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PRIVACY POLICY

Privacy Policy

We care about your privacy and about keeping your personal information safe. This policy explains what information APEX ED PVT LTD collects about you, how we use it, who we might share it with, and how you can exercise your privacy rights. It applies whenever you visit our website, submit an enquiry or application, complete a lead form through a third-party platform, enrol in or participate in an APEX ED programme, use our digital or learning services, or otherwise interact with us about educational programmes and related services.

It’s important that you read this policy so you understand how and why we use your information. You can jump to any section below, or read it in full.

  1. Key Terms
  2. Who We Are
  3. Who to Contact
  4. What Is Personal Information
  5. Our Data Protection Principles
  6. What We Collect and Why
  7. Marketing and Advertising
  8. Cookies
  9. Who We Share Your Information With
  10. Sending Your Information to Other Countries
  11. Keeping Your Information Safe
  12. How Long We Keep Your Information
  13. Your Rights
  14. Children and Young People
  15. Automated Decision-Making and Profiling
  16. Third-Party Websites and Platforms
  17. Changes to This Policy
  18. Complaints
  19. Contact Us

Applicant / Prospective Student – anyone who enquires about, applies for, or expresses interest in an APEX ED educational programme.

Partner – a university, awarding organisation, academic institution, professional body or other organisation that APEX ED works with in connection with programme delivery, recognition, certification, progression or related educational services.

Agent – a third party engaged to help promote programmes or support an application, on our behalf or yours.

Lead Form – an enquiry form you complete on our website, or on a third-party platform such as Meta, Instagram, TikTok, LinkedIn or Google, asking us to contact you.

Sponsor – an individual, government body or organisation contributing to a student’s fees or costs.

We are APEX ED PVT LTD, an education and training provider offering educational programmes and related services. Depending on the programme, APEX ED may provide or support programme delivery and may work with universities, awarding organisations and other academic or professional partners in connection with qualifications, recognition, certification, progression and other educational services.

For the personal information described in this Privacy Policy, APEX ED PVT LTD is generally the data controller. This means that we decide why and how that information is processed. Universities, awarding organisations, academic partners, payment providers and other organisations may act as independent controllers for information they process for their own purposes. Where that applies, their own privacy information may also apply.

Legal name: APEX ED PVT LTD
Company number: 14236681
Registered office: 20-22 Wenlock Road, London, England, N1 7GU, United Kingdom
In this policy, “APEX ED,” “we,” “us,” and “our” refer to APEX ED PVT LTD.

Data protection queries and requests: [email protected]
General enquiries: [email protected]
Postal address: APEX ED PVT LTD, 20-22 Wenlock Road, London, England, N1 7GU, United Kingdom

If you would like to exercise a privacy right – including access, correction, deletion, restriction, objection, portability or withdrawal of consent where applicable – you may contact us using the data protection email above. We may ask for information reasonably necessary to confirm your identity before acting on a request.

If you have a complaint, please contact us so that we can review the matter. You also have the right to complain directly to a competent data-protection supervisory authority where applicable; Section 18 provides further information.

Personal information is information relating to an identified or identifiable individual – for example your name, address, phone number, email address, student record, passport number or online identifier.

Some personal information receives additional protection under data-protection law. Under the UK GDPR, special category personal data includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric data used for identification, health data, and information concerning a person’s sex life or sexual orientation. We only process special category information where it is necessary and where an appropriate legal condition applies. Information such as passport details, nationality or immigration status may be sensitive in context, but is not special category data merely because of its subject matter.

Please don’t send us sensitive information unless it’s genuinely relevant to your enquiry, application, programme, support needs or another legitimate APEX ED process.

We follow data-protection principles when using personal information. We seek to:

APEX ED processes personal information in accordance with applicable data-protection and privacy law, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR), each as amended from time to time, where applicable.

We collect different information depending on how you interact with us.

If you enquire or apply. When you contact us, submit a lead form, or apply for a programme, we may collect information such as your name, contact details, date of birth, nationality, country of residence, address, education history, qualifications, language proficiency, employment or professional history, personal statements, references and referee details, the programmes and destinations you are interested in, and application or intake preferences. Where relevant to admissions or verification, we may also need passport or other identification information and immigration-related information. In limited circumstances, we may process health or disability information where relevant to accessibility, support or reasonable adjustments.

