Privacy policy

 

How We Use Your Information

Data Privacy Notice

If you have come to this page because you want to access your marketing preferences please click here or the unsubscribe link in any marketing e-mail we send to you.

Background

This notice is to help you understand how and why we collect your personal data and what we do with it. It also explains the decisions that you can make about your personal data.

This privacy notice applies to the personal data of our campuses visitors, website users, including but not limited to prospective students as well as other people whom we may contact through our students or prospective students such as sponsors, employers, references and emergency contacts. It also applies to our suppliers whether partnerships and companies or atypical workers such as independent contractors and freelance workers, who provide services to School.

If you are a member of Glion Institute of Higher Education (the “School”)’ staff you should refer to the Sommet Education group ‘s staff privacy notice which is available on the Sommet Education intranet. The privacy notice for our candidates is available on the career page of the Sommet Education website. Finally, if you are a current student, please refer to the School student privacy notice which is available on the student platform.

What is “personal data”?

Personal data is information that School holds about you and which identifies you or could identify you when combined with other data which School either holds or is likely to obtain.

WEBSITE USERS

Whenever you use our School’s websites, even though you do not create an account and log on with your user name and password, we collect a limited amount of data which we use to help us improve your experience when using our website and manage the services we provide. Indeed, our web server automatically records details about your visit, that does not, on its own, permit direct association with you including but not limited to your IP address, the website from which you visit us, the advertisements on which you have clicked, the type of browser software used, the pages that you actually visit including the date and duration of your visit, the language you choose and the way you navigate on our website – See “Cookies Policy” below for further information.

PROSPECTIVE STUDENTS

We may collect and process the following types of personal data about you:

•  your name, and contact information such as address, email address and telephone number, as well as your date and place of birth, gender, photo, country of domicile and your nationality including copy of legal documents issued by public bodies such as your ID or passport;
•  information relating to your education and employment history;
• funding or financial details (income, sponsor);
• information about your family or personal circumstances, and both academic and extracurricular interests, for example where this is relevant to the assessment of your suitability to receive a bursary or in order to provide you with appropriate help;
• sensitive personal data and information in particular, information concerning your health and medical conditions;
• access and authentication information (e.g., user name, passwords); and
• records of interactions with School services. In particular, we may monitor or record calls to our enrolment/admissions line in case we need to resolve queries or issues. Conversations may also be monitored for staff training purposes and to help improve our service. Where applicable, we will notify you and take appropriate measures to ensure that sensitive data is not recorded.

 

School doesn’t seek to collect personal data from individuals under age of 16. Individuals under age of 16 should receive permission from their parent or legal guardian before providing any personal data to us on the website.

CAMPUSES VISITORS

We require our visitors to provide basic personal information, which usually includes name, company name, reason of visit, date & time. Video footage is also being recorded on our CCTV system installed on campuses premises. When we provide you with IT services during your visit, your usage of IT services will be recorded in usage logs and audit trails as part of the normal operation of the services.

Also, when you enter our campuses, you enter an area where photography, audio, and video recording may occur as our campuses love to share news on social media, online, and print publications for the legitimate purpose of disseminating information about our activities. As far as possible, notifications will be put up in and around ‘open’ events to inform you when such photography / video is taking place. If you do not wish to appear in photographs or be recorded, please avoid the concerned area at that time.

SPONSORS, EMPLOYERS, REFERENCES AND EMERGENCY CONTACTS

We may collect and process the following types of personal data about you:

• sponsors (e.g. parents or other legal guardians or relatives): your contact and financial details and confirmation that you agree to sponsor the student with tuition and other fees;
• references: your contact details and confirmation of the information provided by candidates or prospective students who have put your contact details down as a reference;
• emergency contact: your contacts details where of one of our students, candidates or a member of staff has put you down as their emergency contact;
• employer: your contacts and company details and evaluation and related information when you have accepted one of our students for an internship.

SUPPLIER DATA

We collect contact details of relevant individuals at your organisation.

Regardless of the category you belong to, the examples provided above are not all-inclusive. We also may collect similar or related information and in particular information you choose to share voluntarily about you.

Where does the School get your personal data from?

 

WEBSITE USERS

We collect your data automatically via cookies, in line with cookie settings in your browser – See “Cookies Policy” below for further information.

PROSPECTIVE STUDENTS

We obtain personal data regarding you from the following sources:

• You when you:
  • create an account on our websites;
  • provide information through one of our online forms such as Contact Us, Visit Us, Request a brochure, Newsletter sign-up, Register to Open Day, Registration to an Event; Register for a private tour etc;
  • registered for one of our academic programs whether through an online application form, during a fair or otherwise; and
  • give us any info via email or other messaging channel, e.g. LinkedIn, Facebook, WhatsApp, SMS, phone calls etc.

