Privacy Policy - The Student Promise

The Student Promise handles your personal data with care and in line with relevant data protection legislation, such as the Data Protection Act 2018; the General Data Protection Regulation, the Law on Protection of Personal Data No 6698 and other laws and regulations. In this Privacy Statement we explain who we are, what personal data we collect and for what reasons, how we handle this personal data and what rights you have with regards to your personal data. This Privacy Statement is intended for website visitors and users of our platform.

1. Who are we and what do we do?

The Student Promise is a brand owned by:

EPSN Workforce S.à r.l. 5iè9e social 153-155 rue du Kiem 8030 Strassen Luxembourg Chamber of Commerce: 8187491

This brand is licensed to:

The Student Promise LTD Station House North Street Havant PO9 1QU England

The Student Promise is seen as the ‘Data Controller’. It has subsidiary offices in five countries: the Netherlands, Spain, Romania, Turkey and India. The current generation of students and starters look at their careers in a different way. To them, a job is much more than a job; it’s a way to realise personal ambitions. This can be achieved by developing your personal skills, by making money or by meeting new people. The Student Promise guides you on this journey, helping you understand your best personal and cultural fit and allowing you to apply for jobs with different companies worldwide. The Student Promise is thus the enabler for your personal ambitions.

2. What personal data do we collect?

The Student Promise collects different categories of personal data about you, sometimes dependent on which stage in your journey you are in.

Contact Information

We collect your first and last name, email address, postal address, phone number and other similar contact data.

Financial Information

We collect information needed for invoicing, such as your bank account number or credit card information and if needed additional information such as BIC numbers.

Academic Information

We collect your education data such as university, year of study as well as grade you achieved.

Employment Information

We collect data about current and previous employment. We also collect data about your preferred employers and employer types.

Assessment results & profile

We collect your assessment outcomes. We collect data about you such as your age, gender, country and preferred language. We collect data about you, your interests and hobbies and other elements to help build a digital profile.

Sensitive Information

We collect sensitive personal data which may include details of your health condition. This is for the purposes of fairer assessment. Providing this information is entirely optional and it will not affect the scores or how your profile is presented. We only collect sensitive data with explicit consent.

Device & Account information

We collect passwords and similar security information used for authentication and account access and data about your device and how you and your device interact with The Student Promise products.

Social Media information

You may choose to login to the TSP platform using social media profiles, such as Facebook or LinkedIn. You may also choose to share your journey through social media, including Facebook, LinkedIn, Twitter and Instagram.

The Student Promise obtains your personal data from you directly, though in some cases an intermediary is used (for example for assessments).

3. Why do we need your personal data?

The Student Promise aims to help you on your journey to a dream job. In order to do so, we need to know some things about you.

  • We need contact information in order to stay in touch and keep you up to date about your progress.

  • We need financial information in order to invoice your subscription.

  • We need information about your personality, likes and dislikes, in order to effectively match you with different companies and cultural environments.

  • We may need sensitive information, including information about your health, in case this may affect your ability to take and complete assessments, or may impact your cultural fit.

The personal data is processed based on our contractual relationship (including the pre-contractual phase), a legal obligation, our legitimate interest or your consent.

4. How do we use personal data?

Depending on the exact services you choose to use, we will collect personal data about you. We will use this personal data to provide you with the desired service, for example a personality assessment.

The personal data gathered throughout your journey is used to build a profile, to help match you to suitable employers and opportunities.

Additionally, we may use your information to send you e-mails or push notifications, but only if you want us to. If you don’t, you can manage your contact preferences in your own profile.

Please see below to find out more about the way your personal data is used for particular services:

  • Orientation: this service includes general information about what will happen after leaving University; how to find a job in general; how the labour market works; what it means to live abroad; the situation of the labour market in the chosen country and do’s and don'ts about commercial services.

  • Culture Fit: this service includes information about what type of company and national cultures exist and which culture you are most suited to, including: The Culture Map; Hofstede Insights; Company Culture.

  • Personal Fit: this service will provide you with a deep(er) understanding of your personality and the skills that you can offer to a company and how to offer them. This service includes the following tracks: Knowing yourself; Why assessments; Interests assessment; Building a profile; Benchmark my CV; Making my own video presentation.

  • Company Fit: this service will ensure that you apply for your dream job and that your contract matches the market requirements. For this purpose, you will complete the following paths: The right job; Career investigation; Jobmatching; Applying; How to do an Interview Contracts; Negotiation; Benchmark my contract.

  • 300 plus E-learnings: this service includes access to 300+ e-learning modules, such as Communication Essentials; Office 365 or Managing Stress.

5. How long do we keep your personal data?

The Student Promise will store and use your personal data throughout your journey. Once your journey has been completed and your contract with TSP has ended, we will only store your personal data in line with our internal retention policies and legal requirements.

This means for example, that your financial information (in the Netherlands) will be stored for up to 7 years, whilst we will only retain your other account information for one year after your subscription ends.

6. Who is your personal data shared with?

The Student Promise is hosted on Microsoft Azure; this has been allocated to the Western Europe zone and more specifically Amsterdam.

The Student Promise has several partners who integrate with the platform at different levels.

