Politique de confidentialité

My School UP

Privacy Policy

Last Updated on 11th November 2020

Welcome to My School UP!

At My School UP your privacy is our priority and we are committed to the confidentiality of your Data.
This Privacy Policy shall serve to inform you of the extent and of the purpose of the collection, use, consultation, process and transmission of the information provided by you, as the “User” of this website.
By accessing and navigating our website you accept to be governed by My School UP ’s Privacy Policy and the Terms and Conditions (“Agreements”), as outlined on our website: https://www.myschoolup.com/.

1. Definitions

1.1.“Agency”/”We”/”Our”/”Us” – This refers to the Agency named “UP Conseils”, including its parents, subsidiaries, shareholders, directors, officers, agents and/or employees;
1.2. “Agreement” – This refers to this Privacy Policy Agreement contracted between the Agency and you, the User;
1.3. “Agreements” – This refers to this Privacy Policy Agreement and the Terms and Conditions;
1.4. “Customer”/“Client” – This refers to any natural person, group of individuals, single entity, corporate or other statutory body with legal personality that is engaging the Agency for its Services and/or using its website;  
1.5. “Confidential Information”– This refers to any information disclosed by one party to another which is defined as confidential and proprietary as per the terms of the Agreements;
1.6. “Cookies” – This refers to any text file kept in the browser storage (including but not limited to Microsoft Edge and/or Google Chrome) and used on any device, which records specific information, including but not limited to documents, images and/or videos;
1.7. “Data” – This refers to any personal, confidential or other kind of information provided or generated by the User whilst accessing or navigating this website;
1.8. “Data Controller” – This refers to any natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of processing of personal data;
1.9. “Data Processor” – This refers to any natural or legal person, public authority, agency or other body which processes personal data on behalf of the Data Controller;
1.10. “Device” or “Devices” – This refers to any computer hardware, network, storage, input/output or electronic control devices, or software installed on such devices by means of which the User accesses the Agency’s website or communicates with the Agency or its Partners;
1.11. “GDPR” – This refers to the General Data Processing Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC;
1.12. “Minor” – This refers to any natural person under eighteen (18) years of age;
1.13. “Personal Information” – This refers to any and all information relating to the personal identity of a natural or legal person including, but not limited to, name, surname, nationality, sex, age, date of birth, ID or passport number, phone number, email, address and location;
1.14. “User” – This refers to any person who may access our website https://www.myschoolup.com/, whether that person be a Customer/Client or otherwise.

2.Our Purpose

2.1. At My School UP, our aim is to assist people who are seeking to achieve their personal, academic, or professional goals, find the most adequate language programmes, accommodation, cultural and/or professional trips and other ancillary services or activities, as described in our Terms and Conditions.

3. User Data Consent

3.1. The Agency may collect, use, consult, process, and/or transmit the data and information that the User and/or Customer/Client may provide the Agency with through different means including, but not limited to, this website, e-mail, telephone communication, social medias, post, videos or any other form of communication;
3.2. By providing any kind of information, the User acknowledges and explicitly consents to the Agency collecting, using, consulting, processing or transmitting Data in order to fulfil the specific requirements needed prior to entering in a contractual relationship with the providers of language programmes, accommodation, cultural and/or professional trips and other ancillary services or activities.

4. Data Collection

4.1. The User recognises that s/he directly provides the Agency with most of the data collected by the Agency. Data is collected when the User:
4.1.1. Registers online or makes a booking directly on our website;
4.1.2. Completes any form/s on our website;
4.1.3. Contact us through social media channels
4.1.4. Voluntarily completes a customer survey or provides feedback on any of our message boards, surveys or via email;
4.1.5. Uses or views our website via the User’s browser’s cookies.
4.2. In the event that the User provides the Agency with any Data pertaining to minors, the User guarantees that such Data is provided with the consent of the minor’s parents or those persons having legal custody of the minor;
4.3. The Agency automatically collects certain information when you visit, use or navigate the Website. This information does not reveal your specific identity such as name or contact information, but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when the User uses the Agency’s website and other technical information. This information is primarily needed to maintain the security and operation of the Agency’s website, and for our internal analytics and reporting purposes.  
4.3.1. We also collect information through cookies and similar technologies.

