Fulbright Limited (“we“, “us”, “our”) are committed to protecting and respecting your privacy.
For the purpose of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, (“GDPR”), the Data Protection Act 2018 and any applicable national implementing laws, regulations and secondary legislation relating to the processing of personal data (together “Data Protection Law”), the data controller is Fulbright Limited of Harrow House, 23 West Street, Haslemere, GU27 2AB.
Legal Basis for Processing
We collect and use the personal data described below in order to provide you with access to our Site and Services in a reliable and secure manner. We also collect and use personal data:
- For our legitimate business needs.
- To fulfil our contractual obligations to you.
- To comply with our legal obligations.
To the extent we process your personal data for any other purposes, we ask for your consent in advance or require that our partners obtain such consent.
INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
Information you give us. When you are registered to use our Services and/or our Site, correspond with us by phone, e-mail or otherwise or when you report a problem with our Site we may ask you to provide certain information such as, your name, photo, email address, role, department and office location.
Information we collect about you. With regard to each of your visits to our Site we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including pages you access or visit, and information about your use of our sites, for example the pages viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
We use persistent cookies and session cookies on our Site.
A persistent cookie is stored on a user’s device in between browser sessions which allows the preferences or actions of a user across the Site (or in some cases across different websites) to be remembered. We use persistent cookies to save your login information for future logins to the Site.
A session cookie allows the Site to link your actions during a browser session. We use session cookies to enable certain features of the Site, to better understand how you interact with the Site and to monitor aggregate usage by users and web traffic routing on the Site. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Site and then close your browser.
Which Cookies we use and why
The table below explains the cookies we use and why we use each of them.
|Cookie Type||Cookie Name||Purpose|
|Analytics||Google Analytics||These cookies are used to collect information about how visitors use our Site. We use the information to compile reports and to help us improve the Site. The cookies collect information in an anonymous form, including the number of visitors to the Site, where visitors have come to the Site from and the pages they visited.|
|These cookies are used to store information about the login sessions, login settings and browser used by the user for the Site. SimpleSAML cookies are stored in addition to the objectivemanager_production cookie when logging in via SSO. They do not store personal information.|
You can set up your browser options, to stop your computer accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use the whole of the Site or all functionality of the services.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
USES MADE OF THE INFORMATION
We use information held about you in the following ways.
Information you give to us. We will use this information:
- to carry out our obligations arising from any contracts entered into between your company and us;
- to allow us to manage your account on the basis that processing is necessary in order to perform our contract with your company and to provide our Services;
- to validate information from your Human Resources team to check that the data we hold about you is accurate, consistent and up to date
- to ensure that content from our Site is presented in the most effective manner for you and for your computer.
Information we collect about you. We will use this information:
- to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our Site to ensure that content is presented in the most effective manner for you and your computer;
- as part of our efforts to keep our Site safe and secure.
DISCLOSURE OF YOUR INFORMATION
Information we share with third parties. We may share your information with selected third parties including:
- Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or your company. Analytics and search engine providers that assist us in the improvement and optimisation of our Site.
Information we disclose to third parties. We may disclose your personal data to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If we or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Standard Terms and Conditions and/or any other agreements; or to protect our rights, property, safety, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
WHERE WE STORE YOUR PERSONAL DATA
Your information (including personal data) may be stored and processed in any country where we have operations or where we engage service providers, and we may transfer your information to countries outside of your country of residence, which may have data protection rules that are different from those of your country of residence.
The personal data that we collect from you may therefore be transferred to, and stored outside the UK and the European Economic Area (“EEA“). It may also be processed by staff operating outside the UK and the EEA who work for us or for one of our suppliers or partners. Such staff or subcontractors may be engaged in, among other things, the fulfilment of your order, the processing of your payment details or the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing outside of the UK or the EEA.
Our Site and Services are accessible via the internet and may potentially be accessed by anyone around the world. Other users may access the Site or Services from outside the UK or the EEA. This means that where you chose to post your data on our Site or within the Services, it could be accessed from anywhere around the world and therefore a transfer of your data outside of the UK or the EEA may be deemed to have occurred. You consent to such transfer of your data for and by way of this purpose.
PROTECTION OF INFORMATION
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share any password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will endeavour to protect your personal data, we cannot guarantee the security of your data transmitted to our Site. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
LINKS TO OTHER WEBSITES
Our Site contains a link to a partner website to allow you to access our Help Guides and FAQ’s. You will not be asked to submit any personal data to this site. Your organisation may from time to time request that we add to our Site links to internal and external websites of their choice. If you follow a link to any of these websites, please note that these websites may have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
You have the right under Data Protection Law, free of charge, to request:
- Access to your personal data.
- Rectification or deletion of your personal data.
- A restriction on the processing of your personal data.
- Object to the processing of your personal data.
- A transfer of your personal data (data portability).
- Withdraw your consent to us processing your personal data at any time.
Where we process your personal data for marketing purposes, we will inform you and obtain your opt in consent (before collecting your personal data) if we intend to use your personal data for such purposes. If you change your mind about being contacted in the future, please click on the opt out options and we will remove you from our mailing lists.
We send push notifications from time to time in order to update you about any service updates, events and promotions we may be running. If you no longer wish to receive these communications, please disable these in the settings on your device.
We retain personal data for as long as necessary for the relevant activity for which it was provided or collected. This will be for as long as we provide access to the Site or Service to you, your account with us remains open or any period set out in any relevant contract your company has with us. However, we may keep some data after your account is closed, where reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, maintain security, prevent fraud and abuse, resolve disputes, enforce our Standard Terms and Conditions, or fulfil your request to “unsubscribe” from further messages from us.
We will retain de-personalised information after your account has been closed.
Please note: After your account has been closed or information deleted from your account, any information you have shared with others may remain visible. We do not control data that other users may have copied from the Site.
For individuals located in the EU: your local data protection supervisory authority in the country in which you are located;
For all other individuals: The Information Commissioner’s Office at, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England (“ICO”).
Fulbright Limited of Harrow House, 23 West Street, Haslemere, GU27 2AB Or firstname.lastname@example.org