If you complete a lead form through advertising. When you respond to an advertisement or lead form on a third-party platform, the platform may pass us the information you submitted – typically your name and contact details – together with information about how the enquiry was generated, so that we can respond to you and, where permitted, understand campaign performance.

If you enrol in or participate in a programme. We may collect enrolment records, student or learner identifiers, programme information, learning-platform activity, submissions, attendance information where applicable, academic progress, assessment results, academic-integrity records, certification and progression information, and communications with academic and support staff, in order to provide and administer the programme and related educational services.

If you make a payment. We may collect billing information, transaction references, invoices, scholarship or fee-reduction information and payment status. We do not normally need to store complete payment-card details ourselves where payments are processed directly by an external payment provider, such as Stripe or another payment processor.

If you visit our website or use digital services. We may automatically collect technical information such as your IP address, browser and device information, approximate location, log data, pages visited, referral source, and website or platform usage information through server logs, cookies and similar technologies. See Section 8 for further information.

If you are a parent, guardian or sponsor. Where you’re supporting an applicant or student, we may collect your name, contact details and relationship to the student so we can communicate with you where appropriate and, where required, involve you in relevant administrative or support matters.

If you contact us about a complaint, appeal or support matter. We may process the information contained in your correspondence and any supporting documents, together with records of our review and response, to administer the relevant process and maintain appropriate records.

If you subscribe to updates or marketing. We may process your name, contact information, programme interests, communication preferences and relevant engagement information so that we can send or manage communications where permitted by law.

Where We Obtain Personal Information
Personal information may be provided directly by you through enquiries, lead forms, applications, enrolment documents, communications, learning or student platforms, support requests, payments, events or newsletter subscriptions. We may also receive information from other lawful sources where relevant, including referees, education agents or representatives, parents or sponsors, universities, awarding organisations, academic partners, service providers, payment providers, learning-platform providers, public authorities and publicly available sources. Where required by law, we will provide appropriate privacy information when we obtain personal data from another source.

Lawful Bases
The lawful basis we rely on depends on the purpose and circumstances of the processing. Where applicable under the UK GDPR, APEX ED may rely on one or more of the following:

  • Contract or steps before entering into a contract – for example, handling an application, enrolment and delivery of educational services;
  • Legal obligation – where processing is necessary to comply with an applicable legal or regulatory requirement;
  • Legitimate interests – where processing is necessary for legitimate educational, administrative, operational, security, fraud-prevention, communications, record-keeping or legal interests and those interests are not overridden by the individual’s rights and freedoms; and
  • Consent – where we ask you to agree to a specific use and consent is the appropriate lawful basis.

Where APEX ED relies on legitimate interests, those interests may include operating and improving educational and digital services, maintaining secure and efficient systems, preventing fraud or misuse, responding to enquiries, communicating with relevant contacts, protecting legal rights, and maintaining appropriate academic and administrative records. We consider the impact on individuals before relying on this basis.

Where special category personal data is processed, APEX ED will identify both an applicable Article 6 lawful basis and a separate condition under Article 9 of the UK GDPR and, where relevant, the Data Protection Act 2018. Depending on the circumstances, this may include explicit consent or another condition permitted by law.

When Providing Information Is Necessary
Some personal information is optional. Other information may be necessary in order for APEX ED to respond to an application, verify eligibility or identity, enter into or perform a student contract, provide programme access, administer assessments or payments, register a student with an awarding organisation or university where applicable, meet legal or regulatory requirements, or provide another requested service. If required information is not provided, we may be unable to process an application, complete verification, provide or continue a service, register or certify a student, process a payment, or perform the relevant contractual or administrative activity.

Where permitted by law and consistent with your preferences, we may contact you by phone, WhatsApp, SMS, email or social-media message with programme details, entry requirements, fees, scholarship information, event invitations or other information relevant to your enquiry or interests.

We’ll ask for your consent where consent is required. In other cases, we may rely on another lawful basis where available, but we will still comply with applicable electronic-marketing rules.

If you’re in Canada, where Canada’s Anti-Spam Legislation (CASL) applies to a communication, we will send commercial electronic messages only where a lawful form of consent or other permitted basis exists and will provide the information and unsubscribe mechanism required by applicable law.

If you’re in the UK or EU/EEA, electronic marketing will be carried out in accordance with the applicable direct-marketing and electronic-communications rules, including consent requirements and any lawful exception or “soft opt-in” that may apply.

