We are Kaplan International Languages. We help Students learn the English, French and German languages. We decide what personal information we need for the services we provide and how it is used. We are responsible to look after this information.

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Kaplan International Languages is a data controller.  This means we decide what to do with the personal information we collect about you, like your name, contact information and anything else that identifies you. The law says we must explain clearly how we use and protect this information. This is what this Privacy Notice is for - to let you know what happens to your personal information when you give it to us, either directly or through someone else.

Kaplan International Languages is made up of different legal entities. This Privacy Notice is issued on behalf of the Kaplan International Languages, so when we mention “Kaplan”, “we”, “us” or “our” in this Privacy Notice, we are referring to the relevant company in the Kaplan International Languages responsible for processing your information. 

You can contact our Data Protection Officer (DPO) if you have questions about how we use your information. Our DPO makes sure we look after your information properly. You can contact our DPO by email at the address listed below (click on “Would you like to read more?”).

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Our Data Protection Officer (DPO) is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this Privacy Notice, including any requests to exercise your rights, please contact the DPO using the details set out below: 

Email address: [email protected]

Postal address: Palace House, 3 Cathedral St, London SE1 9DE, England, UK. 

If you are resident in an EU country and wish to contact our EU Representative: 

Kaplan Ireland Education Limited, 13/14 Aungier Street, Dublin 2, D02 WC04 Ireland. 

If you are resident in China and wish to contact our China Representative: 

Post address: 

Aspect (Beijing) Education Information Consulting Co., Ltd

C312-3 Beijing Lufthansa Center

50 Liangmaqiao Road

Chaoyang District, Beijing

邮寄地址：爱思博（北京）教育信息咨询有限公司

北京市朝阳区亮马桥路50号燕莎中心写字楼C313

To find out more about how we handle the personal information of Chinese residents, please see our privacy notice here: https://www.kic.org.cn/privacy/ 

You have the right to make a complaint at any time. In the first instance, the complaint should be directed to us. We will respond within 30 days of receipt. If you are not satisfied with our response, you are free to raise any concern with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

Personal information is anything that can identify you. This can include your name, address, phone number, your passport number and other details about you. 

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We may process the following information about you. Please note this list does not include all type of personal information we may process: 

• Name
• Address
• Email address
• Phone number
• Passport information.

Personal information does not include data where information which could identify you has been removed (anonymised data). 

Special Category/Sensitive Personal Information 

Some personal information is more sensitive - like details about health, ethnic background, religion, sexual orientation or criminal convictions. This is called special category or sensitive personal information, and we only use it where absolutely necessary and with stronger protections in place. Where we need to process special category personal information, in this Privacy Notice we will mark this with an asterisk (*) so it is clear to you when we process this type of information. 

We follow strict rules when using your personal information. We promise to use it fairly and legally, always inform you how we use it, only collect what we need, keep it up-to-date, not keep it longer than we need to, and keep it safe.

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We will comply with data protection laws. These say 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. 

We use personal information to help Students achieve entry to study one of our Kaplan International Languages Programmes and whilst the Student is studying with us to support their learning. 

We also use personal information to ensure Students stay safe.

We use personal information when we need to follow the law. 

We also may need some information that helps our business, as long as using it will not harm your rights or freedoms.

For these purposes we may also need to use the personal information of the Students’ Parents/Legal Guardians, Sponsors (see more in section If you are a Parent/Legal Guardian, UK Guardian, or a Sponsor of a Student).

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We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances: 

• Where we need to perform a contract we have entered into with the Student 
• Where we need to comply with a legal obligation 
• 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. 

We may also use your personal information in the following situations, which are likely to be less common: 

• Where we may need to protect a Student’s health, safety and wellbeing (or the health, safety and wellbeing of another person) 
• Where it is needed in the public interest. 

Generally, we do not rely on consent as a legal basis for processing your personal information, other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

Special Category/Sensitive Personal Information

From time to time we may need to process special category data.  The legal basis for using this information is explicit consent of the individual, where we are required to do so by law or where it is in the Student’s or another party’s vital interest. 

