PRIVACY POLICY

Policy version: 10.2.1

UniHawk Education Support Services LLC (“Company” ,”we”, “us” or “our”), having License Number 1112883 and its office at Sheikh Zayed Road Barsha Heights the One Tower office 2702/2703 values your privacy and recognizes the importance of protecting the privacy of all individual accessing or using our website https://www.unihawk.com (our website). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the Federal Decree Law No. 45 of 2021 on the Protection of Data of the United Arab Emirates (UAE), and the subsequent Executive Regulations released by the Government of UAE, from time to time (UAE Data Protection Law)

This version of our privacy policy is primarily written for users of our website, including students, parents and guardians of child users.

This privacy policy is divided into the following sections:

• What this policy applies to
• Personal data we collect about you
• How your personal data is collected
• How and why we use your personal data
• Marketing
• Who we share your personal data with
• How long your personal data will be kept
• Transferring your personal data out of the UAE
• Cookies and other tracking technologies
• Your rights
• Keeping your personal data secure
• Changes to this privacy policy
• How to contact us

1. What this policy applies to

This privacy policy relates to your use of our website only.

2. Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:

• your name, parent/guardian name, address, passport copy and contact information, including email address and telephone number;
• information to check and verify your identity, eg date of birth;
• location data, if you choose to give this to us;
• details of any information, feedback or other matters you give to us by phone, email, post or via social media;
• your activities on, and use of, our website;
• information about the services we provide to you;
• academic records (including transcripts, report cards and test scores);
• your internet protocol (IP) address, region, or general location where your computer or device is accessing the internet, browser type, operating system and device type;
• a record of third party websites accessed when you visit on our Website and clicks on a hyperlink; and
• your responses to surveys, competitions and promotions.

Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case we will tell you and give you the choice before you give the personal data to us. We will also inform you if declining to share that personal data will affect your ability to use our website or any services, including our university admission services. Please note that certain personal data may be required for us to process your application and provide our university admission services, and opting not to provide this data may impact our ability to assist you in the application process.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

3. How your personal data is collected

We collect personal data from you:

• directly, when you enter or send us information, such as when you raise an inquiry with us on the website or contact us (including via email), send us feedback, or opt for our services via our website, post material to our website and complete surveys or participate in competitions via our website or third party website, and
• indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explained in the section on ‘Cookies and other tracking technologies’ below.

We also collect personal data about you from other sources. The categories of sources from which we collect information include:

• Social Networks and other locations that serve or assist in serving our advertisements;
• Documents submitted in support of university or academic program applications;
• Consent and authorization forms issued by us for the purpose of enabling the provision of our services to you.
• Online and offline registration forms;
• School information sessions, fairs, and exhibitions;
• Marketing campaigns and digital promotions (website, social media, email).
• Joint Marketing that we engage for joint marketing activities; and
• Publicly-available sources, including information in the public domain.

4. How and why we use your personal data

Under the data protection law, we can only use your personal data if we have a proper reason, eg:

• where you have given consent
• to comply with our legal and regulatory obligations
• for the performance of a contract with you or to take steps at your request before entering into a contract, or
• for our legitimate interests or those of a third party

We use your personal data, specifically for the following purposes:

1. Providing services to you and perform our contract with you or to take steps at your request before entering into a contract;
2. Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us, to minimise fraud that could be damaging for you and/or us;
3. Enforcing legal rights or defend or undertake legal proceedings and protect our business, interests and rights;
4. Customising our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website, where your consent is gathered or in cases where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e., to be as efficient as we can so we can deliver the best service to you at the best price. If you have provided such a consent you may withdraw it at any time by reaching out to our Data Protection Manager (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn);
5. For retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended in order to be as efficient as we can so we can deliver the best service to you at the best price. If you have provided such a consent you may withdraw it at any time by reaching out to our Data Protection Manager (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn);
6. Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices, in order to be as efficient as we can so we can deliver the best service to you at a competitive price;
7. Protecting the security of systems and data used to provide the services. We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us;
8. Statistical analysis to help us understand our student base so as to be as efficient as we can so we can deliver the best service to you at competitive prices;
9. Updating and enhancing student records, to perform our contract with you or to take steps at your request before entering into a contract and for our legitimate interests such as making sure that we can keep in touch with our students about new services;
10. Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant;
11. Generally, internal and external audit purposes, including audits to support our finance department; and
12. To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency so as to protect, realise or grow the value in our business and assets
13. To provide personalized counselling, tutoring, test preparation, and university admission services;
14. To act on your behalf, with your authorized consent, in submitting applications to universities or related institutions; and
15. To submit required documents to relevant institutions based on your prior signed authorization form with us.

