PRIVACY POLICY

This Privacy Policy applies to services (“Services”) offered through the website located at www.srtfairs.com and www.edu.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”).

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.

This Privacy Policy explains how SRT may collect, use, process, disclose and safeguard Personal Data related to you through the Services we provide, and in connection with our partner relationships. It also explains you about your rights and choices with respect to your Personal Data, and how you can contact us if you have any questions or concerns.

What personal data does SRT collect?

We collect a variety of data on an institutional and individual level to provide you with services and information. We collect student data through event registration (e.g., university fairs and recruitment tours) and online forms to connect high school students with universities.

The personal information we collect from you is the following:

  • personal data including your name, date of birth and gender;
  • contact data including your home address, citizenship, email address and phone number;
  • profile data including your specific requests, preferences, feedback, survey responses and usernames on social media channels;
  • usage data including your IP address, browser and technology, how you use our website, social media and services;
  • academic history including your high school, your academic records, your activities and achievements in and outside of school, contact information of people recommending you, etc.;
  • marketing data including your preferences in receiving marketing messages and materials from us;
  • photographs or images of you captured during еvents for marketing and promotional purposes.

Apart from the abovementioned we collect the following personal data from the students taking part in online events organized by us:

  • Account name (login);
  • Email address;
  • Comments, feedback, questions, contributions during the online event.

Any student participating in an online event organized by SRT is informed and expressly agrees to this personal data being shared with the following recipients:

  • The company which organizes the online event in its capacity as Data Controller and/or Data Processor;
  • SRT partner universities taking part in the online event/webinar.

How do we collect personal data?

We collect information about you when you:

  • request information to be sent to you;
  • attend or register for an event, an educational fair or high school visit;
  • submit your test scores to us as part of the application process;
  • interact with any SRT page or account on a social media platform, or when you use your social media account or credentials to log in to the Website.

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 does SRT use and share your information?

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.

Students

We collect student data through event registration (e.g., university fairs and recruitment tours) and online forms to connect high school students with universities. If you have opted-in to be included in our list, SRT partner universities taking part in the event/webinar you register for will have access to your personal data, and may contact you regarding global study options. These communications may be sent electronically by email.

Events

We may use an event app or share materials to promote networking at our events. If you are registered to attend an event, your name, email and school will be shared with other participants attending the event.

Communications

We send regular communications to inform you of services available as part of your membership, and to conduct SRT association business as noted in the membership agreement. You can manage your email preferences to opt in and out of specific communications according to your interests. This option can be found at the end of each communication under Manage your preferences.

Marketing & Promotion

By registering for the high school fair, you explicitly acknowledge, consent and grant SRT Fairs the irrevocable right to utilize any photographs or images of you captured during the Event for marketing and promotional purposes. This includes, but is not limited to, the use of such photographs in print materials, online advertisements, social media platforms, website content, or other appropriate marketing channels. We may retain the right to crop, resize, edit, or otherwise modify the photographs as necessary, ensuring their optimal presentation in marketing and promotional materials.

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 educational institutions as necessary to facilitate study abroad; partner institutions, as well as other parties as necessary to organize and administer study abroad programs.

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 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.

We may process your personal data because it is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract. In this respect, we use your personal data for the following:

  • to interact with you before you are enrolled as a student, as part of the admissions process;
  • once you have enrolled, to provide you with the Services;
  • to deal with any concerns or feedback you may have;
  • for any other purpose for which you provide us with your personal data.

Apart from the abovementioned grounds, most commonly personal data will be processed in the following circumstances:

  • we have your specific or, where necessary, explicit consent to do so;
  • In order to fulfill SRT’s obligations to you as part of a contract;
  • Where it is necessary for SRT’s legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
  • To protect the vital interests of the data subject or of another person;
  • In order to perform a task carried out in the public interest.
  • to promote our services;
  • to seek advice on our rights and obligations.

We may also process your personal data in relation to compliance with our legal obligations. In this respect, we may use your personal data for the following:

  • financial audits;
  • compliance with our regulatory and legal obligations;
  • compliance with anti-money laundering laws and safeguarding requirements;
  • prevention and detection of crime;
  • criminal investigations – assist with investigations (including criminal investigations) carried out by the police and other competent authorities.

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.

Cookies policy

The SRT’s website uses cookies in order to learn more about the way you interact with our content and to help us to improve your experience when visiting our website. Cookies remember the type of browser you use and which additional browser software you have installed. They also remember your preferences, such as language and region, which become your default settings when you revisit the website. Some of the cookies we use are session cookies which last only until you close your browser; others are persistent cookies which are stored on your computer.

