Unifrog Education Limited
Privacy Policy
Unifrog Education Limited (“Unifrog” / “we” / “our” / “us”) is committed to protecting and respecting your privacy.
This Policy sets out the basis on which we will process your personal information, including through the Unifrog Website.
Where we refer to the “Unifrog Website” in this Policy, we mean the website which can be accessed at https://www.unifrog.org, and where we refer to the “Unifrog Platform” we mean the parts of the Unifrog Website which you can only access if you have an account with us.
Please read this Policy carefully to understand:
- what information we collect about you;
- how we use and share that information; and
- your rights and choices relating to that information.
Our contact details are at the end of this Policy (see HOW TO CONTACT US below).
TOPICS COVERED:
- WHO WE ARE
- WHO THIS POLICY APPLIES TO
- SCHOOL AGREEMENT
- OTHER TERMS WHICH APPLY TO YOU
- INFORMATION WE COLLECT (INCLUDING WHEN AND HOW WE COLLECT IT)
- HOW WE USE YOUR INFORMATION AND OUR LEGAL BASIS FOR DOING SO
- SHARING / ENABLING OTHERS TO PROCESS YOUR INFORMATION
- WHERE WE PROCESS AND STORE YOUR INFORMATION (INCLUDING TRANSFERS OUTSIDE OF THE EUROPEAN ECONOMIC AREA (“EEA”)
- KEEPING YOUR INFORMATION SECURE
- RETAINING YOUR INFORMATION
- UPDATING AND ACCESSING YOUR INFORMATION
- YOUR RIGHTS
- MARKETING
- OTHER WEBSITES
- CHANGES TO THIS POLICY
- HOW TO CONTACT US
WHO WE ARE
Unifrog is a company registered in England and Wales under company number 08231699 whose registered office is at 71-75 Shelton Street, London, WC2H 9JQ.
For our contact information, please see HOW TO CONTACT US.
WHO THIS POLICY APPLIES TO
Unless we say otherwise, the terms of this Policy apply to:
- “Students”, i.e. someone who uses the Unifrog Platform to help plan their further education or career, for example, to search and compare educational courses, apprenticeships and training opportunities and to draft and upload personal statements, essays and CVs;
- “Teachers”, i.e. someone who uses the Unifrog Platform in a teaching, administrative or supervisory capacity, for example, to provide opinions, comments and recommendations for or about Students (and review those provided by other Teachers), to review Students’ academic performance, activities, skills and interactions, and to set tasks for Students; and
- “Parents”, i.e. a Student's parent or guardian who:
- uses the Unifrog Platform via a "dummy" account in order to explore the opportunities that are available to his/her child, and understand how the Unifrog Platform works; or
- provides their (the Parent’s) personal data in respect of his/her child’s proposed work placement;
- “Visitors”, i.e. someone who visits and uses the Unifrog Website but who does not use the Unifrog Platform; and
- “Employers”, i.e. an employer or a staff member of an employer who provides his/her personal data in respect of a Student’s proposed work placement.
Some sections of this Policy only apply to users in the EU/UK. We make it clear where this is the case.
Where we refer to the “EU”, we mean the following countries: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden.
SCHOOL AGREEMENT
If you are a Student or Teacher, Unifrog will have entered into an agreement with your school or college (“your School”) for the use of the Unifrog Platform (the “School Agreement”).
If you are a Parent, you may have been invited by your child’s school or college to create a “dummy” account on the Unifrog Platform.
OTHER TERMS WHICH APPLY TO YOU
This Policy refers to the following additional terms, which also apply to you:
- the “Unifrog Terms of Use”, which govern your use of the Unifrog Website, including the rules you must follow when you use it; and
- the “Unifrog Cookie Policy ”, which sets out information about the cookies we use in connection with the Unifrog Website.
INFORMATION WE COLLECT (INCLUDING WHEN AND HOW WE COLLECT IT)
We collect the following personal information from and about you:
- Information you give to us
- Information your School gives to us
- Information we collect about you from your use of the Unifrog Website
- Information provided by third parties
1. Information you give to us
When you request a demo of the Unifrog Platform, you must provide us with your name, e-mail address, the name of your school and the closest city to your school.
When you send us a message, provide feedback or report a problem on the Unifrog Website, you must provide us with your name and e-mail address.
When you complete a survey or questionnaire at our request, you may provide us with any personal information you include in your responses.
