Privacy Notice

This privacy notice explains:

• How we collect, use and store your personal data when you visit our website, subscribe or register, submit a form, or sign up for any of our services.
• Your privacy rights pursuant to the Data Protection Act 2018, UK GDPR and EU GDPR (together, the “Data Protection Laws”).

About Us

Inova Training provides workshops, training sessions, mentoring and coaching on topics such as career development, intercultural competencies, entrepreneurship, and personal growth for students, young professionals, organisations, and the general public.

Inova Education promotes higher education opportunities in the United Kingdom, Netherlands and Ireland and act as a representative agent for partner universities in those countries. We operate across Latin America, supporting prospective students through counselling, application assistance, document translations, visa support, and travel preparations. In addition we promote universities and organise events such as webinars, collaborative fairs, presentations, counselling and training sessions, often partnering with  universiteies, funding providers, English exam organisations and other parties.

Our Role: Controller and (for application submission) Processor

Controller: For the personal data you provide directly to us (e.g., via forms, registrations, events, social media lead campaigns, or service sign-ups), and for the information we manage in our own systems when providing counselling and application-support services, we are the data controller. This means we determine how and why your personal data is used for our services.

Processor (submission to universities): Where you instruct us to submit an application to a university on your behalf, we may enter your information and upload supporting documents into the university’s application portal. For this submission activity, and where required under our agreement with the university, we act as a data processor for the relevant university and process your personal data on its instructions. For admissions purposes, the relevant university will act as the data controller and we may act as a processor for the submission activity, as described above. We remain a controller for the copy of the information we hold in our own systems for the purposes described in this Privacy Notice.

Data Protection Officer: We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to your data. If you have any questions about how we process your data, including any requests to exercise your legal rights you can contact our DPO on dpo@inovatraining.com.

Types of personal data

Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed. This is known as anonymised data. Anonymised data falls outside the scope of Data Protection Laws.

We may collect, store and process different types of personal data about you which we have grouped together. The types of data we process will depend on your relationship with us, including:

• Identity Data: Name, username or similar identifier and title.
• Contact Data: Email, phone, billing and delivery addresses
• Educational Data: Academic background, course and university interests, language proficiency, study preferences
• Financial Data: Payment card or bank details
• Transaction Data: Payment history and other details for the provision of services you have purchased from us.
• Technical Data: IP address, device info, login data, 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 our website.
• Profile and Usage Data: Account preferences, surveys, feedback, website usage.
• Marketing and Communication Data: Communication preferences , consent for updates.

We do not generally process special categories of personal data (e.g., health information) unless you give explicit consent, for example for event accessibility or university applications.

How we collect your personal data

Directly from you: You give us your personal data in your direct interactions with us through forms, registrations, events, social media messaging, WahtsApp, email, phone, or in-person interactions.

From our website: We gather information and statistics collectively about visitors to our website. Analysis of this information demonstrates the most frequently used sections of the website and assists us in continually improving the online service. You give us your personal data, which includes Profile Data, Usage Data, Technical Data and/or Marketing and Communications Data when you use our website or which we have agreed with you to use or when you review any publications or marketing material we send you. Please see our cookies notice for more information.

Indirectly, from third parties: Universities, educational institutions, government bodies, or other organisations when necessary to provide our services. For instance, other parties such as a university send us your personal data to enable us to provide our services to you or you provide your personal data to a third party for example a university or other organisation for the purpose of sharing it with us.

Providing personal data is voluntary but may be necessary to deliver services. Where we need to collect personal data, including data collected by law or where necessary to take steps at your request or to provide you with services you have requested, and you do not provide that information when requested, we may not be able to provide those services. In this case we may have to cancel or limit our service but we will notify you if this is the case at the time.