You can withdraw consent or opt out at any time using an unsubscribe mechanism in the relevant communication, by telling us through the communication channel, or by emailing [email protected]. We may retain limited suppression information so that your opt-out can continue to be respected.

Our website may use cookies and similar storage or access technologies, including pixels, tags, local storage and advertising identifiers, to support website functionality, understand how visitors use the site and, where enabled, measure or support advertising activities. Depending on the technologies actually used, providers may include analytics, advertising or social-media platforms.

Some technologies may be used without consent where an applicable legal exception permits this. Under current UK rules, this can include technologies that are strictly necessary and, subject to the statutory conditions, certain technologies used solely for statistical purposes to improve a service or to adapt its appearance or functionality to a user preference. Where an exception requires clear information and a simple, free way to object, APEX ED will provide this.

Where consent is required, including for advertising, cross-service tracking, profiling or other non-exempt purposes, the relevant technology will be used only after an appropriate choice has been provided. You can manage available choices through the website Cookie Settings facility [Link]. Browser settings may also allow you to block or delete cookies, although doing so may affect certain website features.

To provide our services, we sometimes need to share personal information where necessary, lawful and proportionate. Recipients may include:

Universities, awarding organisations and academic or professional partners, for admissions, registration, assessment, quality assurance, qualification verification, certification, progression or other programme-related purposes where applicable.

Service providers, including website hosting, cloud, CRM, learning-management systems, communications, video-conferencing, analytics, advertising, security and payment-processing providers.

Professional advisers, such as lawyers, accountants, auditors and insurers, where necessary.

Authorities and regulators, including courts, law-enforcement bodies, tax authorities, safeguarding bodies or regulators, where disclosure is required or permitted by law.

A buyer, successor or relevant adviser, if APEX ED is involved in a lawful corporate restructuring, merger, acquisition or transfer, subject to appropriate safeguards.

We don’t sell personal information for money. Where an applicable law gives you a specific right to opt out of a form of disclosure that it defines as a ‘sale’, ‘sharing’ or targeted advertising, we will provide the relevant mechanism where that law applies to our processing.

Where a third party processes personal information on APEX ED’s behalf as a processor, we use appropriate contractual and organisational safeguards. Where another organisation acts as an independent controller, its own privacy notice and legal responsibilities may also apply.

We operate internationally and use digital platforms, so personal information may be accessed, processed or stored outside the country where you live, including in the United Kingdom and in countries where our service providers or academic partners operate.

Where personal information is transferred from the United Kingdom in a way that is restricted under UK data-protection law, APEX ED will use an applicable lawful transfer mechanism. Depending on the circumstances, this may include UK adequacy regulations, the UK International Data Transfer Agreement (IDTA), the UK Addendum to approved EU standard contractual clauses, or another lawful transfer provision. Where required, we will also assess the protection available for the transfer and apply supplementary contractual, organisational or technical measures.

Where EU/EEA data-protection law applies to particular processing, any restricted transfer subject to that law will be handled using an applicable EU transfer mechanism, such as an adequacy decision or the European Commission’s Standard Contractual Clauses, together with any additional measures required in the circumstances.

You may contact [email protected] for further information about safeguards relevant to a particular transfer.

We use reasonable technical and organisational measures to protect your information against unauthorised access, alteration, loss, misuse, disclosure or destruction. Depending on the nature of the processing, measures may include access controls, secure systems and hosting, encryption or secure transmission where appropriate, staff confidentiality and awareness requirements, account controls, incident-response procedures and appropriate arrangements with service providers. Access is limited according to role and need.

No digital system can be guaranteed to be completely secure. If a personal-data breach occurs, APEX ED will assess the circumstances and will notify affected individuals and relevant supervisory authorities where required by applicable law.

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including to provide educational services, maintain academic and certification records, meet contractual obligations, comply with legal, regulatory, accounting or awarding-body requirements, resolve disputes and protect legitimate legal interests.

Retention periods may differ according to the type of information and the relevant programme or relationship. In deciding how long to retain information, APEX ED may consider:

Marketing information will be retained in accordance with applicable law and communication preferences, including limited suppression information necessary to respect an opt-out. Retention of cookie and similar-technology information is addressed through the relevant Cookie Policy or Cookie Settings information.

Where APEX ED adopts a more specific retention schedule for a particular record category, that schedule will apply subject to any overriding legal, regulatory, academic or contractual requirement.

