OQUDA
OQUDA
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Privacy Policy
Effective: 29/04/2021
GENERAL
Your privacy is important to us and we are committed to responsibly handling your personal data taking all reasonable steps to protect your information from misuse and to keep it secure in compliance with the Personal Data Protection Act 2012, the EU General Data Protection Regulation (EU) 2016/679 (“GDPR”) and all other applicable data protection and privacy legislation in force from time to time in USA (“Privacy Laws”). We believe it is important to inform you about how we will use your personal data. You can find information about how, whether, and why we collect and use your personal information on our Website. Where we use the term “OQUDA.COM” in this Privacy Policy, we mean the “OQUDA.COM” domain (including any mobile sites), OQUDA.COM computing platform and any applications, and all other websites, mobile applications, software, components, products and services.
1. Consent
  • Your consent to this Privacy Policy is the legal basis upon which we can collect, use, disclose and retain your personal data.
  • You acknowledge and agree that:
  • by clicking on the “I Agree” field (or any similar field or link designated to indicate your acceptance of this Privacy Policy), you are consenting to providing us with your personal data; and
  • you have had a sufficient opportunity to access and review this Privacy Policy and you have read and consented to its terms.
  • If you do not wish to provide personal data to us, then you are not obliged to do so. However, please be aware that this will affect your use OQUDA.COM.
  • OQUDA reserves the right to review, amend, update or change this Privacy Policy from time to time to reflect its practices and obligations. Any changes will take effect when they are made or posted on our website and you are electronically notified of the same.
2. Who We Are
  • OQUDA.COM is a multi-sided discovery and booking platform for the international student recruitment market.
  • Our business is based in USA and we have satellite offices worldwide.
  • OQUDA inc. , 919 North Market Street, Suite 950, Wilmington, Delaware,19801 is responsible for using your personal data, together with other related OQUDA Education companies. OQUDA and the other related OQUDA company will be referred to hereafter as ‘OQUDA’ or ‘we’.
3. Scope
  • This Privacy Policy applies to all personal data that is collected and used by us when you use OQUDA.COM, including creating an OQUDA.COM account when you visit or use the websites, applications, or other services of OQUDA (“Services”), participate in events or contests of OQUDA or interact with us through social media or otherwise. For purposes of this Privacy Policy, ‘personal data’ means any information through which we can identify you, as further described and defined below in Personal Data We Collect. It does not include data where the identity has been removed.
  • This Privacy Policy sets out how we collect, store, use and disclose your Personal Data. You understand that through your use of the Services you consent to the collection and use (as outlined in the Privacy Policy) of this information, including the transfer of this information to the United States, and/or other countries for storage, processing and use by OQUDA and its affiliates.
  • If you do not agree to any of the provisions of this Privacy Policy, you should not use OQUDA.COM, our Services or provide OQUDA with any Personal Data.
  • By visiting OQUDA.COM and our Services, you agree to your information being collected, held, used and disclosed as set out in this Privacy Policy.
4. Personal Data We Collect
  • Where practicable, we will give you the option of interacting with us anonymously or using a pseudonym. We collect the Personal Data necessary for us to provide you with the Services you have requested from us, and to manage your use of OQUDA.COM. You do not have to provide us with your Personal Data, but if you do not do so, we may not be able to provide you with some or all of our Services.By disclosing Personal Data to OQUDA, you are consenting to its collection. If OQUDA receives unsolicited Personal Data about you, this Personal Data may be included in your use of the Services. OQUDA may destroy such data where it is not necessary for our legitimate interests, including to enable you to use and interact with our Services or to comply with our legal obligations.
  • From time to time, you may have the option to participate in surveys or other activities intended to improve the services of OQUDA, which may involve providing additional personal data. Your participation in such activities is subject to your consent.
  • The Personal Data that you are currently required to provide to use or subscribe to our Services includes (without limitation):
PERSONAL DATA
Identity and Contact Data
  • full name (including any previous name(s));
  • address(es) (including any previous address(es));
  • date of birth;
  • email address;
  • telephone number(s);
  • qualification information;
  • gender;
  • ethnicity;
  • citizenship/residency status;
  • English proficiency;
  • Language;
  • Country of birth; and
  • Preferences current and previous employment history; and
  • profession certifications and memberships.
Financial and Transactional Data
  • bank account details;
  • billing information;
  • credit or debit card details; and
  • payment history.
