Our privacy policy tells you about the personal information we collect from you, how we use it, and what your rights are. If we make any major changes to this policy, we’ll add an alert on this website, our social media channels, or contact you. If you've got any questions about our privacy policy, or how we use personal information, email contact@brighterfuturesafrica.com or write to brighterfuturesafrica@gmail.com Terms Used in this policy BFA stands for ‘Brighter Futures Africa’ – we provide equal access to higher and further education by providing a platform that offers African students learning opportunities both locally and internationally. All personal information provided by you through this website is under the control of BFA and BFA Media, and we’re responsible for taking care of your personal information. This policy may refer to either organisation as ‘BFA’, ‘our’, ‘us’, or ‘we’, and our registered office is Plot 34271, Off-Shantumbu Road, Lusaka, Zambia. Collecting personal information When you visit our website, we may collect your personal information, so we can contact you about your request or enquiry. This could include: • Your name, contact details, and interests, if you register to receive a newsletter, updates about our services, or information from third parties • Your name and contact details, if you enter a competition. If you're one of the competition winners, we may publish your name on our website. If we need to collect more information from you, or share it with anyone, we’ll let you know when you enter the competition • Collecting your IP address when you visit our website, if you are the only person with access to your computer or device, and it can identify you. We may produce combined statistics about visitors to our website and website traffic patterns, answers to questions, content entered, and related website information. The information used for these purposes is aggregated (i.e. combined with other user data) and anonymised. It’s used to improve our website and will not be shared in a way which identifies you. • Sharing your personal information We may share your personal information with employees of BFA or BFA Media, or our suppliers who provide services to us, if this is necessary to progress or address your request/enquiry. Using your personal Information o We use this personal information to provide you with updates about event(s) you’re attending and ask your opinion about our services. o We also use this personal information to make sure any information and advice we send you is relevant and useful – such as open days likely to be of interest to you, based on the subjects you want to study, and where you live. We retain the personal information to produce research about such things as attendance at events, and their impact on access to higher education. Any statistical analysis reports we produce will not allow you to be identified. 'Special category' Personal information o We ask you to provide details of any special requirements you have, such as disabled access needs, or visual or hearing impairments, so appropriate support can be put in place at the event. o You don’t have to give us this information, but by doing so, we hope to make sure you have a better experience at the event, as the information will be shared with BFA Events employees and relevant employees at the venue (such as those with responsibility for security, and health and safety). o Using your image at an event o When you attend an event, you might decide to have your photo taken. If you do, it will be stored in Flickr and shared on our website to help promote our events. This means, anyone who visits our website will be able to see and download your photo for two weeks after your visit. You must, therefore, be sure you’re happy for your photo to be shared. If you want to have your photo removed, email contact@brighterfuturesafrica.com with: - the details of the event you attended (date and venue) - a copy of the picture you want to be removed - How we share your personal information Any personal information you choose to share could be accessed publicly, if you to share any content on this site, or on any of our social media sites (Facebook, Twitter, YouTube, Pinterest, Instagram, Vine, LinkedIn, or Google+). This includes disclosing personal information if you engage with BFA social media, such as posting comments on our BFA Facebook page, voting for your favourite blogger, sending us a private message, uploading a video, or tweeting us. We cannot be held responsible for any damaging actions or behaviours which may result, following your use of this, or any other related social media activity. Social media acceptable use When you engage with BFA on social media, such as our Facebook page or Twitter feed, comments you post are live as soon as you publish them. We do not check and approve them beforehand. We will remove inappropriate posts. • Cookies o We want to make sure we give you very clear information about the cookies we collect, how we use them, and how to disable them o We use cookies to provide users with the functionality contained in our website, and produce anonymous information to help analyse website traffic, usage, and behaviour. This helps us improve the visitor experience on our website, and ensure you receive relevant adverts when you use our website, and others. •Sharing your personal information We may share the personal information we collect about you with: o our service providers, who may need your personal information to progress your request or enquiry o course providers, if you’ve provided a reference in support of an application o Personal information- your rights o The GDPR provides you with rights in respect of your personal information. The right to object to ‘automated decision-making’, including profiling – you have a right under the GDPR to object to any decision that has legal effects on you made by solely automated means (e.g. no human intervention). BFA’ uses of personal