Depending on applicable law and the circumstances of the processing, you may have rights relating to your personal information, including:

These rights are not absolute and may be subject to legal conditions or exemptions. To exercise a right, email [email protected]. We may ask for information reasonably necessary to confirm your identity and will respond within the period required by applicable law. There is normally no fee, although applicable law may permit a reasonable fee or other action in limited circumstances, for example where a request is manifestly unfounded or excessive.

Your Right to Object
You have the right to object at any time to the processing of your personal information for direct-marketing purposes. Where you object to direct marketing, APEX ED will stop using your personal information for that purpose. You may also have the right to object to processing based on legitimate interests. In that case, we will consider the objection in accordance with applicable law and will stop the relevant processing unless there are lawful grounds to continue.

Additional Rights in Some Jurisdictions
Depending on where you live and whether the relevant law applies to APEX ED’s processing, additional or differently framed rights may be available. These may include the following:

United States. Certain state privacy laws may provide rights to access, correct or delete personal information, obtain a portable copy, and opt out of certain sales, sharing, targeted advertising or profiling. Where an applicable law requires recognition of browser-based opt-out preference signals, APEX ED will honour them as required by that law.

Canada. Where applicable Canadian privacy law applies, you may have rights to request access to and correction of personal information and to challenge APEX ED’s compliance with applicable privacy requirements.

Mexico. Where applicable Mexican privacy law applies, you may have rights of access, rectification, cancellation and objection (commonly referred to as ARCO rights), subject to the relevant legal conditions.

EU/EEA. Where the EU GDPR applies to APEX ED’s processing, you may exercise the rights provided under that law and may complain to a competent supervisory authority in an EU or EEA member state.

Australia. Where the Australian Privacy Act 1988 and the Australian Privacy Principles apply to APEX ED’s processing, you may have rights to access and correct personal information and to make a privacy complaint.

New Zealand. Where the New Zealand Privacy Act 2020 applies to APEX ED’s processing, you may have rights including access and correction and may make a privacy complaint under that law.

Some APEX ED programmes may be available to people under 18 depending on the programme and applicable entry requirements. Where we collect or use personal information about a child or young person, we take age into account, collect only what is reasonably necessary, use appropriate safeguards and provide privacy information in a form appropriate to the circumstances.

We may collect parent or guardian information or involve a parent or guardian where this is required by law, reasonably necessary for the educational or contractual relationship, or appropriate to protect the interests of the learner. We do not knowingly use children’s personal information for targeted advertising in circumstances where this would be prohibited by applicable law.

APEX ED may use limited analytics, segmentation or profiling for purposes such as understanding programme interests, improving services or measuring marketing performance where permitted by law. This does not ordinarily involve decisions based solely on automated processing that produce legal or similarly significant effects on an individual.

APEX ED does not intend to make a solely automated decision that produces legal or similarly significant effects without informing the individual and complying with the applicable data-protection requirements. If such processing is used, we will provide the information required by law about the logic involved, its significance, the envisaged consequences and the individual’s applicable rights.

Our website and communications sometimes link to third-party sites or services, including social-media platforms, payment providers, learning platforms, universities and awarding organisations. Those organisations have their own privacy policies and may be responsible for their own processing. We’re not responsible for the privacy practices, content or security of services we don’t control.

We may update this policy from time to time to reflect changes in our services, technologies, providers, processing activities, legal obligations or applicable data-protection requirements. The current version will be published on the APEX ED website with the date of the latest update.

Where required by law, we will bring material changes or new uses of personal information to the attention of affected individuals before the relevant new processing begins.

Please contact us if you’re concerned about how we’ve handled your information so that we can review the matter:

Email: [email protected]
Address: APEX ED PVT LTD, 20-22 Wenlock Road, London, England, N1 7GU, United Kingdom

You also have the right to complain to the UK Information Commissioner’s Office (ICO). You do not have to contact APEX ED before making a complaint to the ICO.

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
United Kingdom
Telephone: 0303 123 1113
Website: www.ico.org.uk

Depending on where you live and whether the relevant law applies, you may also be able to contact a competent privacy or data-protection authority, including:

APEX ED PVT LTD
20-22 Wenlock Road, London, England, N1 7GU, United Kingdom
Data protection email: [email protected]
General email: [email protected]
Website: www.apexed.co.uk