PRIVACY POLICY SRT Scan App

PRIVACY POLICY FOR SRT SCAN APP USERS

Last Updated: 20.10.2022

This Privacy Policy applies to services (“Services”) offered through the website located at www.srtfairs.com (“Website”), controlled by SRT International Ltd., a limited liability company incorporated under Bulgarian law, registered with the Bulgarian Commercial Register under No. 201439810, with headquarters and registered address in the city of Sofia, Bulgaria (referred to as “SRT”, “the Company”, “we” or “us”). By using our website, located at http://www. srtfairs.com (“Website”), our mobile app SRT Scan App (“Application”), and/or other services we provide (collectively, “SRT”), you agree to the practices set forth in this Privacy Policy.

This Privacy Policy is intended as well to govern the collection, use of and access to your data within the framework of use of the services of webinar hosting platforms, particularly during the organisation, management and participation in online events organized by SRT.

This Privacy Policy is intended to comply with the European Union’s (“EU”) General Data Protection Regulation (“GDPR”), and applies to personal data that SRT collects or processes about an individual (“Data Subject”, “you”) while the Data Subject is located in the EU, regardless of whether the Data Subject is a citizen or permanent resident of an EU country. “Personal Data” means any information relating to an identified or identifiable Data Subject.

The SRT Scan App is an application, which has been developed for the purposes of SRT by a third party – Grind Web Studio Ltd., 280 Tsar Simeon str., Sofia, Bulgaria, UIC BG202662951 (https://grindwebstudio.com), which is in charge of the maintenance of the application.

What personal data SRT collects

We collect student data when you sign up for an SRT Scan App user account and create a user profile.

The personal information we collect from you is the following:

Personal data including your name and date of birth;
Contact data including your email address and phone number;
Academic history and preferences including your year of graduation; school name; preferred schools; preferred countries of study preferred studies;
Usage data including your IP address, browser and technology, how you use our website, social media and services;
Mobile device ID. Your mobile device’s unique ID number (e.g., IMEI, AD ID) to analyze trends, administer the site, prevent fraud, track visitor movement in the aggregate, as well as to issue a unique QR code to each registered user.

How SRT collects personal data

SRT directly collects information when you sign up for an SRT Scan App user account and create a user profile.

Personal data may be provided to SRT by third parties as well (universities, high schools, other educational institutions, etc.). When we obtain personal data from third party sources, we will look to ensure that the third party has lawful authority to provide us with your personal data.

How SRT uses and shares your information

Once a student registers through SRT Scan App and provides his/her personal details, he/she receives a a QR code that contains his/her data. Universities scan the relevant QR code and gain access to the student’s data. Each university representative creates a personal profile in the application, through which he gets access to data from students they have met.

Therefore, pursuant to the terms of this Privacy Policy, we may use the information we collect from you for the following business purposes:

facilitate the exchange of data between universities and students during live education exhibitions;
perform remarketing by universities or establish subsequent written communication between students and universities;
to tailor and provide communications to you about SRT Scan App and related offers, promotions, advertising, news, upcoming events, and other information we think will be of interest to you;
monitor and analyze trends, usage and activities;
investigate and prevent fraud and other illegal activities;
6. where we otherwise have a legitimate interest in doing so, for example, direct marketing, research (including marketing research), network and information security, fraud prevention, and enforcing our terms, conditions and policies or defending against legal claims; and
7. for any purposes disclosed to you at the time we collect your information or pursuant to your consent.

SRT will not share your personal data with third parties except:

as necessary to meet one of its lawful purposes, including but not limited to, its legitimate interest, contract compliance, pursuant to consent provided by the Data Subject, or as required by law;
as necessary to protect SRT’s interests;
with other service providers acting on SRT’s behalf who have agreed to protect the confidentiality of the oersonal data.

The personal data that SRT collects may be shared with: high schools, universities and other educa

We will follow the terms of this privacy policy. Your personally identifiable information will not be disclosed without your permission unless we are legally entitled or required to do so, such as by a legal process or to prevent fraud or another crime or if we believe that such action is necessary to protect and/or defend our rights, property or personal safety and/or those of our users/members or other individuals. We do not sell information to third parties.