In addition, if you are a Student:
When you register and create a Unifrog account, you must provide us with your name, title, form group code, e-mail address, date of birth and postcode (if you are based in the UK) and may provide us with your gender. You must also choose a password.
When you use the Unifrog Platform, you may provide us with:
- details of your education and academic performance (for example your achieved and predicted grades);
- details of any further education and career opportunities which may be of interest to you (for example educational courses and further study (including college / sixth form and university), qualifications, MOOCs, open days, apprenticeships, training programmes and other similar opportunities);
- details you include in any other information you upload or submit (whether in an application, personal statement, essay or CV, in any item you add to your locker, or otherwise). For example, you may give us details of your interests and hobbies, as well as any goals or skills you wish to develop;
- your “activities”, i.e. details of your academic and extracurricular activities (including the nature and duration of those activities);
- your “skills”, i.e. details of your skill in key areas (including examples of when you have demonstrated each such skill);
- your “interactions”, i.e. details of relevant interactions (for example with your Teachers and advisors, prospective universities and employers, as well as work experience placements, open days, talks and presentations); and
- details of your referees, including their name and e-mail address.
When you send someone else your CV or details of your activities or skills through the Unifrog Platform, you will provide us with their e-mail address.
When you sign up to participate in a Unifrog coaching programme, course or workshop, you may be asked to provide information on your ethnicity, nationality, and socioeconomic background, for example whether you have ever been eligible for Free School Meals.
After you have left your School, you may provide us with your name, e-mail address, year of leaving your School, and details of any further education and employment you undertake or have undertaken (see SHARING / ENABLING OTHERS TO PROCESS YOUR INFORMATION for more details).
If you are a Teacher:
When you register and create a Unifrog account, you must provide us with your name and e-mail address. You must also choose a password.
When you use the Unifrog Platform, you may provide us with:
- details of the subject(s) you teach and the Students for whom you are responsible;
- records of your interactions with Students; and
- details about yourself, Students, other teachers and other relevant individuals which you include in any other information you upload or submit (for example in opinions, comments or recommendations you provide, items you add to Students’ lockers and tasks you require Students to undertake (whether or not these can be viewed by Students)).
If you are a Parent:
When you register and create a “dummy” Unifrog account, you must provide us with your name and e-mail address. You must also choose a password.
When you agree to a work placement for your child, you must provide us with your name, e-mail address, phone number and your relationship to your child.
When you agree for your child to participate in a Unifrog coaching programme, course or workshop, you must provide us with your name and e-mail address, and may provide us with information about your socioeconomic background.
If you are an Employer:
When a work placement or internship is proposed for a Student, you must provide your name, job role, e-mail address and phone number.
2. Information your School gives to us
If you are a Student:
- we will obtain details for your registration on the Unifrog Platform from your School (including from your Teachers) (for example your name, form group and teachers);
- we will obtain details of your education and academic performance, and prospective further education and career opportunities from your School (for example details of your ability and progress, your interactions, your attendance at your School, your level of achievement, which curriculum you follow, and your Teachers’ opinions, comments and recommendations for or about you (whether or not these can be viewed by you)); and
- we may obtain from your School details of any further education and employment you undertake (for example any college or university you attend, course you study and employment you undertake).
In addition, your School may use the Unifrog Platform to record details of your ethnicity, nationality, your socioeconomic background or socioeconomic markers, whether you are a "looked-after" child, whether you have any special educational needs (SEN), disability or mental health difficulties, your academic predictions and results, and your attendance record, for its own internal reporting purposes. As the provider of the Unifrog Platform, we will store these details and may access them for example during troubleshooting or bug fixing. Separately, we may anonymise these details (meaning that they no longer identify you) and aggregate them with similar anonymised details of other Students to publish reports on how different groups of Students use the Unifrog Platform and progress after they have left School (see HOW WE USE YOUR INFORMATION AND OUR LEGAL BASIS FOR DOING SO for further details.)
If you are a Teacher:
- we may obtain details for your registration on the Unifrog Platform from your School (including from Students and other Teachers) (for example the subject(s) you teach and the Students for whom you are responsible); and
- we may obtain other relevant information about you from your School (for example records of your interactions with Students and any other information uploaded or submitted by Students and other Teachers (including in opinions, comments and recommendations)).