5. Data Classification
In order to provide its Services, the Agency may gather different kinds of data, including but not limited to the following categories:

5.1. Personal Data: This may include but it is not limited to name, surname, nationality, sex, age, date of birth, ID or passport number, phone number, email, address and location;
5.2. Booking Data: This may include but it is not limited to dates of stay, duration, programme, destination, expectations, accommodation preferences, source of contact (website, social media, network, and so on), feedback and client´s review on different platforms, including social media, emails, website and Google business, amongst others;
5.3. Correspondence Data: This may include but it is not limited to date and time of contact, means of contact (website, submission of form and telephone calls, amongst others), date of phone appointment, duration of the appointment, and summary of the appointment;
5.4. Documentation: This may include but it is not limited to ID card, passport, visa, resident permit, flight confirmation, consent form in the case of a minor, IBAN and bank details in case of refund, proof of payment of goods or services, completed and signed application forms when requested by a service provider, and work placement agreement when requested;
5.5. Cookies.

6. Treatment of Data

6.1. The Agency shall collect, use, consult, process and/or transmit Data in order to deliver the following Services which include but are not limited to:
6.1.1. To facilitate account creation and logon process.
6.1.2. Finding a suitable language school or third-party provider according to the client´s profile in terms of age, sanitary equipment, expectations and requests, amongst other requirements;
6.1.3. Finding the right accommodation while making sure the client´s requirements are respected in terms of expectations, safety, health requirements, medical information, diet, cultural and religious requirements, amongst others;
6.1.4.Facilitate logistic for particular trips;
6.1.5. Maintain contact with the clients;
6.1.6. Improve and develop the management of the Agency’s customer relationship, our marketing communication activities, our service offering, our partner network, and the user experience of the Agency’s website;
6.1.7. Establish statistics and reports for internal use;
6.1.8. Provide the client with news about the Agency, its Services and the Website;
6.1.9. Request feedback from Clients;
6.1.10. To post testimonials on the Agency’s Services that may contain personal information.
6.2. The Agency shall store Data for as long as it is required for the respective processing purposes for instance for booking purposes and advertising purposes;
6.3. The Agency may share data with third party service providers, partners or agents and who shall require access to such information to carry out the Services contracted by the Client;
6.3.1. The Agency may only provide Data to third party service providers for the purpose of carrying out the Services as outlined in the Agreements. In each case, the Agency shall ensure that access to Data is strictly limited to those individuals and/or companies who need to know and/or have access to the relevant Data, as strictly necessary for the purposes of the Agreement and in accordance with applicable laws in the context of that individual's and/or company’s duties to the Agency;
6.3.2. Unless otherwise described in this Agreement, the Agency does not share, sell, rent or trade any of your information with third parties for their promotional purposes;
6.3.3. The Agency has Data Protection Agreements in place with the Agency’s data processors, which are designed to help safeguard the User’s personal information. The data processors are not authorised to do anything with your personal information unless the Agency has instructed them to do so. The data processors shall not share the User’s personal information with any organisation apart from us. The data processors shall commit to protect the Data they hold on behalf of the Agency and to retain it for the period instructed by the said Agency.
6.3.4. When a User is redirected to this website through content embedded on a Partner’s website, then any personal data collected upon redirection to this website shall be collected in accordance with the provisions of this Privacy Policy.

