Terms and conditions

Terms and Conditions

We are Go Abroad Study Programs Pte. Ltd. and we look forward to the opportunity to act as your booking agent for your semester abroad. These terms and conditions (the "Agreement") describe what you are legally entitled to expect from us when you purchase services through us, in addition to your obligations as a customer. The terms "we", "us" and "our" refer to Go Abroad Study Programs Pte. Ltd. The term "you" refers to the customer visiting our websites, booking through us or otherwise using our services

Please read these Conditions carefully. They apply to all applications and bookings made through us. We are acting as as intermediary or agents on behalf of different suppliers and service providers (“Suppliers") for products and services that are not directly supplied by us. We are not a co-vendor of such products and services. You are contracting with the suppliers, whose terms and conditions apply to your application or booking. Copies of those terms and conditions are available upon request from the supplier. Certain software and content found on our website are owned or licensed by us or our Suppliers, your use of which may be subject to further conditions.

These conditions govern your relationship with us. The person making the application or booking must be at least 18 years of age and must be authorised to make the application or booking on behalf of the members of the party. The person making the application or booking must also provide a copy of these booking conditions to the other members of the party.

The Contract

After we have received your application fee, deposit or full payment (if applicable) and we have issued a confirmation invoice, a contract will exist between you and each of the suppliers, effective from the date printed on your invoice. The terms and conditions of each supplier you have applied for or booked with will apply to your booking. Once the contract(s) is made, the supplier is responsible for providing you with what you have booked.

Agency

We are acting as as intermediary or agents on behalf of different suppliers and service providers (“Suppliers") for products and services that are not directly supplied by us. In doing so we give no warranty nor make any representation regarding the services to be supplied or the products purchased by you. Your application or booking will be subject to the terms and conditions applied by the provider of the service or products. You agree that if the services or products are not supplied in accordance with your application ore booking your remedy lies with the service provider and not with us.

Prices

Every effort is made to ensure that the prices quoted to you are correct; however we act only as an agent and rely on information provided to us from the suppliers of the services and products. We will bring to your attention any change in price made prior to you completing your application or booking and paying the balance of the price. Please note some supplier and service providers reserve the right to increase the price of your arrangements due to increases in fares, fees and currency fluctuations.

Alterations made by you

If you want to change any part of your application or booking, we will do all we can to help. However, the suppliers are under no obligation to make any change, although with reasonable notice (usually more than four weeks), changes may be possible. If a supplier is able to make a change, we will charge an administration fee per application or booking as set out in the attached schedule of fees.

Cancellation Fees

If you cancel your booking you may incur a cancellation charge from the supplier. The amount of this charge will vary depending on when the cancellation is made and the terms and conditions of the supplier of services or product. We do not guaranty that any refunds will apply. If you are entitled to a refund please note we are unable to provide you with funds until they are received from the supplier. We are not responsible for a Supplier’s failure to pay a refund. We will charge a cancellation fee per application or booking as set out in the attached schedule of fees.

Promotions

Invite a friend Promotion The cash-reward promotion is a promotional activity from Go Abroad Study Programs Pte. Ltd. and doesn't affect or reduce the Udayana University tuition fee, which must be paid in full by every student. The inviting student can receive, for a maximum of 4 times, a 25% refund on the paid tuition fee by inviting other students if the invitation meets all of the following conditions:

The inviting student shares the unique invitation code mentioned in his/her myUNUD account
The inviting student paid the tuition fee
The inviting student started to study at Udayana University
The invited student mentioned the unique invitation code of the inviting student in his/her application
The invited student started to study at Udayana University in the same semester as the inviting student

If any of the conditions is not applicable, a refund can’t be issued. The maximum refund an inviting student can receive is 100% of the paid tuition fee.  The refund will be transferred to the inviting student’s bank account 2 weeks after the start of the semester in which the inviting student started to study. Therefore it is the student’s responsibility to provide Go Abroad Study Programs Pte. Ltd. with the international bank account details of the receiving account.

