the Privacy Officer.

5.2 Effective Date

This policy is effective as of 16th April, 2024.

5.3 Revisions

The Privacy Officer is responsible for the maintenance and accuracy of this policy. Notice of significant revisions shall be provided to EDMO employees through the Human Resources department. Changes to this policy will come into force when published on EDMO Policy Portal https://ischoolconnect.com/privacy-policy.

6. Related Documents

Listed below are documents that relate to and are referenced by this policy.

  • Website Privacy Policy
  • Terms of Use
  • Website Cookie Policy
  • Backup and Data Retention Policy

7. Annexure

This policy is applicable to:

  • iSchoolConnect , Inc.
  • iSchool India Private Limited