How we use your personal data

We only use your personal data where permitted by law. Under the Data Protection Laws, the lawful bases we rely on are:

• Performance of a contract: Where we need to take steps at your request prior to entering into a contract, or to perform a contract we have entered into with you (for example, when you sign up to our services, and when we provide counselling and application-support services you request).
• Legal obligation: Where we need to comply with a legal or regulatory obligation (for example, for accounting, tax, fraud prevention, or responding to lawful requests from authorities).
• Legitimate interests: 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 rely on legitimate interests, we consider the impact on you and your rights.
• Consent: We do not generally rely on consent as a legal basis for processing your personal data. Where we do rely on consent (for example, where required for certain marketing communications, or where you voluntarily provide special category data such as accessibility requirements), you have the right to withdraw consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before you withdrew it. To withdraw consent, please contact us at dpo@inovatraining.com or use the unsubscribe link in our marketing emails.

Examples of processing include:

• Administering events, fairs, presentations, counselling sessions, and webinars, including registrations and attendance management.

• Providing counselling, guidance, and application-support services that you request.

• Submitting your application information to universities at your request/on your instruction (including entering information into university application portals and uploading supporting documents) and managing such applications. Please note that, for this submission activity, the relevant university will act as the data controller for admissions purposes and we may act as a processor on the university’s instructions, as described in the “Our Role: Controller and (for application submission) Processor” section.

• Responding to enquiries, feedback, or complaints.

• Sending service-related updates and relevant educational information (such as events, webinars, scholarship and funding opportunities, English language exam information, and university programme updates), subject to your communication preferences and applicable law.

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 our DPO at dpo@inovatraining.com 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 provide you with our services.	(a) Identity (b) Contact	Steps at your request prior to entering into a contract, and/or performance of a contract with you (where applicable).
To respond to any enquiries.	(a) Identity (b) Contact	(a) Steps at your request prior to entering into a contract, and/or performance of a contract with you (where applicable). (b) Necessary for our legitimate interests (to respond to enquiries and provide information requested).
To provide application-support services and submit application information and supporting documents to selected universities at your request/on your instruction.	(a) Identity (b) Contact (c) Educational (d) Profile (e) Special Categories (where provided, e.g., accessibility requirements)	Steps at your request prior to entering into a contract, and/or performance of a contract with you (where applicable). For the submission activity, the relevant university will act as controller for admissions purposes and we may act as processor on the university’s instructions (as described in this Privacy Notice).
To process and deliver our services to you including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction	(a) Steps at your request prior to entering into a contract, and/or performance of a contract with you (where applicable). (b) Necessary for our legitimate interests (to recover debts due to us).
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy notice (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Steps at your request prior to entering into a contract, and/or performance of a contract with you (where applicable). (b) Necessary to comply with a legal obligation (where applicable). (c) Necessary for our legitimate interests (to keep our records updated and to understand how users engage with our services/website).
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 (where applicable).
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to understand how users use our website/services and to improve our communications), and where required, consent for advertising/analytics cookies or similar technologies (see our cookies notice).
To use data analytics to improve our website, services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to understand how users engage with our website/services, to keep our website updated and relevant, and to inform our communications). Note: Where applicable, consent will be used for data analytics obtained through cookies or similar technologies. See our cookies notice.
To make suggestions and recommendations to you about our services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to provide relevant information about our services). You can opt out of marketing communications at any time.

Marketing communications

We may contact you about events, webinars, funding opportunities, English language exams, and university programmes that are relevant to your expressed interests and enquiries.

You can opt out at any time via the unsubscribe links in our communications or by contacting us at dpo@inovatraining.com.

Right to object: Where we process your personal data for direct marketing, you have the right to object at any time, and we will stop using your personal data for that purpose.

Note: Our communications are strictly educational and service-related. We do not send promotional content unrelated to training, education or our services.