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If you are a Student

• Applications

If you make an application to study on one of our Kaplan  International Languages Programmes or for us to help you with your  application, we may collect the following categories of personal information about you and your Parent/Legal Guardian,  or Sponsor (see what information we process about them in section If you are a Parent/Legal Guardian, or a Sponsor of a Student): 

• Name, title, address, telephone numbers and personal email addresses 
• Date of birth 
• Gender
• Nationality and country of residence 
• Passport number 
• Visa information and immigration status 
• Education history
• Level of English language 
• Academic and any other qualifications you have
• Employment history 
• Billing address
• Credit or other payment information in order to process payments to us
• Information on how you will fund your studies with us
• Information about the subjects you are interested in studying and the universities and countries you wish to study in
• Information about any criminal convictions*
• Information to ensure that we do not engage in transactions or relationships prohibited under applicable laws or regulations
• Information about your health and any disabilities that you may need support with*.

Please note, depending on the course you apply for, we may need you to provide further information.

Other than the special category information, the legal basis for using this information is to enter into and fulfil the contract we have for your studies or to comply with our legal obligations.

During your studies we will collect information about your academic experience and course 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.

If you use an Agent to arrange your application, we may collect the categories of personal information described above from your Agent. 

• Safety and Wellbeing

To look after your safety and wellbeing, we will ask for emergency contacts. This will usually be:

• Your Parents or Legal Guardian, if you are under 18
• A person whose details you have provided to us for this purpose, if you are aged 18 or over.  

The personal information we will collect about them is:

• Name
• Telephone number
• Address
• Email address
• Relationship to you.

Our legal basis to process this information is our legal obligations to ensure the health and wellbeing you if are under 18, and your consent if you are 18 or over. 

• Studying on a Kaplan International Languages Programme

If you are studying on a Kaplan International Languages Programme, during your studies, we will collect information:

• About your academic experience
• Attendance
• Course progression 
• Exam bookings
• Payments made to us
• To investigate any allegations of misconduct. 

The legal basis for processing this information is to fulfil our contract with you, but it is also in our legitimate interest to use this personal information in order to monitor the provision of our services. 

We may also collect personal information about your health and any disabilities you may have in order to make appropriate arrangements and reasonable adjustments to help you study. We will only process this information with your explicit consent.

• Examinations

Sometimes we will assist students to book exams with external exam providers. We will process the below information in order to make the booking:

• Name 
• Student number
• Your ID
• Address
• Any medical information if you require any assistance.

We will sometimes receive a copy of the exam certificate which we will provide to you and if required a copy to your sponsor. 

The legal basis for processing this information is your consent. 

• Accommodation 

If you live in accommodation we have arranged for you while studying on a Kaplan International Languages Programme, we will also process the following information about you:

• Name, title, addresses, telephone numbers and personal email addresses 
• Age
• Bank account details 
• Billing address
• Credit card or other payment information in order to process payments to us
• Any violations you commit of accommodation rules
• Financial information regarding the ability to pay the rent for the accommodation
• Information to ensure that we do not engage in transactions or relationships prohibited under applicable laws or regulations. 
• Gender
• Nationality 

We may also collect personal data about your health in order to make appropriate arrangements and reasonable adjustments for you regarding your welfare and accommodation. We use this information in order to perform our contract with you but also in order to fulfil our legal obligations.

This information, together with the personal information provided to us at application stage, will be used by us to perform the contract we have entered into with you, it is in our legitimate interest or to comply with our legal obligations. 

• Excursions 

We will process your personal information to book your place on an excursion. This will involve your name, student ID number and email address and we will send email communications to keep you updated about the excursion you have booked on to. 

• CCTV

CCTV is used within all our buildings in internal and external communal areas.  The footage captured is intended to ensure the safety of Students, employees and visitors and to safeguard property. 

We may use CCTV in buildings where exams take place to monitor if any misconduct takes place.

The legal basis to process the information we collect is our legitimate interest.

