Privacy Policy

GDPR Privacy Policy
Welcome to the International Students House (“ISH”) Privacy Policy. 

International Students House (“us”, “we”, or “our”) operates the https://ish.org.uk website (hereinafter referred to as the “Website”). We are the controller and we are responsible for your Personal Data (defined below).

This page informs you of our policies regarding the collection, use and disclosure of Personal Data when you use our Website, Service (the accommodation service provided in accordance with the Room Booking Agreement accessible from https://ish.org.uk) and as an Alumnus (defined below), and the choices you have associated with that data.

When you become a resident of ISH by using our Service, you will automatically become an alumnus of ISH and a member of our alumni community when you leave (an “Alumnus”).

By using the Website and Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Room Booking Agreement.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Full name of legal entity: International Students House

Email address: shami.nathoo@ish.org.uk

Postal address: Attn: Shami Nathoo, International Students House, 229 Great Portland Street, London, W1W 5PN, United Kingdom

Telephone number: 0207 631 8300

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service and as a member of the Alumni community, we may ask you to provide us with certain personally identifiable information that can be used to identify you (“Personal Data”). It does not include data where the identity has been removed (anonymous data).

 

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

 

• Identity Dataincludes first name, middle name, last name, username, password, marital status, title, date of birth, country of birth and nationality, passport details, photograph, Star Rez ID number, and gender.

 

• Contact Dataincludes correspondence address,  family address, email address, telephone numbers, and fax numbers. We will ask for the contact data of a person to contact in case of an emergency (an Emergency Contact).

 

• Financial Dataincludes bank account and payment card details.

 

• Transaction Dataincludes details about payments to and from you and other details of products and services you have purchased from us.

 

• Technical Dataincludes 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 Dataincludes your username and password, purchases or orders made by you..

 

• Usage Dataincludes information about how you use our Website (including the pages of our Website that you visit, the time and date of your visit, the time spent on those pages), products and services. In emails to Alumni, we record whether emails from us have been opened and whether the links contained within the email have been clicked on,

 

• Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. We may use your Personal Data to contact you with newsletters, updates on developments at ISH, details of and invitations to in-house events, details of special offers and benefits available to Alumni, requests for Alumni to consider supporting us in terms of time, philanthropy, donations and/or supporting employability for current students, and other information that may be of interest to you. You may opt out of receiving any, or all, of the communications from us listed in this paragraph by following the unsubscribe link or the instructions provided in any email we send. We will keep a record of our communications with you as an Alumnus.

 

• Insurance Data includes details of your insurance policy for health and emergency cover, collected only when relevant and applicable.

 

• Academic Data includes details of the academic institution where you will be studying, your subject of study, discipline and qualification, the duration of your course, the start and end dates of your course, and whether you are applying for financial support.

 

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

We may also collect Health Data about you. This is a Special Category of Personal Data and includes information about your health (including disabilities, allergy information, special needs, and serious medical conditions). We would only collect this with your explicit consent. We cannot accept your application to use the Services if you do not provide this consent. You may withdraw consent at any time, but we will not be able to continue providing the Services after you have withdrawn your consent. We do not keep this data when you become an Alumnus.

If you Fail to Provide Personal Data

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, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Website and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Website.

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 portions of our Website.

Further details of the cookies we use can be found here: https://www.ish.org.uk/privacy-and-cookies/

 

Collection of Data

We use different methods to collect Personal Data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
  • apply for our Services;
  • create an account on our Website; or
  • give us feedback or contact us.

 

• Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

 

• Third parties or publicly available sources. We will receive Personal Data about you from various third parties as set out below:
  • Technical Data from analytics providers such as Google based outside the EU;
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services Stripe, PayPal, Braintree and Sage Pay. Further details can be found below under the heading ‘Payment’;
  • Company and charity filings;
  • Articles found in the media; and
  • Social networking websites such as LinkedIn.

 

Use of 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:

• Assessing your application for accommodation at ISH and to contact you regarding the outcome of your application.
• 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 obligation.
• Where we have your consent to using your Personal Data for a particular purpose.
• To communicate with you as an Alumnus.

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.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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.

Comply with a legal obligation means processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.

To protect your vital interests means to protect an interest which is essential for your life for example emergency medical care.