Special Categories of Personal Data, including sensitive data
  • information about your health, and genetic and biometric;
  • criminal record; and
  • religious or philosophical beliefs
Technical and Profile Data
  • device data;
  • internet protocol address;
  • browser type and version;
  • operating system and platform; and
  • username and passwords
Location Data
  • information about your actual location
Marketing and Communications Data
  • preferences in receiving marketing from us and other third party communications; and
  • feedback and survey responses.
5. How we collect your Personal Data
We will only collect personal information or Personal Data through lawful and fair means and not in any unreasonably intrusive way. Personal Data is collected in a number of ways, including:
  • where you expressly provide this information to us, including your use of OQUDA.COM and the Services;
  • from your interactions with us (including our personnel), including by telephone, text message, e-mail communications, social media, and in person;
  • from your voluntary participation in surveys, reviews or marketing promotions; and
  • from the electronic devices you may use to access OQUDA.COM, including information collected from your browser’s cookies.
Whenever possible, OQUDA will collect your Personal Data directly from you. However, in some situations, OQUDA will collect information that may include your Personal Data from a third party. These third parties include:
  • institutions, including secondary institutions, where you have studied or where OQUDA reasonably believes you may have studied;
  • Authorities that OQUDA reasonably believes may hold results pertinent to your application;
  • Government bodies, departments and agents;
  • Admission centres; and
  • third party verification services.
In addition, by providing the details of an authorized person to OQUDA (such as a Recruiter), you are consenting to the collection of your Personal Data from your authorized person.
6. How we use your Personal Data
We only use your Personal Data for the purpose for which it was provided to us, related purposes, purposes for which you consent, and as otherwise required or permitted by law. Such purposes include:
  • provision of information about any of OQUDA Services that may be relevant to you;
  • provision of information about institution services which may be relevant to you;
  • responding to your enquiries;
  • to identify you when you log into OQUDA.COM or otherwise contact OQUDA;
  • providing you with Services you have requested;
  • processing your OQUDA application to determine your eligibility for courses or visas;
  • advising you about subject prerequisites;
  • maintaining/administering your OQUDA application;
  • processing payments you have authorized; and
  • any other purposes identified at the time of collecting your information.
We will only use your sensitive information for the purposes for which it was initially collected, other directly related purposes or purposes to which you otherwise consent.
UNSOLICITED INFORMATION
Where we receive unsolicited information, we will determine, within a reasonable period of time, whether or not we would be permitted to collect that information. Where we are not permitted to collect the information, we will destroy that information or ensure it is de-identified as soon as practicable. Otherwise, we may retain the information in accordance with the terms of this Privacy Policy. THIRD PARTY DISCLOSURE
  • Where appropriate, we may disclose your Personal Data to third parties as required to process your OQUDA application or to provide you with other services.
  • In addition, by providing the details of an authorized person to OQUDA, you are consenting to the disclosure of your Personal Data to your authorized person.
  • Your personal data may be disclosed to third parties including:
  • institutions that participate in OQUDA.COM;
  • institutions, including secondary institutions, where you have studied or where OQUDA reasonably believes you may have studied;
  • mail centres and other similar service providers; and
  • Government bodies, departments, agents.
  • Third parties may only use Personal Data disclosed by OQUDA to the extent necessary to achieve authorized and lawful purposes. The authorized and lawful purposes for which Personal disclosed by OQUDA may be used are:
  • any purpose for which the third party has secured the prior consent of the individual to whom the Personal Data relates;
  • processing applications for admission to courses;
  • carrying out checks to determine eligibility for courses for which the individual has applied
  • allocating tertiary places to eligible applicants;
  • communicating with prospective students;
  • carrying out research or performing analysis that does not involve the identification of specific individuals;
  • dealing with a specific tertiary application enquiry made by the individual to whom the personal data relates or made by an authorized representative of that person; and
  • any other purpose for which prior written authorisation is obtained from OQUDA.
  • As required by law, the third parties we communicate your personal information and Personal Data to are to provide GDPR compliant services. However, to the maximum extent provided by the relevant laws, OQUDA are not responsible or liable for the protection and privacy of any information which is provided to the third parties.
  • The third party must take reasonable steps, to the satisfaction of OQUDA, to ensure that Personal Data disclosed by OQUDA is protected against misuse, interference, loss and unauthorized access, modification and disclosure. The third party must ensure that each of its employees who access, use or disclose Personal Data are aware of and comply with the obligations under the Privacy Policy when they are accessing, using or disclosing the Personal Data. If the third party becomes aware of any misuse, interference, loss, or unauthorized access, modification or disclosure of Personal Data disclosed by OQUDA, the third party must immediately notify OQUDA.