If you are a Parent:
- Your school may use the Unifrog Platform to record your email address, and (subject to the school choosing to), we will send you a weekly summary email of the activities your child has done on Unifrog in the previous day. You can unsubscribe from this email at any time. It is the school's responsibility to obtain permission from you to add your email address to the Unifrog platform.
3. Information we collect about you when you use the Unifrog Website
If you are a Student, Teacher or Parent we will collect details about you from your activity on the Unifrog Platform, including:
- any further education, courses or career opportunities you “shortlist” or search and apply for (whether on your own behalf or on behalf of a Student);
- any “pathways” you explore, or careers, subjects and know-how guides you choose to “favourite” (and, if you are a Teacher, which you send or recommend to a Student); and
- your online and school identifiers; your year of graduation (for Students). All this information is then aggregated, and it is anonymised after your account is deleted, so it cannot be linked to you.
4. Information provided by third parties
When you use the Unifrog Website, we may receive information about that use from other companies who provide us with services in connection with it.
In particular, if you complete a survey or questionnaire, our survey provider e.g. SurveyMonkey, we will collect personal information contained in (or connected with) your responses, but this information will be aggregated and anonymised before being processed any further, so that it cannot be linked to you.
If you are a Student and your School has chosen to use Unifrog’s integrations with the Common Application (the “Common App”), or Parchment, we will have access to some of the application information that is contained in your Common App account and any document or application that is submitted by your Teachers to the Common App, and any document that is submitted by your Teachers via Parchment.
Note: Unifrog’s integrations with the Common App and Parchment are optional modules within the Unifrog platform that facilitate applications to universities around the world, and especially in North America.
After you have left your School, we may receive information telling us which university or other education provider you have enrolled with, from the Higher Education Access Tracker (also known as HEAT).
HOW WE USE YOUR INFORMATION AND OUR LEGAL BASIS FOR DOING SO
We collect information about you so that we can operate the Unifrog Website effectively and provide you with the best possible service.
The information we collect and process depends on how you interact with us. It also depends on the choices you make, for example the features you use on the Unifrog Website and the privacy settings you select on your device.
You may choose not to provide or allow us to collect certain information. If this is the case, you may not be able to use some parts of the Unifrog Website (where we need that information for you to do so).
Learn more below about how and why we use your information (and our legal basis for doing so) if you are a:
Students |
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Type(s) of personal information we process |
Why we process this personal information |
Our legal basis (and, where applicable, our appropriate processing condition) for processing this personal information |
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To help us to identify you and your Unifrog account (including to verify your eligibility to use the Unifrog Platform) |
To allow us to perform our obligations under the School Agreement |
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To keep your Unifrog account secure |
To enable us to pursue our legitimate interests to keep the Unifrog Platform secure and prevent fraud |
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To allow us to analyse how the Unifrog Platform is used (for example by carrying out statistical analysis) |
To enable us to pursue our legitimate interests to understand how the Unifrog Platform is used |
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To improve your (and your Teachers’) experience of the Unifrog Platform |
To enable us to pursue our legitimate interests to:
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To enable your Teachers to see how you progress after you have left School and to compare this with Students at other schools |
To enable your School to pursue its legitimate interests to allow Teachers to understand and compare how their Students progress after they have left school
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To enable your School to improve equality of opportunity and support for different groups of Students |
To enable your School to pursue its legitimate interests to support its Students fairly and appropriately Appropriate processing condition: substantial public interest (equality of opportunity or treatment) |
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To allow us to determine whether you are eligible to participate in a Unifrog programme, course or workshop that you wish to sign up to |
To enable us to pursue our legitimate interests to:
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To enable us to anonymise these details, aggregate (or combine) them and publish reports on how different groups of Students use the Unifrog Platform and progress after they have left School To enable your School to carry out statistical analysis on the data relating to its Students, to assess how different groups of Students progress after they have left School |
To enable us to pursue our legitimate interests to:
To enable your School to pursue its legitimate interests to understand how different groups of Students progress after they have left School Appropriate processing condition (where applicable, including for health and ethnicity data, SEN status and “looked-after” status): necessary for statistical purposes in the public interest |
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To obtain a reference from your referee |
Your referee or your contact’s consent, which you must obtain before giving us this information |
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To deal with any enquiries, correspondence, feedback, concerns or complaints from you and/or to improve the Unifrog Website
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To enable us to pursue our legitimate interests to:
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To obtain your views and opinions on education and/or to improve the Unifrog Website |
To enable us to pursue our legitimate interests to:
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To enable us to send you information about the Unifrog Platform and/or other products or services of ours which may be of interest to you |
Your consent |
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To enable your School to contact you about its alumni programme (for example to send you school news; invitations to events, reunions and networking opportunities; information about work experience, job opportunities and fundraising; and requests to speak at its events) |
Your consent |
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To enable you to connect your Common App account with your Unifrog account (if you use the Common App to apply to universities and colleges in the US, Canada and elsewhere). To enable your Teachers to upload to and access your information on the Common App, via the Unifrog Platform. |
To enable us to pursue our legitimate interests to:
as part of our service to you and your School. |
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To enable you and your Teachers to submit documents to universities that receive documents via Parchment |
To enable us to pursue our legitimate interests to:
as part of our service to you and your School. |
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Information we collect when you use the Unifrog Website such as:
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For troubleshooting. To keep the Unifrog Website secure and to prevent fraud. To enable us to store usage data for 365 days so that we can address any security breach on the Unifrog Platform. |
To enable us to pursue our legitimate interests to:
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Teachers |
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Type(s) of personal information we process |
Why we process this personal information |
Our legal basis for processing this personal information |
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To help us to identify you and your Unifrog account (including to verify your eligibility to use the Unifrog Platform) |
To allow us to perform our obligations under the School Agreement |
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To keep your Unifrog account secure |
To enable us to pursue our legitimate interests to keep the Unifrog Platform secure and prevent fraud |
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To improve your (and your Students’ and other Teachers’) experience of the Unifrog Platform |
To enable us to pursue our legitimate interests to:
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To create and use a video “case study” about the Unifrog Platform for our promotional purposes |
To enable us to pursue our legitimate interests to promote the Unifrog Platform |
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To deal with any enquiries, correspondence, feedback, concerns or complaints from you and/or to improve the Unifrog Website
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To enable us to pursue our legitimate interests to:
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To obtain your views and opinions on education and/or to improve the Unifrog Website |
To enable us to pursue our legitimate interests to:
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To enable us to send you information about the Unifrog Platform and/or other products or services of ours which may be of interest to you |
Your consent |
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Information we collect when you use the Unifrog Website such as:
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To carry out research and statistical analysis, for example, so that:
To ensure that the Unifrog Website is presented in the best way for you and for your device To enable us to understand how you use the Unifrog Website (so that we can promote and market the Unifrog Platform, for example) To keep the Unifrog Website secure and to prevent fraud To enable us to store usage data for 3 years so that we can address any security breach on the Unifrog Platform. |
To enable us to pursue our legitimate interests to:
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Information we collect when you use the Unifrog Platform such as:
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To enable us to anonymise this information, aggregate (or combine) it in order that we may:
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To enable us to pursue our legitimate interests to:
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Parents |
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Type(s) of personal information we process |
Why we process this personal information |
Our legal basis for processing this personal information |
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To help us to identify you and your “dummy” Unifrog account (including to verify your eligibility to use the Unifrog Platform) |
To enable us to pursue our legitimate interests to allow you to:
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To keep your “dummy” Unifrog account secure |
To enable us to pursue our legitimate interests to keep the Unifrog Platform secure and prevent fraud |
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To enable us to arrange a work placement for your child |
To enable us to pursue our legitimate interests to arrange a work placement for your child |
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Information we collect when you use the Unifrog Website such as:
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To allow us to analyse how the Unifrog Website works (for example by carrying out research, statistical analysis and troubleshooting) To ensure that the Unifrog Website is presented in the best way for you and for your device To enable us to understand how you use the Unifrog Website To keep the Unifrog Website secure and to prevent fraud To enable us to store usage data for 3 years so that we can address any security breach on the Unifrog Platform. |
To enable us to pursue our legitimate interests to:
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Information we collect when you use the Unifrog Platform such as:
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To enable us to anonymise this information, aggregate (or combine) it in order that we may:
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To enable us to pursue our legitimate interests to:
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Information we collect when you agree to your child participating in a Unifrog coaching programme, course or workshop:
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To allow us to determine whether your child is eligible to participate in a Unifrog programme, course or workshop that your child wishes to sign up to, and to have an emergency contact for the duration of the programme, course or workshop. |