• Enquiries and Marketing

If you enquire about the services we offer, we may use your:

• Name
• Email
• Telephone number
• Where you live
• Nationality
• Age
• Whether you are under 18
• Your query
• What you are interested in studying and where
• How you have engaged with our website or our events and other interactions with us. 

This helps us understand what courses we can offer you and to provide you information about similar services and to prioritise queries. It may be necessary to process additional personal information about you, depending on your enquiry.

The legal basis to process this information is your consent, where you have provided your consent in your enquiry, or where it is in our legitimate interest to do so. 

If you are a current Student or one of our graduates, we may use your personal information to inform you of special offers and new or existing services that we believe may be of interest to you or to send you surveys or questionnaires so that we can learn more about your needs and interests and improve our services.  The legal basis to process your information is our legitimate interest. 

You will always be provided with the option to opt out of such communications, if you no longer wish to receive them.

• Internal business purposes 

We may also use the personal information listed above 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.  

• Use of our website 

As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal information by using cookies and other similar technologies. 

Please see our cookie policy on our website for further details. [include link to the Cookies Policy].

• Artificial Intelligence (AI)

To enhance the Student support we offer or to make our services more efficient, we may deploy AI tools which process some of your information.

For example, we may use AI tools to summarise questions we receive from you, to answer an FAQ, to capture information about you and your query before submitting it to a staff member, or to provide instant feedback on answers to simple quizzes or queries. These features will supplement the existing support we provide and will help us improve the services we offer you.

Where AI is utilised, Kaplan will ensure that your privacy rights and the security of your data are robustly protected as follows: 

• We will always inform you where you are engaging with an AI tool such as a chatbot or virtual assistant
• In most cases the Al features we use will not be trained with your data
• In limited circumstances, and where there is no adverse effect on you, the AI models may be trained on your data. This will be done in order to enable specific features of the tool or to teach the model how to triage different types of queries. However, in most of these cases, your personal information will only be used by us and will not be shared with or used by the supplier of the AI tool. If this is not the case, we will inform you and give you the option to opt out of the sharing
• In some cases, aggregated data may be used to train a supplier's AI model. In this case, all personal information will be anonymised in advance, which means that it will no longer be possible for anyone to identify you. 

Where we use AI for other purposes, we will provide you a separate notice about how the AI tool is used and what personal information is processed.

If you are a Parent/Legal Guardian, Sponsor of a Student

We may process the following personal information where it is necessary to support a Student’s application, study, wellbeing or accommodation.

• Student Application 

We may need to process the personal information of a Student’s Parents/Legal Guardians to facilitate the Student’s application. This includes:

• Name, title, addresses, telephone numbers and personal email addresses
• Date of birth 
• Gender
• Nationality and country of residence 
• Passport number 
• Payment information 
• Relationship with the Student
• Financial information regarding the ability to pay for the accommodation
• Information to ensure that we do not engage in transactions or relationships prohibited under applicable laws or regulations. 

The legal basis for using this information is to enter into and fulfil the contract we with the Student or to comply with our legal obligations.

• Emergency contacts

If you are named as an emergency contact for a Student, we will collect personal information about you to ensure we are able to contact you if necessary. This includes:

• Name
• Telephone number
• Address
• Email address
• Relationship to the Student.

Our legal basis to process this information is to satisfy our legal obligations to ensure the health and wellbeing of the Student is protected.

This information, together with the personal information provided to us at application stage, will be used by us to perform the contract we have entered into with the Student, to fulfil our legitimate interest or to comply with our legal obligations. 

If you fail to provide personal information 

Where we need to collect personal information for a Student’s application, studies or accommodation, and you fail to provide that information when requested, we may not be able to provide the services to the Student. 

Where we need to collect personal information to fulfil our legal obligations, for example, to comply with visa and immigration obligations, we may be required to inform the government body responsible that the requested information has not been provided.

To provide the services we offer, it is sometimes necessary to share the personal information we process with third parties. We only do this where it is necessary. 

This could include our third-party service providers, our business partners, including our partner universities, government authorities, other Kaplan companies and other third parties. 