 

• Third party sources:
  • such as organisations that assist us with pursuing our purposes described below, including the School regional and country enrolment offices, partners institutions or organisations or your educational counsellor;
  • if you have expressed your interest in one of our programs to a friend or another person and agreed for them to share your contact details with the School as part of a School referral program as the case may be; and
  • if you ‘like’ our page on Facebook or ‘follow’ us on Twitter we will receive your personal information from those sites including any personal data you agreed with the respective websites to share.

CAMPUSES VISITORS

As a visitor, we usually obtain personal data regarding you either directly from you or from our staff or students when the latter invite you to visit them on campus.

SPONSORS, EMPLOYERS, REFERENCES AND EMERGENCY CONTACTS

As a sponsor, we obtain personal data regarding you either directly from you where you actively communicated it to us or from one of our students or prospective students.

As a reference or emergency contact, we obtain personal data regarding you from one of our students, candidates or staff member.

As an employer, we obtain personal data regarding you either directly from you or your company where you contact us or register with our Career and Internship portal or from one of our students as part of their compulsory internships.

SUPPLIER DATA

We obtain personal data regarding you from the following sources:

• You, your employer or organisation when you contact us proactively, usually by phone or email or where we contact you, either by phone or email; or

• Third party sources such as organisations that assist us with pursuing our purposes described below including where relevant due diligence services providers, media articles, social networking posts or other public sources for example the world wide web.

Why does School collect and use your personal data?

WEBSITE USERS

We use your data to help us improve your experience of using our website. Our website also uses re-targeting, which allows us to make our online content more interesting for you. Retargeting technology means we can advertise recently viewed and related products on our partners’ websites, meaning our adverts, even on other companies’ sites, are relevant to what you would like to see. We do this by analysing user behaviour from data collected by our cookies even without having a user profile – See “Cookies Policy” below.

PROSPECTIVE STUDENTS

We will use the personal information you provide for the purposes of processing your application and providing you with the information and services you requested, including, but not limited to the following activities:

• storing (and updating when necessary) your details on our databases;
• verifying your account and providing a personalized experience for you;
• allowing you to participate in the interactive features of our services, when you choose to do so;
• communicating with you about the School (including its services and programs) and inviting you to events – to manage your communication preferences online visit […];
• automated decision making: the marketing team use various modelling tools that will automatically process your data to assess the likelihood of you being interested in special promotions, new products and services, or upcoming events; and
• assessing your application to one of our programs (any medical information required will only be used to ensure you are fit to start and continue learning at School or to make sure we can reasonably adjust our teaching methods or attend any special need during your stay).

If your application is successful and you become a student we will also use your personal data for study-related purposes.

CAMPUSES VISITORS

We collect and use your personal data i) in order to ensure the security of people, items and confidential information located in the School’s premises or accessible from the School’s premises, ii) to provide IT services during your visit (e.g. to support your usage of systems, investigate information security or data integrity incidents or understand usage and performance of IT systems) or other services as the case may be and iii) to help us understand the make-up of the community we serve (e.g. we use it to generate reports and to help us to make decisions to improve our services).

Also, as mentioned, photo/video taken on campus may be shared on social media, online, and print publications for the legitimate purpose of disseminating information about our activities. In some instances, you may be identifiable in the picture or audio but you will not be identified using your name or personal information without your consent and you are free to avoid the concerned area.

SPONSORS, EMPLOYERS, REFERENCES AND EMERGENCY CONTACTS

As a sponsor, we store (and update when necessary) your details on our databases so that we can contact you in relation to the student you sponsor and process payments where relevant. We may also be conducting surveys. There is no requirement for you to take part in any of these surveys but participation assists the School in enhancing sponsor and student experience.

As an emergency contact, we store (and update when necessary) the information that our students and candidates/staff members give us about you in order to put you down on our form as an emergency contact and we will contact you in the case of an accident or emergency affecting them.

As a reference, we will contact you in order to take up a reference.

As an employer, we may use your personal data as follows:

• if you take one of our students as a trainee, as part of our students’ compulsory internships, you will be requested to evaluate your trainee and provide certain information;
• if you decide to register on our Career and Internship Portal, students may be allowed to access your information and reach out to you for, among other things, the purpose of internships and employment; and
• we may contact/inform you about upcoming Career Fairs, student placement and institutional initiatives.