To enable us to pursue our legitimate interests to:
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Employers |
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Type(s) of personal information we process |
Why we process this personal information |
Our legal basis for processing this personal information |
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To enable us to arrange a work placement for a Student |
To enable us to pursue our legitimate interests to arrange a work placement for a Student |
Visitors |
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Type(s) of personal information we process |
Why we process this personal information |
Our legal basis for processing this personal information |
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To fulfil a request from you to provide you with a demo of the Unifrog Platform To identify where you are contacting us from so that we can direct your request appropriately |
To enable us to pursue our legitimate interests to promote the Unifrog Platform |
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To deal with any enquiries, correspondence, feedback, concerns or complaints from you and/or to improve the Unifrog Website
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To enable us to pursue our legitimate interests to:
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To enable us to send you information about the Unifrog Platform and/or other products or services of ours which may be of interest to you |
Your consent |
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Information we collect when you use the Unifrog Website such as:
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To allow us to analyse how the Unifrog Website works (for example by carrying out research, statistical analysis and troubleshooting) To ensure that the Unifrog Website is presented in the best way for you and for your device To enable us to understand how you use the Unifrog Website To keep the Unifrog Website secure and to prevent fraud To enable us to store usage data for 3 years so that we can address any security breach on the Unifrog Platform. |
To enable us to pursue our legitimate interests to:
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More about the information we use and why (this section only applies if you are in the EU/UK)
Where we need consent to use your personal information, we will clearly ask you for this – and you can withdraw that consent at any time. For example, we may ask you to positively opt-in to us sending you marketing communications when you first log in to your Unifrog account.
Where you provide us with other people’s personal information (for example, if you are a Student and you send someone else your CV through the Unifrog Platform and you give us his or her e-mail address for this purpose), you must obtain their consent before doing so.
If you have any questions or you need any further information regarding how we use your information, please contact us (see HOW TO CONTACT US).
SHARING / ENABLING OTHERS TO PROCESS YOUR INFORMATION
When and why might you share my personal information with others?
If you are a Student or Teacher, we need to share some of your personal information with your School (including, as applicable, your Teachers or your Students). See below for more details.
In addition, whether you are a Student, Teacher, Parent or Visitor, in order to operate the Unifrog Website and provide our services to you, we use carefully selected companies. In doing so, these companies may process your information.
We make sure that these selected companies take security measures to protect your information in line with our policies. We do not allow them to use your personal information for their own purposes and we only permit them to process your personal information as is necessary and in accordance with our instructions.
In some circumstances, we may need to share your personal information with a data protection regulator or in order to comply with the law or a legal process. We may also do so where we have another legitimate interest that is not outweighed by your interests and fundamental rights (for example, to maintain the security of our computer systems).
Who will you share my personal information with?
Students
We will share some of your personal information with your School (including your Teachers) so that you and they can use the Unifrog Platform as intended. For example, your Teachers will be able to see some of your information, including your name, details of your education and academic performance, as well as any further education and career opportunities which are of interest to you. They will also be able to access and comment on your activities, skills and interactions, and on any other information you upload or submit. We may also share with your School details of any educational courses, open days, internships, apprenticeships, job opportunities and other similar opportunities offered by universities, other educational establishments and employers that are available to you.
Your School and/or your Teachers may choose to upload certain types of information to the Unifrog Platform which they do not want to share with you, for example, opinions or comments on your activities, skills and interactions which are only intended for other Teachers. For the same reason, they may also choose to upload something to your locker, which you are not able to see. This may include personal information about you. See YOUR RIGHTS for details on your right to access any personal information which we hold about you.
If you provide us with details of your referees, we will share your name with that referee so that they can provide a reference about you. Similarly, if you send someone else details of your activities or skills through the Unifrog Platform, we will send your name and those details to that individual at your request.
If your School has agreed for your School's Unifrog subscription to be paid or part paid for by another entity, for example an education foundation it belongs to, we may pass on to this entity information allowing it to assess how much you have used the platform.
If your School’s Unifrog account is integrated with the Common App and you apply to universities via the Common App, The Common Application, Inc. will receive some of your personal information contained in your Unifrog account, including your name, email address, date of birth, details of your education and academic performance. The Common Application, Inc. will also be able to access personal information that is contained in any document or application that is submitted by you, or by a Teacher on your behalf, to the Common App via the Unifrog Platform.
