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PRIVACY POLICY

Data Controller

SEO (Sponsors for Educational Opportunity) London provides access to the SEO London services including its website, available via the URL https://www.seo-london.org/ (the “Website”), and to information, and other materials available on and through the Website. SEO London is the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used. We will not rent or sell our users’ details to any other organisation or individual.

Introduction

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals in the European Economic Area (EEA).

Given the nature of SEO London’s programmes, we do not expect to collect the personal data of anyone under 16 years old. If you are aware that any personal data of anyone under 16 years old has been shared via our website, please let us know so that we can delete that data.

This version of our privacy policy is primarily written for adults, including parents and guardians of child users. If you are a child (under 18 years old) you are welcome to read this policy. If there is anything you are unsure about in this Privacy Policy, you can contact our Data Team via data@seo-london.org

Scope

This policy applies to the gathering and processing of your personal data when you visit our website at https://www.seo-london.org/ and if you participate in SEO London or the SEO group of organisation’s programmes or services, including but not limited to SEO Schools, Careers, Alumni, Europe and Connect: The Diverse Talent Club.

Why we process Personal Data

Sponsors for Educational Opportunity London’s (“SEO London”) mission is to help talented and ambitious individuals from underrepresented backgrounds to realise their full potential. As this Privacy Policy explains, information you provide to us will be used to help us fulfil this mission. 

Our vision is a society where everyone, regardless of background, has equal opportunity to achieve long-term professional and personal success. Our Mission is to prepare talented students from underserved and underrepresented backgrounds for career success. More information surrounding our Theory of Change can be found by visiting https://www.seo-london.org/impact as part of this mission, we collect personal data, including special category information to determine your eligibility for our programmes and to ensure we can deliver a quality service to that end. We will process your personal and special category data as a means to this end where we have a legal basis. We will take all reasonable care to safeguard this information.

Who we are collecting from

What we collect

Students

We collect personal and special category data including your name, contact information, email, postal address and telephone number, bank information, emergency contacts, visa / asylum status, LinkedIn profile, date of birth, gender, educational details and any qualifications attained, social mobility and household income data), details relating to any work experience or job that you may have had or will have, personal interests and academic/career aspirations, ethnic origin, nationality and any disabilities or medical conditions you may have.

Suppliers and other related organisations

We collect information which may include your name, contact details and bank information.

Professional Network and Supporters

We collect information which may include your name, contact information, employment information and bank details. We may also collect special category data (as defined by applicable data protection laws) from you.

Sponsors and Donors

We collect information which may include your name, contact information, employment information and bank details.

Website users

Technical information, including your IP address, your login information, browser type and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times and download errors; information about your visit, including the websites you visit before and after our website and items you viewed or searched for; and length of visits to certain pages, page interaction information (such as scrolling, clicks and mouseovers) and methods used to browse away from the page.

What Personal Data we collect

 

 

 

 

 

 

 

 

 

 

 

 

Special Category

 

Certain personal data we collect is treated as a special category to which additional protections apply under data protection law:
 
Where we process such special category personal data, we will always ensure we are permitted to do so under data protection laws. As a not-for-profit organisation, we will process special category personal data to fulfil our charitable mission.

Our Lawful Basis to Processing Activities 

Certain personal data we collect is treated as a special category to which additional protections apply under data protection law:
 
Where we process such special category personal data, we will always ensure we are permitted to do so under data protection laws. As a not-for-profit organisation, we will process special category personal data to fulfil our charitable mission.

 

Our Lawful Basis to Processing Activities

We use different methods to collect data from and about you including through:

Direct interactions: You may give us your data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

•    create an account on our website;
•    subscribe to our service or publications;
•    request marketing to be sent to you; or
•    give us some feedback.

Automated technologies or interactions: As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.

Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources, including any of our sponsor firms, your universities, or more general publicly available sources on the web, such as LinkedIn.

Data protection laws require that, where we are processing your personal data, we must satisfy at least one prescribed condition for processing. These are set out in UK and EU data protection law, and we rely on several different conditions for the activities we carry out. In most cases, the personal data we process will be provided to us by you because you want to take services from us or engage with us and our use of your information will be governed by contract terms. Giving this information to us is therefore your choice and processing is necessary for performance of a contract and to comply with law.

Lawful Basis

Contractual Necessity

Legitimate Interests

Processing Activity

  • Eligibility and Fulfilment of Services. We will process personal data including special category personal data to fulfil our contractual obligations where this data is crucial  for this business need. Such as eligibility for candidacy, programmes, events, and internships as well as internal monitoring and reporting purposes.

  • Financial Data. We may collect bank account information in order to make reimbursements or to provide financial support in conjunction with SEO Programme curriculum.

For more information see the Terms and Conditions

  • Impact Analysis. We may process your data to assess the effectiveness of our services and impact on both an individual and societal level. No personal data will be processed that is not necessary and data available for this processing will be subject to our retention policy.