We may also share Student information with their Parents/Legal Guardians, Sponsors or Agents.

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This sharing will take place where we are required to do so by law, where it is necessary to perform our contract with the Student or where we have a legitimate interest in doing so. 

We only do this where we have ensured the organisation we are sharing your information with will keep it as safe and secure and will comply with any relevant data protection laws.

The third parties we may share your personal information with include:

Our service providers 

We may share your personal information with other companies that perform certain services. These services may include processing payments, providing customer service and marketing assistance, performing business and recruitment analysis and supporting our website and IT functionality. These service providers will be supplied with or have access to your personal information solely for the purpose of providing these services to us or on our behalf. 

When required, if there is outstanding money owed to us by a Student, Parent or Sponsor, we may also share personal information with our debt recovery service providers. We share this information as it is in our legitimate interest to recover any monies owed to us.

In most circumstances the third party which provides the services on our behalf will be a data processor and we will remain accountable for the protection of your personal information. 

In some circumstances, the third party which provides the services will be an independent data controller. In these cases, the third party will provide you with information on how they process your personal information.

Accommodation providers 

We use third parties, including host families, to provide accommodation to our Students. In these circumstances it may be necessary to share the Student’s personal information or the personal information of the Student’s Parents/Legal Guardians or Sponsor with the host provider. 

Our business partners 

We may share your personal data with universities if we are helping you with your application with the university.  

Sponsors

We may also share Student’s personal information with their Sponsor with whom we have an agreement or arrangement relating to the Student’s programme of study. 

Parents/Legal Guardians, if the Student is under 18 

We may share a Student’s personal information with their Parents/Legal Guardians in order to perform our contract and comply with our legal obligations to keep the Student safe.

Parents, Legal Guardian,  if the Student is 18 and over

• We may share a Student’s personal information with the person the Student has named as their emergency contact in order to comply with our duty to keep our Students safe
• We may share information about a Student with their Parents/Legal Guardians to protect the Student’s vital interests 
• We may share information about a Student with their Parents/Legal Guardians, if the Student has provided consent to keep them informed about their progress, attendance, wellbeing or any incidents of misconduct.

Agents 

If a Student uses an agent to arrange their application, we may share the Student’s personal information with them. 

Government Authorities and Regulators 

We may need to share the personal information of a Student, their Parents/Legal Guardians or Sponsor, where necessary to ensure that we comply with all applicable laws and regulations. This includes, but may not be limited to: 

• Responding to lawful requests, including audits, from regulatory bodies, government authorities or law enforcement agencies 
• Fulfilling statutory or regulatory reporting requirements
• Carrying out checks to ensure that we do not engage in transactions or relationships prohibited under applicable laws or regulations

• Disclosing information regarding any criminal convictions*, where required.

  Other entities in the Kaplan group 

We may share the personal information we process with other entities in our group to fulfil our contract with the Student, support our business needs, as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise or for system maintenance support and hosting of data. We will only do this where it does not affect your rights and freedoms.

• Others 

We may share the personal information we process with other third parties, such as in the context of the possible sale of our business. We may also need to share your personal information in order to pursue available remedies or limit damages we may sustain. 

Sometimes we need to send the personal information we process to other countries, but we make sure it is still protected.  Even if a country’s privacy rules are different, we take steps to keep your personal information safe.

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As we are an international business with employees, entities and service providers all over the world, we may need to transfer the personal information we process to other countries which may be outside the European Economic Area (EEA). 

When we transfer personal information outside the EEA, we will ensure we comply with both data protection laws in the EEA and, where appropriate, the data protection laws in the country we are transferring the information to. Where the data protection laws in such countries may not be as comprehensive and provide the same level of protection for your personal information as those within the EEA, we will take appropriate steps to ensure that the personal information is protected. These steps will include contractual mechanisms with the organisations we share the information with, to ensure they provide an appropriate level of protection.  Please contact us using the contact details in this Privacy Notice if you would like more information. 

We take care to keep the personal information we process safe and protected from any loss, theft or misuse. We make sure only the right people can see or use your information. If something goes wrong, we will tell you if you need to take action.