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

5. Marketing

We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

We may use your name, achievements, and success stories in digital media, presentations, and marketing campaigns only after obtaining your express written consent. Where you are a minor, consent will be obtained from a parent or legal guardian.

You have the right to opt out of receiving marketing communications at any time by contacting us at [email protected]

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell or share it with other organisations outside our group for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

6. Who we share your personal data with

Where we share your data with third parties, we always ensure appropriate measures are taken to protect your data in compliance with the UAE Data Protection Law.

We share your data internally purely on a need-to-know basis. We share your data with our Affiliates, with persons representing you or arranging services on your behalf, universities, institutions, as well as with other persons to help us provide you with our services or from whom we need information to process your claims or entitlements. We also share your information where required to by law or to protect our legal rights.

In certain instances, we share your data with the following persons for the purposes set out in this Policy:

• Other companies belonging to our group;
• Entities to which our services are outsourced;
• Our partners and other third parties that assist us in our provision of our services, including agents working on our behalf, reinsurers and insurers, actuaries, auditors, financial, legal and tax consultants, IT service providers, anti-money laundering authorities, data protection supervisory authorities and other regulators;
• Governmental entities to the extent required to perform our contractual obligations;
• Any entity which purchases all or part of the Company;
• Persons with whom we are permitted or obliged to share your data by applicable law in certain circumstances;
• Public authorities in accordance with applicable laws.
• To prevent and investigate criminal acts;
• Video surveillance of the offices to collect evidence in case of attacks, fraud or other policy or legal breaches;
• To exercise or defend our legal rights and comply with court orders; and
• To keep your data safe and secure. Using your data for security purposes (e.g. ensuring IT security) or to investigate possible fraud or other violations of this Policy and other contractual obligations.

We may process your data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.

We occasionally also share personal data with:

• our external auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
• our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
• other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

7. How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. The length of time over which data may be retained is dependent upon the circumstances including why the personal information was obtained in the first place. Different retention periods apply for different types of personal data. Following the end of the of the relevant retention period, we will delete or anonymise your personal data, unless we are legally obligated to retain this data for longer time periods.

8. Transferring your personal data out of the UAE

As part of a multinational group, we deal with entities in different jurisdictions with global presence themselves. As a result, where legally required or while carrying out our rights pursuant to this Policy, we transfer and process data inside and outside the UAE. Certain countries where we process data may have laws less protective than those in the UAE. It is sometimes necessary for us to transfer your personal data to countries outside the UAE. In those cases we will comply with UAE Data Protection Law designed to ensure the privacy of your personal data.

We will only transfer your data to a jurisdiction classified as adequate as per the UAE Data Protection Law or otherwise where we have put in place adequate safeguards to protect your data. In particular, if none of the above apply and we wish to transfer your data to a jurisdiction that does not have an adequate level of data protection as per the UAE Data Protection Law, we will undertake all reasonable measures to ensure this protection is set out in a written agreement between us and the receiving entity or that otherwise, the legally required measures are undertaken. For more information on the safeguards and measures undertaken by us to protect your data, please contact us using the details set out under ‘How to contact us’ section below.

In the event we cannot or choose not to continue to rely on mechanisms at any time we will not transfer your personal data outside the UAE unless we can do so on the basis of an alternative mechanism or exception provided by UAE Data Protection Law and reflected in an update to this policy.

If you would like further information about data transferred outside the UAE, please contact us or our Data Protection Manager (see ‘How to contact us’ below).

9. Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website (“Cookies”). We use Cookies and similar technologies on our website to track the activity on and store certain information. These help us recognise you and your device and store some information about your preferences or past actions.