If your School’s Unifrog account is integrated with Parchment and you or your Teachers submit a document from the Unifrog Platform via Parchment to a university, Parchment LLC will receive some of your personal information that is contained in your Unifrog account, including your name and email address, as well as any personal information that is contained in the document that you submit.
If you agree (by ticking the relevant box when you complete your Unifrog account registration and log in to the Unifrog Platform for the first time), we may share with your School some of your information after you have left school so that your School can contact you about its alumni programme. This includes your name, e-mail address, year of leaving school, and details of any further education or employment you undertake (or have undertaken). Your School will use this information to send you school news; invitations to events; information about work experience, job opportunities and fundraising; and requests to speak at its events, for example. We will rely on your consent as the legal basis for sharing this information with your School. You can withdraw your consent at any time by changing the privacy settings of your Unifrog account, or by contacting us (see HOW TO CONTACT US) or by notifying your School, either by email or by using the unsubscribe link at the bottom of its messages.
Unless you ask us not to, we will share some of your personal information with the Higher Education Access Tracker to find out which university or other education provider you have enrolled with (if any), for the reasons mentioned above (see here) We may remind your university of any interactions you had with them on the Unifrog Platform before you applied to them.
We may share details of any further education or employment you undertake with your Teachers so that they can see how you progress after you have left school. Your School may analyse and compare this information with similar (anonymised) information about Students from other schools for its own internal reporting and analysis.
We will share your details with an Employer if we are arranging a proposed work placement for you.
Teachers
We will share some of your personal information with your School (including your Students and other Teachers) so that you and they can use the Unifrog Platform as intended. For example, your Students will be able to see some of your information, including your name, details of the subject(s) you teach and the Students for whom you are responsible. We will also share records of your interactions with Students and/or your opinions, comments or recommendations, together with any items you add to their lockers, if you choose to allow those Students to see this information.
If you use the Common App via the Unifrog Platform, The Common Application, Inc. will receive certain information about you, including your name and the email address you use as your Unifrog username. It may use this information to contact you in respect of the Common App service, for example regarding updates to the online school forms system.
If your School uses Parchment via the Unifrog Platform, Parchment LLC will receive certain information about you, including your name and the email address you use as your Unifrog username.
Employers
We will share your personal information with a Student and their Parent in relation to their proposed work placement.
If you are a Student or Teacher:
- when you complete a survey or questionnaire, our survey provider, e.g. SurveyMonkey, may collect certain technical information, including data about your device or browser (such as your geographic location based on your device IP address) and data about pages you’ve visited and files you’ve viewed on their website or app to analyse your usage patterns, and for troubleshooting and bug fixing, for example.
Our survey provider, e.g. SurveyMonkey, may also collect personal information contained in (or connected with) your survey or questionnaire responses, but this information will be aggregated and anonymised before being processed any further, so that it cannot be linked to you.
- the information we share with your School may also be used by your School and by us for analytical purposes and to help your School use the Unifrog Platform, for example to give your School an impression of how it is supporting its Students.
Who else might obtain my personal information?
Whether you are a Student, Teacher, Parent or Visitor:
- we use Google Analytics to obtain statistics and insights regarding your access and use of the Unifrog Website (see Information provided by third parties). As the provider of that service, Google will receive certain information about that access and use. This is necessary so that we can understand how the Unifrog Website is used in order to improve it; and
- other companies who provide services to us may also access or receive some of your information. For example, we use a software developer, SAV London Ltd, to help us to design and build the Unifrog Website.
WHERE WE PROCESS AND STORE YOUR INFORMATION (INCLUDING TRANSFERS OUTSIDE OF THE UK AND EUROPEAN ECONOMIC AREA (“EEA”)
If you are a Visitor, we will only process and store your personal information in the UK and/or EEA.