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We have put in place appropriate security measures to prevent the personal information we process from being accidentally lost, used or accessed in an unauthorised way, altered or wrongfully disclosed. In addition, we limit access to the personal information we process to only those employees, service providers, business partners, agents and other third parties who need to access it to provide the services we offer. They will only process personal information on our instructions or as otherwise agreed and they will always keep the information secure. 

We have put in place procedures to deal with any suspected data security incident and will notify you if the incident may affect you significantly. We will also inform any relevant regulator, where we are required to do so. 

It is important that the personal information we hold about you is accurate and up-to-date. If at any time the information we hold on you changes, please inform us as soon as possible so we can update our records. This ensures we can continue providing the Student with our services and that the right information reaches the right person. 

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If you are a Student and there is a change to your personal information, please contact the Kaplan Team you have been liaising with.

If you are not an enrolled Student and there is a change to your personal information, please contact us by emailing the address in this notice. 

We will keep the personal information we process for as long as it is necessary for us to provide Students our services, to meet our business needs or to meet our legal duties. We will delete or anonymise the personal information when it is no longer necessary to keep it. 

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We will only retain personal information for as long as necessary to fulfil the purposes we collected it for, including for our business needs and for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of the information, the purposes for which we process the information and whether we can achieve those purposes through other means. We may also be required to keep personal information for a specific period to satisfy any applicable legal requirements. Please contact us using the contact details in this Privacy Notice if you would like more information. 

In some circumstances we may anonymise the personal information and use the anonymised information for statistical purposes or to improve our services. When we anonymise personal information for these purposes, we will take every reasonable measure to ensure it cannot be linked back to an individual. 

You have rights over your personal information. These include the right to:

• Understand how we use your information 
• See what information we hold about you
• Ask us to correct inaccurate information
• Ask us to delete your information (in some cases)
• Tell us not to use your information (in some cases)
• Ask for your information to be sent to someone else. 
• Make a complaint if you are unhappy with the way we have handled your personal information.

We are always happy to help you exercise these rights. If you would like to do so, please use this link.

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The data protection laws give you the following rights: 

• Right to be informed

You have the right to be informed about how we collect and use your personal information. We do this by providing you the information in this Privacy Notice. You are also free to contact us using the contact details provided in this Privacy Notice.

• Request access to your personal information

This is also known as a “subject access request”. This right allows you to request a copy of the personal information we hold about you and to check that we are lawfully processing it. 

• Request correction of the personal information we hold about you

This right allows you to request that any incomplete or inaccurate information we hold about you is updated, although we may need to verify the accuracy of the new personal information that you provide to us.

• Request erasure of your personal information

This right allows you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. Please note, however, that we may not always be able to comply with your request for erasure where there is an overriding reason to keep it - for example, where we have a legitimate interest in retaining it or where we are required by law to keep it. 

• Object to processing of your personal information

Where we rely on legitimate interest, you have the right to object to the processing. Please note, however, that we may not always be able to comply with your request, if we have an overriding reason to continue to process the information. Where we are processing your personal information for direct marketing purposes, we will always comply with your request.

• Request the restriction of processing of your personal information

This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. 

• Request the transfer of your personal information to another party

You have the right to request that we transfer your personal information to another supplier.

• Right to make a complaint

You have the right to submit a formal complaint directly to us if you are unhappy with how your personal information has been handled.

• No fee usually required

You will not have to pay a fee to exercise any of your 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 request information from you to help us confirm your identity to ensure we do not disclose your information to a third party. 

Where you submit a request, please give us as much relevant detail as you can about what you need, to help us provide all relevant information as quickly as possible.

• Your right to withdraw consent 

In circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw that consent. To withdraw your consent, please contact us using the contact details in this Privacy Notice. 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. 

We may update this notice and we will let you know if we have made any big changes.

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We reserve the right to update this Privacy Notice at any time and we will take reasonable steps to provide you with the updated Privacy Notice when we make any substantial changes. We may also notify you in other ways from time to time about the processing of your personal information.