How we share your personal data

We do not sell any of your personal data to any third party. We may have to share your personal data with the parties set out below:

• Internally: Our employees or contractors who are working on providing your services to you on a need-to-know basis.
• Universities and Partners: If you request our application support, we will share your information and documents with the universities we represent and which you select and/or submit them via their application portals, at your request and on your instruction. For admissions  purposes, the relevant university will act as the data controller and we may act as a processor for the submission activity, as described above. We may also share your personal data with other third parties, such as student finance and funding providers, English language providers, carefully selected project partners, and other voluntary agencies. If we do, this will be as necessary to provide the services you have requested from us (or at your request). Where we rely on consent for any such sharing, you can withdraw that consent at any time. We will require universities and all other third parties to respect the security of your personal data and to treat it in accordance with the law.
• Suppliers: This would include service providers who support our business including IT and communication suppliers, and outsourced business support providers such as consultants or CRM software providers to ensure our service runs smoothly.
• Payment facilitation suppliers: This would include service providers, which provide the solutions for you to pay us for example via Stripe and Paypal.
• Professional advisers: This would include lawyers, bankers, auditors, and insurers.
• Law enforcement bodies, regulators and other authorities: This is to comply with our legal requirements or adhere to good practices.
• Advertising networks and analytics service providers: This is to support and display ads on our website and other social media tools.
• Third parties context of sale: This is in the context of the acquisition or transfer of any part of our business or in connection with the business reorganisation. If a change happens to our business then the new owners may use your personal data in the same way as set out in this privacy notice.

International transfers

We may transfer and process your personal data outside of the United Kingdom (UK) and/or European Economic Area (EEA). Where we make a restricted transfer, we will use appropriate safeguards for such transfers, which may include the UK Information Commissioner’s Office (ICO) International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses (as applicable), and/or other Article 46 UK and EU GDPR safeguard mechanisms endorsed by the UK Government or European Commission.We may also carry out a transfer risk assessment where required.

To find out more about the safeguards used for a particular transfer, please contact us at dpo@inovatraining.com.

Data Security

We take reasonable measures to protect 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.

The transmission of information via the internet is not completely secure. Although we will take reasonable measures to protect your personal data, we cannot guarantee the security of your information transmitted and any transmission is at your own risk.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Data Retention

We retain personal data only as long as necessary to provide our services, meet legal requirements, or resolve disputes.

To determine the appropriate retention period for personal information we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means and the applicable legal, regulatory, tax, accounting or other requirements.

We may anonymise your personal data so that it can no longer be associated with you for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Data Subject Rights

Under certain circumstances, you have rights under Data Protection Laws. You can:

Request access to your personal data: This is known as a “data subject access request” and enables you to receive a copy of the personal data we hold about you.

Request correction of your personal data: This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal data: This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note: We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you at the time of your request.

Object to processing of your personal data: This is where we are processing your personal data based on a legitimate interest or those of a third party and you may challenge this.  However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to any legal claims.  See also Marketing communications.

Request restriction of processing your personal information: This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the information’s accuracy (b) where our use of the information is unlawful but you do not want us to erase it (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.

Request transfer of your personal information (“data portability”): This is where in some circumstances we will provide to you or a third party you have chosen your personal data in a structured, commonly used, machine-readable format.

Right to withdraw consent: This is where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. Depending on the processing activity, if you withdraw your consent we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Automated decision making:  This is where decisions are made about you by automated means. We do not carry out automated decision making.

Keeping personal information accurate and current

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.

Carrying out your data subject rights

You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information or to exercise any of your other rights. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you wish to exercise any of the rights set out above, please contact our DPO at dpo@inovatraining.com.

Concerns and complaints

We would appreciate the chance to deal with your concerns in the first instance. Please contact our DPO at dpo@inovatraining.com. If you have unresolved concerns and you live or work in the UK, you have the right to complain at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

If you live outside the UK, you may also have the right to lodge a complaint with your local supervisory authority.

Changes to our privacy notice

This privacy notice may be changed from time to time in response to legal, technical or business developments. We will take appropriate measures to inform you when we update our privacy notice. We will obtain your consent to any material privacy notice changes if and where this is required by applicable Data Protection Laws.

Contact us

If you would like more information about the way we manage personal information that we hold about you, please contact Inova Training (a trading name of Inova Consultancy Ltd) by email at dpo@inovatraining.com. Our postal address is: Inova Training, Spaces, Pennine Five, Block 2, 1 Tenter Street, Sheffield, S1 4BY, United Kingdom.

This version was last updated on 19 August 2024