SUPPLIER

We will use the personal information you provide to ensure that things run smoothly including, but not limited to the following activities:

• storing (and updating when necessary) your details on our databases, so that we can contact you in relation to our agreement(s);
• communicating with you in relation to our agreement(s) including paying for the services you provide (if this is part of the contractual arrangements between us); and
• performing due diligence: please note that if your services consist in acting on behalf of School for any reasons we may process your personal data, including information from the public domain, for due diligence purposes, in accordance with our then current policies.

Our legal grounds for using your information

WEBSITE USERS

Some cookies are necessary because otherwise the website is unable to function properly. We need your consent for using other cookies.

PROSPECTIVE STUDENTS

Contractual commitment

School may be processing your personal data often on the basis that it is necessary to enable it to meet its contractual and pre-contractual commitments. For instance, if you have requested information from us through one of our online forms or otherwise or if you have filled out an application form, whether or not online, we assume that you are happy for us to collect and otherwise use your personal data to give you the requested information and where relevant evaluate your application. In case you are really interested in the School and in our programs, we also want to provide you with tailored programs recommendations and relevant articles to read to help you on your application. We therefore think it’s reasonable for us to process your data to make sure that we send you the most appropriate content. If, at any stage, you are concerned about the content, frequency or method of communications, you can unsubscribe or update your preferences using links provided at the bottom of the relevant correspondence.

Legal obligation

School may also be required to process the above personal data in order to comply with its legal obligations.

Legitimate interest

Certain activities are also necessary for the purposes of the legitimate interest of the School and other third parties, including students. These interests are not overridden by the interests and fundamental rights or the freedoms of the data subjects concerned.

Consent

Where none of these legal bases apply, your consent to process your personal data will be sought. If we ask for your consent to use your personal data you can take back this consent at any time. Any use of your personal data before you withdraw your consent remains valid.

Sensitive personal data

Some of the information we collect and use may include sensitive personal data, the processing of which is either based on a legal obligation or on your consent as appropriate in each case.

 

 

Also, please note that the School will be processing some of your data because you have clearly made it publicly available, in particular on the internet.

CAMPUS VISITORS, SPONSORS, EMPLOYERS, REFERENCES AND EMERGENCY CONTACTS

We need your consent only for those aspects of our activities which are not covered by our legitimate interests.

For instance, for photographs/videos taken on campus for use in publication materials, where you are not the subject of the image, i.e. if it is a “group” or “crowd” photograph, we may use such images without requiring your consent, however, where you are the subject of the photograph, you will be asked to provide your explicit consent to use the image.

If we ask for your consent to use your personal data you can take back this consent at any time. Any use of your personal data before you withdraw your consent remains valid.

SUPPLIER

Contractual commitment & Legal obligation

As a supplier, most of the time the School will be processing your personal data on the basis that it is necessary to enable it to meet its contractual and pre-contractual commitments or in order to comply with its legal obligations, for instance as regards to payments, taxes etc.

Legitimate interest

We may use your personal data for the above purposes if we deem this to be necessary for our legitimate interests.

 

Regardless of the category you belong it may also be necessary for us to process your personal data, where appropriate and in accordance with local laws and requirements, in connection with exercising or defending legal claims.  This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.

 

In any cases, your personal data will be processed in accordance with applicable laws and regulation and the Sommet Education Group Data Protection Policy as amended from time to time.

Sharing information with others

 

For operational reasons and as is necessary and proportionate for intended purposes, we may share your information with other entities in the Sommet Education Group.

For the purposes referred to in this privacy notice and relying on the bases for processing as set out above, we may also share your personal data with certain third parties:

• government departments and agencies and local authorities where we have a statutory obligation to provide information;
• crime prevention or detection agencies (e.g. the police, the department for work); We may also need to share information with or our legal advisers;
• contractors, suppliers, agencies, or any other parties acting on School’s behalf (collectively, “External Parties”) where there is a legitimate reason for their receiving the information, including but not limited to third parties contracted to provide IT services for us including cloud-based storage providers or if you are a prospective student:
  • international agents (if you are an international applicant and you apply via an international agent;
  • partner educational institutions and organisation involved in the delivery of our programmes, including those outside the EEA, if you apply to a programme partially delivered by such an institution.

School contractually requires External Parties processing personal data on behalf of the School to follow this policy, whether they are utilizing School’s and/or their own electronic systems and data management tools. School employees are responsible for ensuring that any External Parties they work with in support of School operations comply with this policy.

This website may contain advertising of third parties and links to other sites or frames of other sites where School does not control how your data is processed. In those situations, please ensure you read and understand the privacy policies and practices of such websites and be aware that we are not responsible for the privacy practices or content of those third parties or other sites.