  • We will only disclose your sensitive information for the purposes for which it was initially collected, other directly related purposes, purposes to which you consent, and as otherwise permitted or required by law.
PROHIBITION ON US OQUDA will not use or disclose Personal for any reason without your consent, except where required by the Privacy Laws and/or the GDPR, including when disclosure may be required by law or is necessary to protect the rights or property of OQUDA, or any member of the public, or to lessen a serious threat to a person’s health or safety.
7. Purposes of processing your Personal Data
How do we process your personal information or Personal Data? Processing your Personal Data is lawfully undertaken by us:
  • in obtaining your consent;
  • by necessity for the performance of a contract to which you are a party or in taking steps for your entry into that contract;
  • to comply with our legal obligations; and
  • by necessity for our legitimate interests and the legitimate interests of third parties, except where such interests are overridden by your interests or your fundamental rights and freedoms requiring the protection of your Personal Data.
OQUDA is allowed to process Personal Data for this purpose to pursue its own legitimate interests or those of the educational institutions; with the legitimate interests being OQUDA to be able to communicate with you for providing the best service it can to align you with the educational institutions of your choice.
8. Storage and Security
HOW DO WE STORE YOUR PERSONAL INFORMATION OR PERSON DATA?
  • OQUDA takes all reasonable and lawful steps to keep secure Personal Data recorded and to keep this information accurate and up to date.
  • Personal Data is stored on secure servers if in digital format, or in locked areas if in hardcopy format. These repositories are protected in controlled facilities. In some cases, these facilities may be located off shore and/or in cloud based servers that have represented to us that they are GDPR compliant.
  • OQUDA employees and data processors are obliged to respect the confidentiality of any personal and/or sensitive information or data.
  • OQUDA only permits authorised personnel to access your information and information will only be disclosed to third parties where they have the appropriate authority and are GDPR compliant.
  • For any payments you make via our websites, over the telephone or face to face, we use a recognized payment service provider that is required to take reasonable steps to protect your information. We also take reasonable precautions to ensure that any information you provide to us through our websites is transferred securely.
  • We will take reasonable steps to protect your personally identifiable information as you transmit your information from your electronic device to us and to protect such information from loss, misuse, and unauthorised access, use, modification, disclosure, alteration, or destruction. However, you should keep in mind that the transmission of information over the Internet is never completely secure or error-free. To the maximum extent provided by the relevant laws, OQUDA are not responsible or liable for your online transmission of Personal Data to OQUDA.
9. Cookies Statement
A cookie is a small data file that is placed on your computer or mobile device when you visit a website. Website owners widely use cookies in order to make their websites work, or to work more efficiently, as well as to provide reporting information. We and our third party providers use cookies to:
  • Personalise your visit to our website (as a cookie allows a web server to ‘remember’ visitors on subsequent visits without having to prompt them for information previously supplied. A cookie can also remember courses previously viewed by a site visitor)
  • Provide information about OQUDA to you while you browse
  • Obtain non-identifying information about your demographic group and general interests.
10. Important notice in relation to fraudulent documentation
  • OQUDA may and disclose your Personal Data without following the provisions in this Privacy Policy where OQUDA has reason to suspect that you have engaged in serious misconduct in relation to OQUDA’ functions, if the use or disclosure of the Personal Data is necessary in order for OQUDA to take appropriate action in relation to the misconduct.
  • OQUDA considers the provision of fraudulent documentation to be serious misconduct in relation to OQUDA’ functions. Therefore, if OQUDA has reason to suspect that you have presented fraudulent documentation of any kind, OQUDA may use or disclose your Personal Data in a manner inconsistent with this Privacy Policy to the extent required to undertake an investigation into that documentation and to take appropriate action in light of the outcome of the investigation.
11. Age Limitations
  • Our online Services are not directed to children under 13 years of age. If you believe we have collected information about a child under the age of 13, please contact our hello@oquda.com so that we may take appropriate steps to delete such information.
  • If you are at least 13 but under 16 years of age, please get the consent of your parent or legal guardian before you give us any Personal Data about yourself. Your parent or guardian should contact OQUDA and provide us with their name, email address and any other identifying information that we may request. OQUDA needs this information in order to verify that they have provided the necessary consent. We may follow up by phone or other means in some circumstances. If you are at least 13 but under 16 years of age, do not contact us or provide us with any Personal Data until after your parent or guardian has sent us an email consenting to your contact and provision of such information.
