Introduction
Welcome to Saveriades Educational Organisation data protection policies.
We respect your privacy and are committed to protecting your personal data. Thisprivacy notice will inform you as to how we look after your personal data when you visit our website or affiliate with our institutions either as staff, a student, a vendor, an agent or a guest. This information will tell you about your privacy rights and how the law protects you.
Purpose of this Privacy Notice
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when weare collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplementsthe other notices and is not intended to override them.
Data Controller
Saveriades Educational Organisation is the controller and responsible for your personal data (collectively referred to as the ‘Organisation’ in this privacy notice).
The Organisation is made up of different two entities, namely, Casa College and Kasa High School. This privacy notice is issued on behalf of the Saveriades Educational Organisation so when we mention “Organisation”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant entities in the Saveriades Educational Organisation responsible for processing your data.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO at DPO@casacollege.ac.cy.
Changes to the privacy notice
The data protection law in the EU changed on 25 May 2018. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications.Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name and last name.We may ask for further identity data but only
in situations where we believe this is essential to delivering the service in question. - Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you
- Technical Data includes internet protocol (IP) address, your login data, browser type
and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. - Profile Data includes your username and password, purchases your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website and services.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, register you for the new semester or graduation). In this case, we may have to cancel the service you have with us but we will notify you if this is the case
at the time.
How Is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your identity and contact data by filling in forms.
- This includes personal data you provide when you:
– subscribe to our College
– make a payment
– enter a competition, promotion or survey.
How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract, we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and
fundamental rights do not override those interests. - Where we need to comply with a legal or regulatory obligation.
- Generally, we do not rely on consent as a legal basis for processing your personal data.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
To register you as a new student/employee | (a )Identity (b) Contact |
(a) Performance of a contract with you |
Manage payments, fees and charges | (a) Identity (b) Contact (c) Financial (d) Transaction |
(a)Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy |
(a) Identity (b) Contact (c) Profile |
(a)Performance of a contract with you (b)Necessary to comply with a legal obligation |
To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage |
(a)Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our College) |
To administer and protect our College and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a college reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation |
Third-party
We will get your express opt-in consent before we share your personal data with any company or other person.
Opting out
You can ask us or third parties to stop sending you messages at any time. Where you opt out of receiving these messages, this will not apply to personal data provided to us.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
KEEPING YOUR DATA SECURE
We have put in place appropriate security measures to prevent your personal datafrom being accidentally lost, used or accessed in an unauthorized way. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
HOW LONG DO WE KEEP YOUR DATA?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 unauthorized 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.
In some circumstances you can ask us to delete your data.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- Requesting access to your personal data
- Requesting correction of your personal data
- Requesting erasure of your personal data
- Objecting to processing of your personal data
- Requesting restriction of processing your personal data
- Requesting transfer of your personal data
- Right to withdraw consent
If you wish to exercise any of the rights set out above, please contact our Data Protection Officer: DPO@casacollege.ac.cy. Please keep in mind that an individual can only access their own information but should they wish to authorise someone else to access their data they must complete the Consent to Release Information Form and send it via email to DPO@casacollege.ac.cy
Fees
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our
response.
LAWFUL BASIS
Legitimate Interest means the interest of our College in conducting and managing our college to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before
we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities
by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal
Kasa High School who offers you the chance to increase your education, determine your future,
and improve your life choices and opportunities. In addition, Kasa High School offers challenging and
interesting classes. You will be able to choose the classes that you take.
Your legal rights
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b)where our use of the data is unlawful but you do not want us to erase it; (c)
where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.