Sending information to other countries

Some of the personal data we process about you will be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) or Switzerland, for example where it is processed by staff operating outside the EEA/Switzerland who work for us or for one of our suppliers, or where personal data is processed by one of our suppliers who is based outside the EEA/Switzerland or who uses storage facilities outside the EEA/Switzerland.

In these circumstances, your personal data will only be transferred on one of the following bases:

• a European Commission decision provides that the country or territory to which the transfer is made ensures an adequate level of protection;
• 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); or
• there exists another situation where the transfer is permitted under applicable law (e.g. where we have your explicit consent).

How Do We Secure your Personal Data?

We implement appropriate physical, administrative and technical measures designed to protect your personal data against accidental, unlawful or unauthorized destruction, loss, alteration, disclosure or access or use, and all other unlawful forms of processing.

School contractually requires that External Parties provide equivalent levels of protection when handling your personal data and only process the data in accordance with our instructions.

In any cases, we limit access to personal data to those employees, agents, contractors and other third parties that have a legitimate business need for such access in accordance with this privacy notice.

For how long do we keep your personal data?

If we have not had meaningful contact with you for a period of three years, we will delete your personal data from our systems unless we believe in good faith that the law or other regulation requires us to preserve it.

When we refer to “meaningful contact”, we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services.

If you become a student of the School, a basic student record will be kept permanently by School, with more detailed records kept for defined retention periods.

What decisions can you make about your personal data?

School makes reasonable efforts to ensure that your personal data is reliable for its intended use. However, you are equally responsible for updating and checking the accuracy of the information provided to School. As an active user of this website you can do this through the […] at […]

Moreover, you are able to make various decisions about your personal data. Your rights are as follows:

• to obtain access to, and copies of, the personal data that we hold about you;
• to require us to correct the personal data we hold about you if it is incorrect;
• to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller;
• to require that we cease processing your personal data if the processing is causing you damage or distress;
• to require us not to send you marketing communications;
• to require us to erase your personal data;
• to require us to restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);
• to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights.

Please note that:

• the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply;
• information request will be fulfilled free of charge unless in case of repetitive, manifestly unfounded or excessive requests or for further copies; and
• where our processing of your personal data relies on your consent and where you then withdraw that consent, it may affect the provision of the services.

Further information and guidance

School reserves the right to modify this notice as needed, for example, to comply with changes in laws, regulations, Schools practices and procedures, or to respond to new threats or new requirements imposed by data protection authorities. Please just visit this page if you want to stay up to date, as we will post any change here.

If you have questions about your personal data, contact marketing@sommet-education.com or email our Data Protection Officer at: dpo@sommet-education.com

If you are not satisfied with how we are processing your personal data, you can make a complaint to the relevant data protection authority.

Last update: August 2020

The www.glion.edu website is operated under the Glion Institute of Higher Education name by Sommet Education Sàrl for the benefit of GIHE Sàrl, a company registered in Switzerland at Rue de l’Ondine 20, 1630 Bulle.

 

 

COOKIES POLICY

WHAT ARE COOKIES?

Our websites, email messages and advertisements may use “cookies” and other technologies.

A cookie is a small text file that is stored on your computer, smartphone or any other device optimized for the Internet when visiting a website. This text file stores information that can be read by the website when visiting it again at a later date being understood that can be distinguished:

• Session cookies: only stored on your computer during your web session and automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any information from your computer; or

 

• Persistent cookies: stored as a file on your computer and remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. For instance we use persistent cookies such as Google Analytics and for personalisation (see below).

Some of these cookies are necessary because otherwise the website is unable to function properly. Cookies are also used to optimise the performance of the website.

Other cookies are convenient for the visitor: they remember your username in a secure way as well as your language preferences, for example. School uses such cookies to help us provide you with a better user experience tailored to your personal preferences. By using cookies we make sure that you do not receive or need to enter the same information every single time you visit the website.

Information collected by cookies and other technologies are most of the time non-personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by certain laws, we also treat these identifiers as personal data. Similarly, to the extent that non-personal information is combined with personal data, we treat the combined information as personal data for the purposes of this privacy notice

PREVENT COOKIES FROM BEING STORED ON YOUR COMPUTER

For certain cookies, your consent will be required. More generally, you can manage the settings in your browser. Usually, your browser’s help section will provide information on how to change your cookie settings. You can find detailed information on how to change your browser settings by clicking here.

When you save your cookies settings, they should also apply to your future visits to the Site. However, for technical reason beyond our control, this cannot be guaranteed.

