Privacy Policy

We respect your right to privacy. Please read this Privacy Policy carefully.

Introduction
1. This privacy and cookie policy (the “Privacy Policy”) explains the policies and procedures governing the collection and processing of personal data related to individual users (“you” and “your”) through the website, associated sub-domain names, and other online presence (the “Website”).
2. For the purposes of this Privacy Policy:
  - The term “personal data” refers to any information relating to a natural person who can be identified, directly or indirectly, by using such information; and
  - The term “processing” refers to collection, storage, erasure, use, and disclosure of personal data.
3. Responsible entity (data controller). The company that is responsible for collection and processing of your personal data is Boston Education Company Ltd, having a registered address at 128 City Road, London EC1V 2NX, United Kingdom ( “we”, “us”, and “our”).
4. About the Website. The Website is an information and e-commerce platform offering advice, tools and services related to education and admission to educational institutions. The term “Website” refers to all our websites where we provide information, services and products to you, and includes but is not limited to bostoneducationcompany.com, collegeappguru.com, mbaappguru.com, gmatguru.net, greguru.net, inseadassessment.net, inseadassessmentguide.com, executiveassessment.net, and all their subdomains, subsites, Facebook pages, and any other online presence.
5. Term and termination. This Privacy Policy enters into force on the effective date indicated at the top of the Privacy Policy and remains valid until terminated or updated by us.
Types of personal data collected by us
1. We comply with data minimization principles and we collect only a minimal amount of personal data that is necessary for ensuring your use of the Website:
  - When you visit the Website, we collect your IP address;
  - When you register your user account on the Website, we collect the following personal data: your (i) first name; (ii) last name; (iii) email address; (iv) phone number; (v) password; (vi) address; (vii) company name (optional); (viii) company registration number (optional); (ix) VAT number (optional); and (x) fax number (optional);
  - When you access the Website through your social media account (e.g., Facebook, Google, Yahoo, or VKontakte), we collect the personal data that you authorize your social media provider to make available to us (e.g., your public social media profile);
  - When you subscribe for a newsletter, we collect your (i) first name, (ii) last name, and (iii) email address;
  - When you contact us through the contact form available on the Website or by email, we collect your (i) name, (ii) phone number, (iii) email address, and (iv) any other information that you decide to provide us in your message.
2. Sensitive data. We do not collect, under any circumstances, any sensitive data from you, such as your health information, opinion about your religious and political beliefs, racial origins, membership of a professional or trade association, or information about your sexual orientation.
Purposes of personal data
1. We respect strictest data protection principles. Thus, we collect and process your personal data only for specified, explicit, and legitimate purposes. The personal data collected through the Website is used only for:
  - Enabling your use of the full functionality of the Website (e.g., registering and maintaining your user account);
  - Carrying out our contractual obligations (e.g., processing and delivering your orders);
  - Responding to your requests (e.g., answering your enquiries, connecting you with target schools);
  - Providing you appropriate content (e.g. the correct language and currency);
  - Delivering you our newsletter (if you have subscribed to one);
  - Analyzing and improving our business activities;
  - Optimizing and improving the Website; and
  - Operating, managing, and promoting our business.
2. Legal grounds for processing of personal data. Depending on the circumstances in which you provide us with your personal data, the collection and processing of your personal data is carried out on the basis of one of the following legal grounds:
  - Ensuring the performance of a contract;
  - Pursuing our legitimate business interests; or
  - If you have provided us with your explicit consent for collection and processing of your personal data for a particular purpose.
Non-personal data
1. Types of non-personal data. When you use the Website, we collect certain non-personal data about your activities on the Website, such as your browser types, operating systems, URL addresses of websites clicked to and from the Website, and your other online behavior data. Such non-personal data does not allow us to identify you in any manner.
2. Purposes of non-personal data. We collect non-personal data for online analytics purposes only, such as:
  - To analyze what kind of users visit the Website;
  - To identify the channels through which the Website is accessed and used;
  - To examine the relevance, popularity, and engagement rate with regard to the content available on the Website; and
  - To personalize the Website to your specific needs.
3. Aggregated data. In case your non-personal data is combined with certain elements of your personal data in a way that allows us to identify you, we will treat such aggregated data as personal data.