If you are a Student, Teacher or Parent:
- if your School is based in the UK or EEA, we will only process and store your personal information in the UK and/or EEA (unless you, as a Student or Teacher, use The Common App or Parchment for university applications – please see below);
- if your School is based outside the UK and EEA, we will process and store your personal information on our systems in the UK and/or EEA, and we will also transfer personal information back to you (and your School, Students, Teachers and Employer) in your own country in order to provide the Unifrog Website to you and/or to fulfil our obligations in the School Agreement and/or to arrange a work placement or internship. We take reasonable precautions to ensure that your information will be adequately protected whenever it is transferred outside the EEA, and that it will be treated in a way which is consistent with UK and European data protection laws. (If you, as a Student or Teacher, use The Common App or Parchment for university applications, please see below);
- if you are a Student applying to universities via Unifrog’s integrations with the Common App and/or Parchment, or if you are a Teacher who uses our integration with the Common App and/or Parchment, The Common Application, Inc. and/or Parchment LLC will access your personal data from the US. The Common App Inc and Parchment LLC may transfer your personal data to a recipient in another country where personal data is not protected to the same level as the UK/EU. For more details please see their privacy policies:
Privacy policy (commonapp.org)
Privacy Policy | Parchment
- if you choose to use the Google Maps function or complete a survey, Google or SurveyMonkey will transfer your personal data to the US. Google and SurveyMonkey have both certified under the EU-US Data Privacy Framework, so that your personal data is provided with a level of protection that is “essentially equivalent” to that provided by the General Data Protection Regulation (GDPR) and UK GDPR.
If you are an Employer:
- if you, the Student and their Parent are based in the UK or EEA, we will only process and store your personal information in the UK and/or EEA;
- if you, the Student and/or their Parent are based outside the UK and EEA, we will process and store your personal information on our systems in the UK and/or EEA, and we will transfer your personal information back to you in your own country, and to the Students and Parent in their own country.
The EEA includes all the countries in the EU (listed here) and also Iceland, Liechtenstein and Norway.
KEEPING YOUR INFORMATION SECURE
We have designed the Unifrog Website keeping in mind the safety of your personal information. All information you provide to us is stored on secure severs. We have put in place technical and organisational measures to safeguard your information.
Unfortunately the transmission of information via the Internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of any information transmitted via the Unifrog Website; 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.
If you are worried that your account or your information might be at risk (for example, if somebody else has found out your password), please contact us (see HOW TO CONTACT US).
RETAINING YOUR INFORMATION (this section only applies if you are in the EU/UK)
We will only retain your personal information for as long as is necessary to fulfil the purposes we collected it for, including for any legal, accounting or reporting obligations.
To decide how long we keep your information, we consider the type of information you give to us or which we collect, and how sensitive that information is. We also consider the risk of harm that might occur if the information went missing or if somebody used it in a way they were not supposed to, for example, and the reasons why we are using your information in the first place.
In some circumstances, we may anonymise your information, which means that it is no longer connected to, or about, you. If we do this, we may use this information without any further permission from you. Even if you ask us to delete your information, we may still need to keep it in a form that does not identify you (see YOUR RIGHTS).
We will keep your information for the following periods, unless we tell you otherwise (or you ask us to delete your information):
- if you are a Student or Teacher, we will keep your information for as long as you continue to use the Unifrog Platform. If you do not use the Unifrog Platform for 4 years then we will delete your information. We hold onto your information for this 4-year period so that you can continue to access useful information, such as personal statements and CVs, after you (or the Students you teach) have left school.
If the School Agreement terminates, we may delete some or all of your information from the Unifrog Platform. We will tell your School before we do so, so that you can download your information if you wish;
- if you are a Parent, we will delete your information on any “dummy” account you create on the Unifrog Platform for as long as you continue to use the Unifrog Platform. If you do not use the Unifrog Platform for 4 years then we will delete your information.
We will delete any information you provide in relation to a proposed work placement for your child when we delete your child’s Unifrog account;
- if you are a Visitor and you do not access the Unifrog Website for one year, then we will delete your information.
We may keep certain information (for example, your name and e-mail address) for longer periods than those stated above if you have agreed to us using it, for example, for keeping in touch about our products or services, or for our promotional purposes.
Please contact us if you would like further details on how long we keep your information (see HOW TO CONTACT US).
UPDATING AND ACCESSING YOUR INFORMATION (this section only applies if you are in the EU/UK)
If you are in the EU or UK, you have the right under EU/UK data protection laws to access personal information held about you, subject to certain conditions, and to ask for it to be changed or deleted.
If you would like to access or amend the personal information which we hold about you, or if you would like us to stop using your personal information, please contact us (see HOW TO CONTACT US).
To learn more about the rights you may have in relation to your personal information see YOUR RIGHTS.