Your attention is drawn to the fact that our cookies improve your browsing experience on the website and allow you to access to certain secure areas where necessary. Where this is the case, certain website functions may be altered or blocked. If you would like to accept School’s cookies but block our partners’ cookies, you can set your browser to block third party cookies.

SPECIFIC COOKIES WE USE

Cookies may be set either by our website or by a third-party website. The tables below identify the cookies we use and explain the purposes for which they are used. However, we continue to collect information about third-party cookies and the tables below are based on the work completed to date. Accordingly, we may update the information contained in this section from time to time.

Pre-Sessional Programs

Cookie name	Cookie purpose	Cookie provider privacy policy
AppNexus	This cookie contains a unique randomly-generated value that enables AppNexus to distinguish browsers and devices. It is matched against information – such as advertising interest segments and histories of ads shown in your browser or on your device – provided by us or other third parties and stored on the AppNexus technology platform. This information is used to select advertisements for delivery by AppNexus, and to measure the performance of, and attribute payment for, those advertisements. In addition, this cookie is sometimes matched to other cookies that contain non-personally identifying information.	https://www.appnexus.com/en/company/platform-privacy-policy
Google Adwords User Lists	This cookie enables us to create, transact and manage digital advertising.	http://www.google.com/intl/en /policies/privacy/
Google Analytics	Google Analytics is a web analytics service provided by Google, Inc. Google Analytics uses cookies to help us analyse how visitors use our site. Google will use this information for the purpose of assessing your use of the website, compiling reports on website activity for us and providing other services to us relating to website activity and internet usage.	http://www.google.com/intl/en /policies/privacy/
GA Audiences	Google Audiences helps us to organise and analyse your data. The cookies help us to understand more about the type of people who visit our website and the optimal frequency with which to send advertising messages to our Website Users.	http://www.google.com/intl/en /policies/privacy/
Google Tag Manager	This cookie is associated with sites using Google Tag Manager to load other scripts and code into a page. The cookie helps us to classify information on our website and label it in a way which makes it easier to be found in future searches.	http://www.google.com/intl/en /policies/privacy/
Google Dynamic Remarketing	This cookie enables us to create, transact and manage digital advertising.	http://google.com/intl/en/policiea/privacy/
Google Adwords Conversion	This cookie enables us to create, transact and manage digital advertising.	http://www.google.com/intl/en/policies/privacy/
Facebook Connect	Facebook Connect is a single sign-on application which allows you to login to and interact with our website through your Facebook account to avoid having to take the basic registration steps on our website.	https://www.facebook.com/abo ut/privacy/
Facebook custom audience	This cookie enables us to create custom lists of existing customers. We can then send relevant advertising to the customers on different lists depending on the specific interests of the custom audience on each list.	https://www.facebook.com/full_data_use_policy
Marketo	These cookies allow our website to link visitor behaviour to the recipient of an email marketing campaign, to measure campaign effectiveness.	http://legal.marketo.com/privacy/
Crazy Egg	We use Crazy Egg’s Analysis Service to obtain information about how you interact with our website. This cookie helps us to see what people are doing on our website, such as showing us where people are clicking (and where they aren’t). Or how many people scroll down our pages (and where most people stop). Also, it allows us to see where those people are coming from to begin with, and who clicks on what the most.	https://www.crazyegg.com/privacy
Bing	This cookie enables us to create, transact and manage digital advertising.	https://advertise.bingads.microsoft.com/en-gb/resources/policies/microsoft-bing-ads-privacy-policy
Kenshoo	Kenshoo allow us to manage, optimize and analyse our digital marketing activities. The information collected by Kenshoo is typically used to identify trends and optimize our overall advertising activities. As such, this information is un-identifiable, and we do not know, nor will we attempt to know the identity of users.	https://kenshoo.com/privacy-policy/
Yandex	This cookie enables us to create, transact and manage digital advertising.	https://yandex.com/legal/privacy/
Baidu Analytics	Baidu Analytics (Baidu Tongji) is a web analytics service provided by Baidu Inc., the largest search engine in China. Similar to Google Analytics, Baidu Analytics also uses cookies to help us analyse how visitors use our site. Baidu will use this information for the purpose of assessing your use of the website, compiling reports on website activity for us and providing other services to us relating to website activity and internet usage. This cookie is only placed on the Chinese websites.	https://www.baidu.com/duty/yinsiquan.html
Baidu SEM Analytics	Baidu SEM Analytics works exactly like regular web analytics. It is used to track paid search campaigns on Baidu. This cookie is only placed on the Chinese websites.	https://www.baidu.com/duty/yinsiquan.html