We use Cookies and similar tracking technologies to track the activity on our website and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse our website. The technologies we use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on your device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our website. Unless you have adjusted your browser setting so that it will refuse Cookies, our website may use Cookies.
• Web Beacons. Certain sections of our website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity)
• Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser.

10. Your rights

With respect to your data, you have the following rights, among others:

• Right to access personal data: You have the right to ask us to provide you with information relating to any data of yours processed by us. We are permitted to restrict such access where legal grounds set out in applicable data protection laws apply, such as, among others, to protect the rights of others or avoid obstructing legal inquiries, investigations and procedures. Where we restrict your access to data, we will inform you of the basis for such restriction.
• Right to correction/rectification: You have the right to request correction of any personal data collected by us, which is inaccurate or incomplete as per the applicable laws.
• Right to erasure: You have the right to request deletion of your data where (a) it is no longer necessary for the purposes it was collected; (b) you withdrew your consent and no other lawful processing basis applies; (c) our storage is unlawful or deletion is required for us to comply with applicable law; or (d) you object to our processing of your data and we do not have any overriding legitimate grounds to continue with such processing. We are not obliged to delete any data unless at least 1 (one) of the above circumstances apply and we do not require your data to comply with legal requirements or to establish or defend ourselves with respect to any legal claims.
• Right to restriction on processing: You have the right to request that we restrict processing of your data if (a) you contest the accuracy of your data, for as long as it takes us to verify such accuracy; (b) our processing is unlawful; (c) the processing was carried out in violation of the UAE Data Protection Law. We may however continue to process such data requested for restriction if we require them to establish, exercise or defend yourself against legal claims; or (d) where you have objected to our processing of your data and we are establishing if we have overriding legitimate grounds to continue such processing.
• Right to transfer data: You shall have the right to obtain personal data which has been provided to us in a structured and machine readable manner only if processing of their information is (a) based on consent or is necessary to fulfil a contractual obligation, and (b) is made by automated means; and may also request the transfer of their personal data to another controller when feasible.
• Right to withdrawal: For the data you have consented to, you shall have the right to withdraw his or her consent at any time which shall not, however, affect the lawfulness of processing based on consent before its withdrawal.
• Right to object to use: You have the right to object to the processing of their personal data by us when it is based on legitimate interests, for direct marketing (including profiling), and processing for scientific and/or historical research and statistics purposes or in violation of the laws. Where such an objection is received based on our legitimate interests, we must cease such processing immediately unless we can demonstrate that our legitimate grounds for such processing override the data subject’s interests, rights and freedoms, or that the processing is necessary for the conduct of legal claims. Where such an objection is received based on our use of the data for direct marketing purposes, we must cease such processing promptly.
• Right to not to be subject to decisions without human involvement: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below).

If you would like to exercise any of those rights, please email, call or write to us, details of which are available on ‘How to contact us’. When contacting us please:

• provide enough information to identify yourself, including details such as your full name, address and any additional identity information we may reasonably request from you, and
• let us know which right(s) you want to exercise and the information to which your request relates

11. Keeping your personal data secure

We have undertaken all reasonable and legally required security measures to ensure your data is secure and prevent it from being accidentally lost, or used, accessed, altered or disclosed in an unauthorized way. We also regularly review and update such measures to meet new perceived threats that may arise from technological advances. We limit access to your personal data to those who have a genuine need to access it.

We also have procedures in place to deal with any suspected data security breach. Where legally required to do so, We will notify you and any applicable regulator of a suspected data security breach.

12. Changes to this privacy policy

We may modify or update this Privacy Policy from time to time. Changes will be posted on this page and cannot be retroactive. Where appropriate, we will notify you of any material changes made to the Privacy Policy. What constitutes a “material change” will be determined at our sole discretion, in good faith and using reasonable judgment and common sense.

Therefore, you are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

13. How to contact us

Please contact us if you have any queries or concerns about our use of your personal data. We hope we will be able to resolve any issues you may have.

You can contact us and/or our Data Protection Manager by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Telephone: +971508778589

Email Address: [email protected]