YOUR RIGHTS (this section only applies if you are in the EU/UK)
If you are in the EU or UK, by law you have the following rights with regard to your personal information:
- Access. You have the right to obtain confirmation as to whether or not your personal information is being processed, and, if it is, request access to that personal information (commonly known as a “data subject access request”). We will need you to prove your identity before we release any personal information to you. In addition, we will normally contact your School to let them know you have made a data subject access request. It is our policy not to disclose references about Students given by their Teachers or others.
- Correction or deletion. You have the right to ask us to correct or delete any personal information that we hold about you (unless we have the legal right to retain it). You also have the right to ask us to delete your information where you have exercised your right to object to processing (see below).
- Objection. You have the right to object to processing of your information where we are relying on a legitimate interest 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 information for direct marketing purposes.
- Restriction. You also have the right to restrict us from processing your personal information. You can ask us to temporarily stop processing information about you, for example if you want us to establish that it is accurate or the reason for processing it.
- Change of preferences. You can change your information processing preferences at any time. For example, if you have given your consent to us to make suggestions and recommendations to you about educational courses, job opportunities, internships, open days, etc, but have changed your mind, you can contact us using the details provided below or clicking the relevant link in any communication you receive (where this specifically relates to marketing messages, see MARKETING).
- Data portability. In some circumstances, you have the right to ask us transfer a copy of the personal information we hold about you to someone else.
Please note that if you ask us to stop processing your personal information in a certain way or if you ask us to delete your information, and we need to use that information to provide the Unifrog Website to you, then you may not be able to continue to use it. This does not include your right to object to direct marketing, which can be exercised at any time without restriction.
If you would like to exercise any of the rights mentioned above, please contact us (see HOW TO CONTACT US).
The above rights do not apply to anonymised personal information.
No fee usually required to access your personal information
You will not normally have to pay a fee to access your personal information (or to exercise any of the other rights set out above). However, we may charge a reasonable fee if your request for access is unreasonable or excessive. Alternatively, we can refuse to comply with the request.
What we may need from you
We may need to request specific information from you to confirm your identity and verify 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.
Right to withdraw consent
Where you have consented to the collection, use or transfer of your personal information 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 (see HOW TO CONTACT US). 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.
MARKETING (this section only applies if you are in the EU/UK)
If you are a Student, as mentioned above we would like to send you information by e-mail and/or via notifications on the Unifrog Platform about services and opportunities from relevant third parties such as universities, other educational establishments and employers which may be of interest to you.
We will ask whether you would like us to send you these e-mails and/or notifications when you complete your Unifrog account registration and log in to the Unifrog Platform for the first time.
You can also manage your preferences by changing the privacy settings of your Unifrog account.
We will not provide your personal information to any other third party businesses for marketing purposes, but if you agree, we may provide some of your personal information to your School for its alumni programme (see SHARING / ENABLING OTHERS TO PROCESS YOUR INFORMATION).
OTHER WEBSITES
The Unifrog Website and the Unifrog Platform contain links to other websites such as Facebook, Twitter, LinkedIn, Google Drive, SurveyMonkey, Dropbox, Common App and Parchment. This Policy only applies to the Unifrog Website and the Unifrog Platform so when you link to other websites, you should read their own privacy policies.
CHANGES TO THIS POLICY
This Policy was last updated in November 2023.
We will update this Policy from time to time and will post any updates on this page. If you don’t agree with those changes, you can always stop using the Unifrog Website and stop giving us any more of your information.
HOW TO CONTACT US
Unifrog is the “data controller” of your personal information which is processed for the purposes set out in this privacy policy. This means that we are responsible for deciding how we hold and use personal information about you.
Unifrog is registered with the UK Information Commissioner’s Office with the registration number: Z357522X.
If you are in the UK or another non-EEA country and you have any questions about this Policy or how we handle your personal information, please e-mail us at info@unifrog.org. Alternatively, you can write to us at Brickfields, Unit 215, 37 Cremer Street, E2 8HD.
If you are in the EEA, please email alex@unifrog.org.
Complaints (this section only applies if you are in the EU/UK)
If, for any reason, you are not happy with the way that we have handled your personal information, please contact us at the address set out above.
If you are still not happy, you have the right to make a make a complaint to your local data protection regulatory authority.
If you are based in the UK, you can contact the Information Commissioner’s Office using the link here: https://ico.org.uk/global/contact-us/.
Each EU country has its own data protection authority. You can find their contact details using the link here: https://edpb.europa.eu/about-edpb/board/members_en