  • Marketing. We will use your personal data to send you updates about exclusive offers, promotions, and new products and services from the SEO London group of organisations or our affiliated and partner firms. You will be contacted via email, text message and telephone.

Consent

  • Marketing. To send you communications, for fundraising campaigns. If you agree to further digital advertising with partners your participation is given with your consent. You may be contacted via email, text message and/or telephone.

  • Market research – we may send you invitations to participate in market research, both internal and in conjunction with research partners. If you do so, your feedback is given with your consent. 

  • Technical data, which includes access data, information about your visit, including the full Uniform Resource Locators (URLs) clickstream to, through and from seo-london.org (including date and time), time on page, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), web usage information (e.g. IP address), your login information, browser type and version, time zone setting, operating system and platform; and cookies, or technology similar to cookies, You will be asked to consent to the use of nonessential cookies before using our website. 

For more information see our Cookies Policy

Legal Obligation

  • Fraud Investigation, detection and protection. Identifying and stopping fraud includes fraudulently accessing our services by embezzlement or unauthorised access.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Usage of imagery and videos

SEO London may collect images, video or content in any format, including digital and print during participation on any SEO London event, for the purpose of promoting the work SEO London do in helping underrepresented communities. Imagery is collected and processed under legitimate interests. For the purposes of determining retention timeframes, we treat imagery as personal data which will be used in accordance with this privacy notice.

If you notice material distributed with your likeness and would like all further processing and distribution to be stopped, please contact data@seo-london.org Imagery with your likeness may be printed and once dispersed may be beyond our ability to recall. Requests to stop distribution will not cover physical resources already distributed.

Marketing

We will use your personal data to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.
 
We have a contractual basis and legitimate interests to use your personal data for marketing purposes (see above). This means we do not always need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
 
You have the right to opt out of receiving certain marketing communications at any time by:


•    Using the ‘unsubscribe’ link at the bottom of marketing emails.
•    Contacting us at info@seo-london.org
 
We may ask you to confirm or update your marketing preferences if you ask us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell or share it with other organisations for financial gain outside the SEO London group of organisations.

 

Who we share with

For the purposes of the UK and European Data Protection Legislation and this Privacy Policy, the data controller is SEO London. Data sharing among the SEO group will occur freely.


Sponsors for Educational Opportunity also share your data with a number of other businesses which you may not normally interact with. This includes but is not limited to business partners, research bodies, corporate donors and sponsors, clients, suppliers and sub-contractors for the performance of any contract we enter, or work undertaken with them or you; and analytics and search engine providers that assist us in the improvement and optimisation of the Website. Different privacy policies may apply to those other businesses, and those policies discuss in more detail how your personal data might be processed. For more information, please contact data@seo-london.org.

We only allow those organisations to handle your personal data if we are satisfied, they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.
 

We or the third parties mentioned above occasionally also share personal data with:

  • our external auditors, e.g., in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations.

  • our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations.

  • law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations.

  • other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised, but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

Retention

If you have any questions about how your data is stored, please contact us directly with your questions at data@seo-london.org.

We will keep your information stored on our systems for as long as it takes to provide the services to you and to perform our legitimate interests. The third parties we engage to provide services on our behalf will keep your data stored on their systems for as long as is necessary to provide the services to you. We will not store your information for longer than is reasonably necessary or required by law.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

Security and Data Transfers
 

We follow strict security procedures as to how your personal information is stored and used, and who sees it, to help stop any unauthorised person getting hold of it. All personal information you register on this Website will be kept in digital format and located behind a firewall. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Temporary physical, ‘paper’ records may be used, but will be destroyed and disposed of securely after the purpose for processing has been completed. 

We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it. 

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

 

The data that we collect from you may be transferred to, and stored at, a destination outside of the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or one of our suppliers. Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where this is not available) legally approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR]. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
 
Where we transfer your personal data outside the EEA, we do so on the basis of an adequacy decision or (where this is not available) legally approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.

Do you need extra help

If you would like this policy in another format, for example audio, large print, braille or any other accessible format, please contact us at data@seo-london.org and we will accommodate as best we can.

Changes to this privacy policy

This policy was last updated on 12th February 2024. 

We may change this privacy policy from time to time—when we make significant changes, we will take steps to inform you, for example via a notice on the portal or website when you log in.

How to Complain

Questions, comments and requests should be addressed to


Address: Sponsors for Educational Opportunity London, 41 Great Guildford Street, London, SE1 0ES
Email address: data@seo-london.org (related to our privacy policy)
Email address: info@seo-london.o
rg (related to everything else)

 

Please contact us if you have any queries or concerns about our use of your personal data. We hope we will be able to resolve any issues you may have directly.

 

You also have the right to lodge a complaint with:

  •  the Information Commissioner [in the UK]

  • a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA

 

The UK’s Information Commissioner may be contacted using the details at ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

 

For a list of EEA data protection supervisory authorities and their contact details see here.

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