12. Data Retention
  • OQUDA retains your Personal Data for as long as reasonably required to satisfy the purpose for which they were collected and used (for example, for the time necessary for us to complete your application, send you the newsletters you subscribed to, to provide you with customer service, answer queries or resolve technical problems, etc.), unless a longer period is necessary for our legal obligations or to defend a legal claim.
  • If you have created an OQUDA.COM subscription or account, we will delete that account and your Personal Data upon your request or 30 days after it has become inactive. We will consider your subscription ‘inactive’ when you haven’t used your OQUDA account for a period of 2 years. Before your account becomes inactive, we will notify you to use your OQUDA account to prevent your account from being inactive. When we cancel your account, your Personal Data will be deleted. If we need to store certain types of your Personal Data for a longer period due to legal requirements, we will store such data in accordance with the mandatory periods.
13. Your Data Protection Rights
You have the right to:
  • Access. You have the right to request we provide you with a copy of Personal Data. We may charge you a small fee for this service. You may access your Personal Data by requesting access from OQUDA by completing a Privacy Enquiry/Complaint Form. A service fee may be charged for retrieving and sending the information to you.
  • Rectification. You have the right to request we correct, amend or update any information you believe is inaccurate or incomplete. You may request your information or data be corrected, amended or updated by:
  • telephone: +1 (774) 608-1505
  • email: hello@oquda.com
  • in person: By appointment, 919 North Market Street , Suite 950, Wilmington, Delaware, USA 19801
  • written correspondence: Attn: Privacy Officer, 919 North Market Street , Suite 950, Wilmington, Delaware, USA 19801
  • Erasure. You have the right to request that we erase or destroy your data in certain circumstances, including where you withdraw your consent, where your data is no longer required for collection purposes or where your data has been unlawfully processed;
  • Restrict Processing. You have the right to request that we restrict the processing of your data under certain conditions, including where processing is inconsistent with the reason for which the data was collected.
  • Object to Processing. You have the right to object to us processing your Personal Data under certain circumstances, including the right to object to profiling, automation and direct marketing.
  • Data Portability. You have the right to request we transfer the data we have collected to another organization or directly to you, under certain circumstances.
  • To the extent that we are relying on our legitimate interests to use your personal data, you also have the right to object to such use (unless we can either demonstrate compelling legitimate grounds for the use that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims).
  • Without undue delay and not later than within a month, we will respond to your request to invoke your rights consistent with applicable law.
  • You may revoke your consent for receiving marketing communications at any time, free of charge by following the instructions in any marketing communication. You can also control these preferences in your profile settings. OQUDA will then stop applying the research results to you at an individual level and will stop sending you marketing communications.
  • In case you may have a question or complaint about how we process your Personal Data, you can send an email to hello@oquda.com. Alternatively, you may consider lodging a complaint with a supervisory data protection authority.
14. Complaint
  • Formal complaints about a breach of this Privacy Policy must be made in writing. OQUDA reserves the right to request any supporting evidence and/or information to substantiate the complaint/breach.
  • We will refer your complaint to the responsible officer at OQUDA, who will investigate the issue and determine the steps we will undertake to resolve your complaint. We will contact you if we require any additional information from you and will notify you in writing of the determination in relation to your complaint.
  • If you are not satisfied with our determination, you can contact us to discuss your concerns or make a complaint to the USA Personal Data Protection Commission.
15. Other Websites
The Website may contain links to other websites (“Third Party Links”) that we provide solely as a convenience to you during your use of the Website. OQUDA does not endorse such websites and is not responsible for any content contained therein. If you decide to access any Third Party Links, you do so entirely at your own risk.
16. Depersonalised or aggregate data
From time to time OQUDA provides aggregate, non-personal data to third parties for research and marketing purposes. It is a condition of accessing this information that no data-matching or data-merging is conducted which has the effect, or may have the effect, of extracting personal data from the aggregate data. Any Personal Data discoverable in aggregate data is subject to this Privacy Policy and must only be used for the authorized purposes outlined above.
17. How to contact us
If you have any questions or concerns about these Terms of Use or its implementation, you may contact us by
  • telephone: +1 (774) 608-1505
  • email: hello@oquda.com
  • written correspondence: Attn: Privacy Officer, OQUDA inc. , 919 North Market Street, Suite 950, Wilmington, Delaware,19801.