Your consent
1. By using the Website, you are consenting to the processing of your personal data as set forth in this Privacy Policy.
2. In exceptional cases (where required by the applicable law), we will seek your consent. For example, we may seek your explicit prior consent for the following purposes:
  - If we would like to provide you with any marketing communication (e.g., sending you a newsletter);
  - If we intend to use your personal data for the purposes that are not indicated in this Privacy Policy;
  - If we would like to disclose or transfer your personal data to third parties that are not indicated in this Privacy Policy;
  - If we intend to collect any sensitive data from you; or
  - If we significantly amend this Privacy Policy.
Marketing communication
1. We will not send you direct marketing messages, such as newsletters, brochures, promotions and advertisements, or contact you by any other means with the purpose to offer you our goods and services, unless you provide us with your prior explicit consent to receive such marketing messages.
2. Informational notices. Please note that the following informational notices sent by us on an “if-needed” basis do not fall within the scope of direct marketing communication that requires your explicit consent:
  - Information about the status of your order;
  - Information about our new goods and services that are closely related to the goods and services already used by you; and
  - Informational notices regarding updates of the Website, your privacy and security, and other important matters.
3. Opt-out from marketing communication. If you have provided us with your consent to receive direct marketing communication and, at some point, you would like to stop receiving such marketing messages, you can easily opt-out by:
  - Clicking on the “unsubscribe” link contained in any of the online marketing communications submitted to you; or
  - Contacting us directly by email at info@2beco.me
Children’s privacy
1. The Website should not accessed by persons under the age of 16 years.
2. If a person under the age of 16 years has provided us with personal data without obtaining parental or guardian consent in advance, the parent or guardian may contact us and request us to destroy the personal data.
Protection of personal data
1. We implement organizational and technical measures to protect your personal data, such as secured networks, encryption, and limited access to your personal data by our staff.
2. In order to ensure the security of your personal data, we kindly ask you to keep your Website login details in a secure and confidential manner and use the Website only through a secure network.
3. Security breaches. Please note that, due to the inherent risks of using the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances beyond our reasonable control. In case a personal data breach occurs, we will inform British Data Protection Authority without undue delay and immediately take reasonable measures to mitigate the breach, as stipulated in the applicable law.
Storage of personal data
1. We will store your personal data in our systems only for as long as such personal data is required for the purposes indicated in Section 3 of this Privacy Policy.
2. After your personal data is no longer necessary for such purposes, we will immediately delete your personal data from our systems.
3. In some cases, we may be required by law to retain your personal data for a certain period of time (e.g., for maintaining our accountancy records). In such cases, we will store your personal data for the time period stipulated by the applicable law.
Disclosure of personal data to third parties
1. In certain situations, on a “case-by-case” basis, we may disclose your personal data to third parties. Such a disclosure is limited to the situations when the personal data is required for the following purposes:
  - Ensuring the operation of the Website;
  - Ensuring the processing and completion of your orders;
  - Pursuing our legitimate business interests;
  - Carrying out our contractual obligations;
  - Law enforcement purposes; or
  - If you provide your prior explicit consent.
2. Your personal data may be disclosed to third parties that provide professional, technical, and other types of support to us, including:
  - Our web developing partners;
  - Our hosting and data storage provider SiteGround;
  - Our SaaS provider G Suite;
  - Our user information logistics provider Google Analytics;
  - Our customer notification and instant communication provider Tawk;
  - Our CRM and marketing partner Hubspot;
  - Our marketing partners and mailing service provider MailChimp;
  - Our transactional mailing service provider Sparkpost;
  - Our logistics partners GLS, DHL, DPD and NordPost; and
  - Our payment service providers PayPal and Stripe.
3. The third parties listed in this section 10 will access your personal data as a part of their partnership with us and only if they agree to ensure an adequate level of protection of personal data that is consistent with this Privacy Policy.
Transfer of personal data outside the EEA
1. Please note that some third parties listed in Section 10 of this Privacy Policy may be located outside United Kingdom and the European Economic Area (EEA) and we may need to transfer your personal data to jurisdictions outside the EEA.
2. In case it is necessary to make such a transfer, we will make sure that the jurisdiction in which the recipient third party is located ensures an adequate level of protection of your personal data or we conclude an agreement with the respective third party that ensures such protection.