information doesn’t include automated decision-making as defined in the GDPR. However, you can object to this occurring in the future. - The right to request deletion of your personal information – BFA retains personal information to support research into the higher education sector. However, you can request that we delete the personal information we hold about you. - The right to object to uses of personal information, in particular where the lawful basis for processing relies on processing in the public interest, or BFA’ legitimate interests. See the section ‘Lawful basis for processing’ (below) for more information. You also have the right to access the personal information we hold about you. Contact us to request a copy. The General Data Protection Regulation (GDPR) contains a variety of purposes for which personal information can be used, and our uses of personal information must meet one of these. They are listed at Article 6 of the GDPR. There are also additional requirements in respect of ‘special category’ personal information listed at Article 9 (2) of the GDPR. The Data Protection Act 2018 contains provisions that allow personal information about criminal convictions to be used where certain circumstances apply. This is known as the ‘lawful basis for processing’. BFA’s lawful basis for using personal information varies, depending on the purpose for which we are using it. Our basis for processing is explained in more detail below. Personal information Purpose 1 Managing your application to higher or further education, or attendance at a BFA event If you apply through BFA, or register to attend a BFA event, you’re accepting our terms and conditions, and entering into a contract with us. We’ll collect the personal information necessary to satisfy the purpose of this contract, such as personal information to allow course providers to make informed decisions on whether to offer a place on a course. This also covers personal information collected from other sources, such as referees, or examination and awarding bodies. GDPR lawful basis for processing – Article 6 1 (b) ‘processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract’. Purpose 2 Sharing personal information with statutory bodies with responsibilities for the higher education sector, and to enable academic research into higher education We share personal information with providers and other public authorities (e.g. government bodies such as the Department for Education) to help them with their statutory functions, including funding, regulation, and policy making. We share personal information with universities to help them meet, or demonstrate they are meeting, government aims or policies such as ‘widening participation’ initiatives, which require them to address discrepancies in the take up of higher education opportunities between different social groups. We also share personal information to enable academic research. We also publish a wide range of reports about our higher education admissions schemes. We always try to share information in a way that does not identify individuals, such as by providing statistical information. Where personal information is provided in a way that allows individuals to be identified, it is done so under contractual terms, and not used to support decisions being made about individuals. GDPR lawful basis for processing – Article 6 1 (e) where ‘processing is necessary for the performance of a task carried out in the public interest’. Purpose 3 Sending information to unplaced applicants about available courses, display advertising, providing services to universities to help their admissions strategies, and producing commercial research If you apply through BFA Undergraduate and do not get a place, we may send you course and opportunity information on behalf of providers, unless you opt out of receiving this. If you have subscribed to Google, Twitter, Facebook, LinkedIn, or Snapchat, we may also use their remarketing features to support promotion of our services that you have shown an interest in. You can stop receiving these adverts by following the advice in ‘Direct marketing, accessing student We give analysis to providers, to help them understand and measure the success of their admissions procedures and improve them. We do not provide personal information that identifies individuals for this purpose. We also may provide statistical analysis to people or organisations undertaking research into the higher education sector. GDPR lawful basis for processing – Article 6 1 (f) where ‘processing is necessary for the purposes of legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child’. BFA does not receive public funding. These services help fund our charitable purposes for public benefit and keep application fees free. These activities do not involve sharing personal information in a manner that identifies you with third parties. We issue information about relevant course opportunities on behalf of universities. Applicants can opt out of receiving such information when they apply, and at any point during the admissions cycle. We have controls built into the technology systems that produce our research, to prevent it being shared in a way that can identify individuals. Purpose 4 – Enhancing customer experience We offer services that enhance customer experience, which people can opt in to. These include: - receipt of information about education, careers, accommodation, and products and services that students might be interested in - sharing contact details with third parties that may be able to offer advice and support with the application, such as the Department for Education GDPR lawful basis for processing – Article 6 1 (a) where an individual ‘has given consent to the processing of his or her personal data for one of more specific purposes’. We will obtain a separate consent for these functions, in addition to the terms agreed to when applicants and others agree to the terms of service associated with the product.