7. Google Analytics

7.1. This website uses Google Analytics, a web analysis service of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA (“Google”). Web analysis is the gathering, collection and analysis of data about the behavior of visitors to websites. Among other things, a web analysis service collects data regarding the website from which a data subject has been redirected to a particular website (so-called referrers), which subpages of the website were accessed or how often and for which period of time a subpage was viewed. A web analysis is mainly used to optimize a website and for the cost-benefit analysis of Internet advertising;
7.2. Google Analytics uses “cookies”, text files, which are stored on the User’s computer and enable analysis of the User’s use of the website. The information generated by the cookie about the User’s use of this website is usually transmitted to a Google server in the USA and stored there. Google might transfer the personal information collected via this technical procedure to third parties;
7.3. Google Analytics further uses the Google AMP Client ID API to link user activities to AMP pages with those on non-AMP pages via Google Analytics. The Google tracking codes of this website use the “_anonymizeIp()” function. As IP anonymization is activated on our website, the User’s IP address will be shortened by Google within Member States of the European Union or other states in agreement with the European Economic Area. The complete IP address is only transmitted to a server from Google in the USA, in exceptional cases and abbreviated there. On behalf of the operator of this website, Google will use this information to evaluate the User’s use of the website, compile reports on website activity and to provide further services related to website and internet use to this website’s operator. The IP address transferred through your browser to Google Analytics will not be combined with other data held by Google;
7.4. In addition, this website uses the Analytics feature UserID to track interaction data. This User ID will be additionally anonymized and encrypted and will not be linked with other data;
7.5. The User can prevent the storage of cookies on the User’s computer via a corresponding setting of the User’s browser software. However, we point out that the User might not be able to use all functions of this website to their full extent in this case;
7.5.1. The User may further prevent the collection of the data generated by the cookie and related to the User’s use of the website (including the User’s IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
This browser add-on informs Google Analytics via JavaScript that no data and information about website visits may be transmitted to Google Analytics;
7.5.2. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.
7.6. This website also uses Google Analytics’ performance reports relating to demographics and interests and reports on Google Display Network impressions. You can disable Google Analytics for display advertising and customize the ads on the Google Display Network by visiting the ad settings at this link: https://adssettings.google.com.
7.7. Further information and Google‘s applicable privacy regulations can be found at https://policies.google.com/privacy?hl=en and https://marketingplatform.google.com/about/.
The following link provides a further explanation of Google Analytics https://marketingplatform.google.com/about/.

8. User Rights

8.1. The entity responsible for processing data is the partnership UP Conseils operating from Pepprina, Claire E Engel, San Giljan, Malta;  By providing any kind of information, the User and/or the Customer/Client acknowledges that the Agency is acting in good faith in order to collect, use, consult, process or transmit any Data provided by them, in order to fulfil the purposes described in this Agreement;
8.2. Pursuant to the Data Protection regulations, namely the GDPR and the Data Protection Act, Chapter 586 of the Laws of Malta, you have a right to free information about your stored data and, where applicable, a right to rectification, deletion, limitation of processing and objection to your stored data;
8.3. In order to exercise its User Rights, the User or Customer/Client agrees to notify the Agency as soon as possible in the event of improper use, violation, or breach of its Data, with the intention to protect, restate, or remedy the proposed situation, prior to seeking any judicial remedy. This shall be done by lodging a request with the Data Protection Officer appointed by the Agency;
8.3.1. Any such request may be lodged by sending an email to contact@myschoolup.com;
8.3.2. The User or Customer/Client may also lodge a complaint with the Maltese Data Protection Agency, that is the Information and Data Protection Commissioner (IDPC) by sending an email to idcp.info@idpc.org.mt.

9. Safeguarding and Risks of data

9.1. The Agency has established appropriate and up-to-date technical controls and measures in order to collect, use, consult, process and/or transmit the User’s Data, in order to ensure that such Data is safe from unauthorised access, misuse, breach of confidentiality, or loss.

10. Third Party Websites

10.1. The website may contain advertisements from third parties that are not affiliated with the Agency and which may link to other websites, online services or mobile applications. The Agency cannot guarantee the safety and privacy of data provided by the User to any third party. Any data collected by third party is not covered by this privacy policy. The Agency is not responsible for the content or privacy and security practices and policies of any third party, including other websites, services or applications that may be linked to or from the website. The User shall review the policies of such third parties and contact them directly to respond to their queries.

11. Amendments to Privacy Policy

11.1. The Agency keeps its Privacy Policy under regular review and places any updates on this website. This privacy policy was last updated on 11th November 2020.
12. Governing Law

12.1. This Agreement shall be governed by and construed in accordance with the laws of Malta. Any dispute arising out of this Agreement or in connection with the interpretation and fulfilment of this Agreement shall be submitted to the exclusive jurisdiction of the courts of Malta.