Your rights
1. You can manage your personal data collected and processed by us and request us to:
  - Access your personal data that we retain;
  - Move your personal data to another processor;
  - Delete your personal data from our systems;
  - Object and restrict processing of your personal data;
  - Withdraw your consent; or
  - Process your complaint.
2. If you would like to exercise your rights listed in this section 12, please contact us by email at info@2beco.me. We may ask you to provide us with an identifying piece of information, so that we would be able to identify you in our system. We will answer your request within a reasonable timeframe but no later than 2 weeks.
3. Lodging a complaint. If you would like to lodge a complaint about the way in which your personal data is handled by us, we kindly ask you to contact us first. After you contact us, we will investigate your complaint and provide you with our response as soon as possible. If you are a resident of the EU and you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.
Third-party links
1. The Website contains links to the websites owned and operated by third parties (e.g., social media providers). We are not responsible for the privacy and security practices of those third-party websites and this Privacy Policy does not apply to any of such websites. Please note that it is your sole responsibility to familiarize with the privacy practices of such third-party websites before using them.
Cookies
1. The Website uses cookies. By using the Website, you agree to our use of cookies as described in this Privacy Policy. If you do not agree to our use of cookies, you need to either discontinue your use of the Website or set your browser to refuse cookies. Please be aware that some parts of the Website may not function properly and some services may not be available without cookies. We will not use cookies for purposes, which are not mentioned in this Privacy Policy.
2. What is a cookie? A cookie is a small computer file, typically consisting of letters and numbers. When you visit a website, the website may send a cookie to your browser. Subsequently, the browser may store the cookie on your computer system. The main purpose of cookies is to allow a website to recognize user’s device. There are two types of cookies, namely, persistent cookies and session cookies. Persistent cookies remain valid until their expiration date, unless deleted by the user before that date. Session cookies will be stored on a web browser and will remain valid until the moment when the browser is closed.
3. What cookies do we use? We use session cookies, such as PHPSESSID, which allow you to use the full functionality of the Website. Session cookies are used in order to verify your details until you are navigating from page to page on the Website. The session cookies enable you to avoid re-entering your details each time you enter a new page on the Website. We also use persistent cookies, such as “language”. We use persistent cookies in order to recognize you as a unique user when you return to the Website. As a result, you do not have to enter your login details multiple times as you move from other websites to the Website.
4. How to refuse cookies? If you would like to refuse our use of cookies, you can do so by disabling cookies in your browser (please check your browser’s “help” functionality for more information) or visiting www.whatarecookies.com for further information.
5. Google Analytics. We use Google Analytics to analyze your use of the Website. Google Analytics generates statistical and other information by means of cookies and we use its services to create reports about the use of the Website and the Services and to collect data via advertising cookies and identifiers. We use the following Google Analytics features: (i) Remarketing with Google Analytics; (ii) Google Display Network Impression Reporting; (iii) Google Analytics Demographics and Interest Reporting; and (iv) Integrated services that require Google Analytics.
6. Opting-out from Google Analytics. If you would like to opt out from Google Analytics, you can do so by installing a Google Analytics opt-out browser add-on available at tools.google.com/dlpage/gaoptout.
Amendments
1. We reserve the right to amend this Privacy Policy from time to time. The amended Privacy Policy will be posted on this page and the date of the last amendment will be indicated therein. We encourage you to review the Privacy Policy regularly.
2. If you continue using the Website after the date of the last amendment, your usage of the Website will constitute your acknowledgment of the amendments and your consent to abide and be bound by the amended Privacy Policy.
3. For significant changes in the Privacy Policy, or where required by the applicable law, we may seek your explicit consent to the changes stated in the Privacy Policy.
4. Last amendment. This Privacy Policy was last amended on 23rd of May 2018.
Translations
1. The original language of this Policy is English. While several translations may be provided by us for your convenience, in case of any discrepancies, the English version shall supersede other versions.
Contact us
1. If you have any questions about this Privacy Policy or would like to receive further clarifications, you can contact us by using the following contact details:
  - Company name: Boston Education Company Ltd
  - Address: 128 City Road, London EC1V 2NX, United Kingdom
  - Email address: info@2beco.me
  - Phone number: +44 794 34 24 757
  - Contact form: Contact Form

This Privacy Policy was last updated on and is effective from 25th of May 2018.