Lawful basis for processing your information

SRT needs your contact details in order provide some of the Services included on or otherwise made available to you through SRT Scan App, as well as through the Website (“Services”) (https://srtfairs.com/services). Where applicable, we indicate whether and why you must provide us with your personal data, as well as the consequences of failing to do so. If you do not provide personal data when requested, you may not be able to benefit from our Services if that information is necessary to provide you with the Services or if we are legally required to collect it.

Receiving and processing your personal data as a prospective student, as listed above, when you participate in school visits, educational fairs in Bulgaria and abroad, is based on your consent – Art. 6 (1) (a) of GDPR, and is exclusively used in the recruitment and application cycle.

Retention of your personal data

Retention periods vary depending on the category of data. Our policy is to keep data for as long as necessary to fulfill the originally intended purpose.

We take measures to delete your Personal Data or keep them in a form that does not permit identifying you when these Personal Data are no longer necessary for the purposes for which we process them, unless we are required by law to keep them for a longer period.

Subject to any other notices that we may provide to you, we may retain your personal data for a maximum period of five years after your association with us has come to an end.

How SRT stores and secures information

We have implemented technology and policies with the objective of protecting your data from unauthorized access and improper use and will update these measures as new technology becomes available. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.

We work with several data processors to deliver services to members. These processors include, but are not limited to, event registration, and payment processors. For each data processor, we carefully review and monitor the vendor’s privacy policy and data security measures to ensure they uphold our high standards. These data processors will not use your personal information for any purpose other than what we have agreed with them.

Your rights in relation to the personal data we hold

GDPR outlines six rights for individuals in relation to their data. If you would like to exercise one of these rights, the actions you can take are listed below.

We will respond to all requests within 30 days, however it may take longer to fulfill your request. If you are unsatisfied with how we handle your request you can contact your local data authority.

You have rights in respect of the way your personal data shall be managed, including the right to:

request an access to your personal data we hold;
rectify or erasure your personal data;
restrict or object to processing concerning your data;
request data transfer to other parties;
withdraw consent at any time, without affecting the lawfulness of processing based on consent before this withdrawal;
lodge a complaint with the supervisory authority – Commission for Personal Data Protection, address – 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592

You may address your concerns or inquiries to e-mail: info@srtfairs.com

Children’s privacy

Generally we do not knowingly collect, maintain, or use personal data from children under 16 years of age, and no part of the Service is directed to children under the age of 16.

Where it is necessary to collect, maintain, or use personal data from children under 16 years of age, for the legitimate purpose of providing Services to such a person, we do not proceed unless consent is given or authorized by the holder of parental responsibility over the child.

If you learn that your child has provided us with personal data without your consent, then you may alert us at info@srtfairs.com. If we learn that we have collected any personal pata from children under 16, then we will promptly take steps to delete such information and terminate the child’s account.

International data transfers

Data we collect will (occasionally) be transferred to selected third parties, which may be located outside of the European Union as part of the services offered to you. For example, some educational institutions we work with are located in countries outside of the EU.

In these circumstances, your personal data will only be transferred on one of the following bases:

where the transfer is subject to one or more of the “appropriate safeguards” for international transfers prescribed by applicable law (e.g. standard data protection clauses adopted by the European Commission);
a European Commission decision provides that the country or territory to which the transfer is made ensures an adequate level of protection; or
there exists another situation where the transfer is permitted under applicable law (e.g. where we have your explicit consent).

SRT is an organization that engages in activities worldwide. SRT staff, affiliates or contractors may access, store or process personal data you submit to us in countries that do not afford a level of data protection equivalent to the EU. By submitting personal data to us you irrevocably agree to the export of your data to such countries.

Other important information

Changes to Privacy Policy

From time to time we may make changes to this privacy policy. If we make any substantial changes to this privacy policy and the way in which we use your personal data, we will post the changes on this page and will do our best to notify you of any significant changes. Check our privacy policy on a regular basis.