We will not use cookies to collect personally identifiable information about you. However, you can choose to reject or block the cookies set by SRT or the websites of any of our third-party suppliers by changing your browser settings. Note that most browsers automatically accept cookies, so if you do not wish cookies to be used, you may need to actively delete or block the cookies.

Some of the functions within our website link to third-party suppliers, for example, when you visit a page with videos embedded from or links to YouTube. These videos or links (and any other content from third party suppliers) may contain third party cookies. You can consult the policies of these third-party websites for information regarding their use of cookies.

To review SRT’s website cookies policy, please check the following https://edu.srtfairs.com

Cookies we use

Service Cookie Name Description
Google Analytics _utma, _utmb, _utmc, _utmz These cookies are used to collect information about how visitors use our website, which we use to help improve it. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Find out more about Google Analytics privacy
You can opt-out from being tracked by Google Analytics by clicking here
CloudFlare _cfduid The __cfduid cookie is used to override any security restrictions based on the IP address the visitor is coming from. For example, if the visitor is in a coffee shop where there are a bunch of infected machines, but the visitor’s machine is known trusted, then the cookie can override the security setting. It does not correspond to any user id in the web application, nor does the cookie store any personally identifiable information.
SRT Session www.srt This cookie only exists while your browser is open, it will be removed automatically at the end of your session. Without this cookie you cannot start, nor finish the online booking process.
Cookie Consent cc_cookie_accept, cc_cookie_decline These cookies are used to remember your choice of allowing or disallowing us to place cookies on your device.

How does SRT store and secure 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.

You 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

School Visits

When we are onsite for a school visit, we respect and adhere to local school policies including those related to data protection, including the distribution, use and storage of data, the rights of the individual, safeguarding and child protection, as well as statutory governmental policies and practices.

Links to other web sites

This Privacy Policy does not cover the links within this site linking to other websites. Those sites are not governed by this Privacy Policy, and if you have questions about how a site uses your information, you’ll need to check that site’s privacy statement.

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.

DECLARATION OF ACCEPTANCE

I hereby declare:

I agree that SRT is collecting, administrating and processing my personal data as follows: full name, email address, and any other personal details, which I willingly provided, as far as this details are necessary for processing my request and providing the requested services. SRT collects personal information only as long as it is absolutely necessary for the flowless performing the requested services in the most professional manner. SRT implemented new procedures and updated its Privacy policy in order to keep up with the highest standards of the most recent national and EU data protection legislation.

I am informed and I agree that:

1.1. my personal data might be provided to third parties – online events hosting platforms, administrative institutions and jurisdictional authorities, empowered by low to require and collect such personal information.

1.2. the personal data I provided might be processed and stored by the company for a maximum period of five years after your association with us has come to an end time, unless I send an email to info@srtfairs.com and declare my wish all personal data to be deleted from the company data base.

1.3. my personal data will be transferred to other countries – EU and NON EU Members , as long as this concerns the services I requested and the company has the assurance that the transferred data will be handled and administrated in accordance with the General Data Privacy Regulation.

I am informed and I agree that any email correspondence between me and the company related to the requested services is considered information freely accessible by the company and its employees and the company can process, transfer to third parties (suppliers, partners) and store this information for an unlimited period of time.

I am informed by the SRT about my rights:

2.1. I have the right to access to my personal data, processed by the SRT. I need to send a written request to : info@srtfairs.com, in order this access to be granted.

2.2. I am entitled to send a request for deleting, correcting and blocking of my personal data, if its processing does not comply with the applicable data protection legislation.

2.3. I have the right to demand that the SRT informs third parties about the deletion, correction and ban of my personal data, that has been disclosed, unless it is impossible for SRT or it requires extraordinary efforts.

2.4. I have the right to be informed, that my personal data is being disclosed to third parties for marketing purposes and I can disagree at any time.

2.5. I have the right to disagree against the processing of my personal data for marketing purposes at any time and absolutely free of charge.

2.6. I have the right to disagree against the processing of my personal data at any time, if I consider our actions non -compliant to the data privacy legislation.

2.7. If there is a security issue, despite our strict internal security measures and procedures, I have the right to be informed within 72 hours.

2.8. If I am an individual at the age of 16 or less, my personal data will be provided only with the acceptance of my parent/legal guardian.

Amended 1 July 2021