  • Level 1: Partners who offer functionalities that are necessary to make the TSP services available to consumers.

  • Level 2: Partners who provide technical infrastructure components where the TSP Proposition is realized.

  • Level 3: Partners who provide analysis functionalities to collect and analyze user behavior for TSP.

  • Level 4: Content and engagement partners who offer functionalities to share content from TSP with other consumers (whether or not affiliated with TSP).

PARTNER LEVEL DESCRIPTION OF SERVICES Eloomi 1 E-learning tracks Joboti 1 E-learning tracks SHL 1 Occupational personality assessment Hofstede 1 Culture compass assessment Stripe 1 Payment services provider Careerjet 1 & 2 Specific vacancies for the user on the platform (1) & international jobboard (2) Xero 2 Software for the financial administration of user payments Sendgrid 2 Transactional e-mails between User and TSP ActiveCampaign 2 Marketing Automation Contentful 2 Content management Microsoft Azure (B2C) 2 Cloud platform & technical building blocks for TSP & Login functionality TSP platform (B2C) Elasticsearch 2 Semantic search engine to create job-matches Whatsapp 2 Chat functions in the platform Google Analytics 3 Statistical analysis of user behaviour & campaign engagement Microsoft PowerBI 3 Collects user behaviour for TSP specific monitoring dashboards AddThis 4 Social sharing partner, allows you to share data from TSP to different social media channels Facebook 4 Social media platform users can share results to & Users can also login to TSP using their Facebook account. Twitter 4 Social media platform users can share results to Instagram 4 Social media platform users can share results to LinkedIn 4 Social media platform users can share results to & Users can also login to TSP using their LinkedIn account Internations 4 Expat network Users can join to meet likeminded individuals [No direct data or content integration at the moment] Youtube 4 Media platform which is used to share videos, by TSP or partners with useful content. VIMEO 4 Media platform which is used to share videos, by TSP or partners with useful content.

Additionally, The Student Promise will share your personal data with the companies that you apply to. In this case, the decision to apply is entirely up to you.

As The Student Promise operates worldwide, data may be transferred outside of the European Union/European Economic Area. In principle all data is stored in the Netherlands by our hosting company and is accessible for use by our office in the United Kingdom, as well as our employees in offices worldwide. In order to ensure adequate safeguards, Standard Contractual Clauses are agreed with all our offices.

For international transfers in relation to applications, these are based on the need for the transfer to occur, in order to provide you with the services which you have obtained from us, based on the contractual agreement we have with you. In this case you are in control of which companies you will apply to and where these companies are located.

7. How do we protect your personal data?

The Student Promise has taken both organisational and technical measures to protect your personal data. Organisational measures include an internal privacy policy, a data subject rights procedure, data breach procedure, DPIA procedure and awareness activities and training for employees.

Technical measures include the following:

  • The exchange of information between the user and the TSP is exchanged via a secure and encrypted HTTPS (TLS 1.3) connection. The information that is exchanged within the TSP is also exchanged over a secure and encrypted HTTPS (TLS 1.3) connection.

  • The platform has several security zones, so that even if one of the layers is penetrated, the other layers are not affected.

  • User accounts and profile data are protected and stored in encrypted form in Microsoft Azure B2C. Microsoft Azure B2C offers highly proactive denial-of-service, security and intrusion measures to secure user data. This data is stored in encrypted form for each individual user.

  • Functional data resulting from the user's interactions with the TSP Platform is also stored in encrypted databases but is not stored in encrypted form per user.

  • The Azure Web Application Firewall (WAF) is used, which ensures that exploits, vulnerabilities and malicious actions are analysed and stopped. This is not a guarantee that malicious actions are prevented, however significant measures at the platform level are required to achieve this.

  • All interactions between the TSP Website, TSP Apps and integration with Level-1 partners is done through the Azure API Gateway. A WAF is used via this API Gateway, just like with the TSP Website. Only authorised users can access authorised information with party-provided authorisations.

  • Access to the PowerBI dashboards is only possible with a personal account of the TSP employee. These accounts are not linked to the TSP Website and are stored in a separate Azure Active Directory identity provider. Access to data can be protected at user group level by means of roles and rights.

8. What rights do you have?

As The Student Promise wants to ensure all our users are treated equally, regardless of geographical location, we have decided to apply the rights as included in the GDPR to all our users.

This means that you have a right to:

  • Access your personal data and obtain a copy of the data we hold;

  • Rectify any data which is incorrect, outdated or incomplete;

  • Restrict processing of your data awaiting correction or a decision;

  • Ask us to delete your personal data;

  • Object to the use of your personal data (in some cases);

  • Withdraw your consent (when applicable);

  • Obtain your data in a machine-readable format to transfer it to another service provider;

  • Not be subjected to automated decision-making.

It is possible that in your country additional rights exist with regards to your data (for example, being allowed to indicate what happens with it if you die). If this is the case, you can send us a request to implement this right and we will honour your requests.

9. Who can you contact with questions?

If you have any questions for example about your subscription or the platform, concerns, complaints or if you want to exercise your data subject rights, you can contact The Student Promise via support@thestudentpromise.com.