Generally, we do not rely on consent as a legal basis for processing your Personal Data, other than Special Categories of 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 potential new customer, consider your application to use the Services, including contacting your intended place of study, and verify that you qualify to use our Services	(a)   Identity (b)   Contact (c)   Academic	Performance of a contract with you
To provide the Service (including our group insurance if you request it) and Website	(a)   Identity (b)   Contact (c)   Insurance (d)   Academic (e)   Health (f)   Technical (g)  Usage	(a)   Performance of a contract with you (b)   Consent (in relation to Health Data) (c)   Necessary for our legitimate interests (to see how you use our Website)
To ensure that we make reasonable adjustments to allow for your use of the Services and your safety while using the Services	(a)   Health	(b)   Consent
To process our fees for this Service including: (a)   Manage payments, fees and charges (b)   Collect and recover money owed to us	(a)   Identity (b)   Contact  (c)   Financial (d)   Transaction (e)   Communications	(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 may include: (a)   Notifying you about changes to our terms, Service or privacy policy (b)   Asking you to leave a review and responding to any complaints (c)  Providing you with customer support (d)  Updating Alumni on developments at ISH	(a)   Identity (b)   Contact (c)   Profile (d)   Communications (e)   Usage	(a)   Performance of a contract with you (b)   Necessary to comply with a legal obligation (c)   Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business 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 business reorganisation or group restructuring exercise) (b)   Necessary to comply with a legal obligation
To deliver relevant content and advertisements to you and measure or understand and monitor the effectiveness and usage of the advertising we serve to you	(a)   Identity (b)   Contact (c)   Profile (d)   Usage (e)   Communications (f)    Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve ISH customer relationships and experiences	(a)   Technical (b)   Usage	Necessary for our legitimate interests (to define types of customers for our Services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you, our events, and special offers and benefits available to Alumni, and record your responses.	(a)   Identity (b)   Contact (c)   Technical (d)   Usage (e)   Profile (f)    Communications (g)   Academic	Necessary for our legitimate interests (to develop our Services and grow our business)
To communicate with Alumni with invitations to develop our relationship which may include: (a)   supporting us in terms of time, philanthropy, and/or supporting employability for current students (b)   occasional donation requests to seek philanthropic support for fundraising projects	(a)   Identity (b)   Contact (c)   Communications (d)   Usage (e)   Academic	Necessary for our legitimate interests (to develop our Services and grow our business)
To contact your Emergency Contact in the event of an emergency	(a)  Identity (b)  Contact	(a) Necessary for our legitimate interests (to contact someone when we need to in an emergency) (b) To protect your vital interests

 

 

 

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.

 

 

Retention of Data

ISH will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal, regulatory, tax, accounting or reporting requirements 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.

ISH will retain Personal Data relating to an unsuccessful application to use the Service for up to 12 months. ISH will retain Personal Data relating to a successful application to use the Service for up to 5 years.

In all other cases, 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 unauthorised 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.

ISH will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Website, or we are legally obligated to retain this data for longer periods.

Transfer of Data

Your information, including Personal Data, may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to United Kingdom and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

ISH will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Disclosure for Law Enforcement

Under certain circumstances, ISH may be required to process or disclose your Personal Data without your knowledge or consent if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

 

Legal Requirements

ISH may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation;
• To protect and defend the rights or property of ISH;
• To prevent or investigate possible wrongdoing in connection with the Service or Website;
• To protect the personal safety of users of the Service or Website or the public;
• To protect against legal liability.

 

Security of Data

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. 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.

The security of your Personal Data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the preferences or settings page of your web browser.

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the United Kingdom or the European Economic Area (EEA), you have certain data protection rights. ISH aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• The right to access, update or delete the information we have on you.Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification.You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object.You have the right to object to our processing of your Personal Data.
• The right of restriction.You have the right to request that we restrict the processing of your personal information.
• The right to data portability.You have the right to be provided with a copy, or request that a third party is provided with a copy, of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent.You also have the right to withdraw your consent at any time where International Students House relied on your consent to process your personal information.

 

Please note that we may ask you to verify your identity before responding to such requests.

Service Providers: Disclosures to Third Parties

We may employ third party companies and individuals to facilitate our Service and/or Website (“Service Providers”), provide the Service and/or Website on our behalf, perform Service or Website-related services or assist us in analysing how our Service and/or Website is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics Providers

We may use third-party Service Providers to monitor and analyse the use of our Service.

• Google Analytics Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
  For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

 

Payments

We provide paid products and/or Services. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American

Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

• Stripe Their Privacy Policy can be viewed at https://stripe.com/us/privacy
• PayPal or Braintree Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full
• Sage Pay Their policies can be viewed at https://www.sagepay.co.uk/policies

Social Media

ISH has a presence on social media (Facebook, Twitter, YouTube, etc.) and you can interact with us through your existing social media accounts. ISH uses Buffer as a tool to help us manage our use of social media.

For more information on the privacy practices of Buffer, please see their privacy policy which can be viewed here: https://buffer.com/legal

Academic institutions

In order to use our Services, you must be a student engaged in full­time study or in a programme of professional work placement or internship (earning no more than £25,000 per annum), leading to a degree or professional qualification. We may contact your place of study and may disclose some of your Personal Data in order to verify your enrolment status.

Insurance

If you choose to be part of our free group insurance policy, we may provide your Personal Data to our insurers.

Links to Other Sites

Our Website may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

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.

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.