Liability

As we are only acting intermediary or as an agent we have no liability in respect of the supply of any element of your application or booking, including any liability for illness, personal injury, death or loss of any kind, delay and inconvenience caused directly or indirectly by any provider of services or products or by other third parties unless caused by our negligence. Any claim for damages for injury, illness, loss or death must be brought against the relevant supplier of the services or products. Nothing in these terms and conditions shall be read as excluding, restricting or modifying rights under the Trade Practices Act and other legislation given to consumers in relation to the supply of goods and services.

Force Majeure

We shall not be liable for any loss or damage incurred by you as a consequence of us or any of the suppliers being unable to perform its obligations under your contract(s) due to the unusual or unforeseeable circumstances (a “force majeure event”) beyond the control of the party affected by the force majeure event.

Travel Insurance

We strongly recommends that you take out comprehensive travel insurance at the time of paying an application fee or deposit. The policy should provide cover for loss of deposit, cancellation and additional expenses, medical expenses and repatriation and loss or damage to baggage and valuables. You are responsible for making any special or increased insurance arrangements which you deem are necessary.

Service Fees

We may at our discretion charge service fees on your booking. Our service charges are set out in the attached schedule of fees.

Payment by Credit Credit or PayPal

Card surcharges may apply to payments made by credit card or PayPal. In the event you pay by credit card or PayPal but the services are not provided by a third party provider of services or products you agree that you will not take steps to charge back your payment to us.

Passport and Visas

It is your sole responsibility to ensure you have a valid passport at the time of travelling and that you hold all necessary visas and permits. Some countries require you when entering to hold passport with at least six months validity.

Complaints

We hope you will have no reason to complain but if you are unhappy with any aspect of the services provided you must report it immediately to the supplier, or contact us. We shall attempt to resolve the matter immediately but if you remain dissatisfied you must write to us within 7 days from the end of your booked service. Failure to complain in time may mean we will be unable to resolve the dispute. Consultancy fees may apply for advising you how to solve your dispute with the supplier. We do not guaranty that disputes can be resolved.

Data Protection

In order to process your application or booking we need to pass your details to the relevant suppliers. We will take all reasonable precautions to ensure the security of that information. We may also use the information you provide for marketing purposes and, if you do wish to receive any further information, please inform us or read more in our Data Protection Policy (https://myunud.gobali.org/api/document/data-protection-policy).

General

We reserves the right to alter these terms and conditions at any time.

Governing Law

Your contract with us is governed by the laws of Singapore and you agree to submit to the jurisdiction of the courts of Singapore to determine any dispute pertaining to the contract.

Appendix

Udayana University Terms and Conditions

Responsibilities of Udayana University Udayana University is fully responsible for all class ofGoBali program. This includes direction, contents, lectures as well as the granting of credit points for passed courses. Udayana University remains the right to change contents of lectures. Udayana University aims to inform students about possible changes.

Application for the GoBali program The applicant should be fluent enough in English to understand lectures in English language. Applications are reviewed in the order they are received. Application is possible either until the deadline stated on the GoBali website or until the program is full, whichever comes first. The number of participants to the program is limited. The application deadlines are obligatory. Applications after the deadline cannot be reviewed. The minimum number of participants in the GoBali program is 15.

Application and Payments To apply for Udayana Universities GoBali program, the application form on the GoBali website (managed by our partner Go Abroad Study programs) must be filled out. This application is binding. Directly after the application Go Abroad Study Programs e-mails by order of Udayana University a confirmation of application containing a personal number as well as an invoice for the application fee of 49€ which goes to Go Abroad Study Programs as their fee to process the application. This application fee has to be paid no later than 14 days after application. If there is no receipt of payment after 14 days, the application – and thereby the reservation of the university place – becomes null and void. After receipt of payment of the application fee an e-mail will be sent regarding the acceptance or denial to the program. This e-mail also contains the invoice for the Udayana University tuition fee. The contract becomes binding with the receipt of this e-mail. The tuition fee has to be remitted to the bank account of Go Abroad Study programs as our payment process partner no later than eight weeks before the start of lectures. The student’s name in full as well as the matriculation number received from GoBali must be stated with all payments.   The Udayana University tuition fee covers the registration fee for the university, the tuition fee, the exam fee, and expenses for tuition material. It does not cover the flight and other travel expenses, accommodation, expenses for food, insurances, visas, vaccinations as well as costs for medical care, further course material like books etc.  Absence If the student does not take part in lectures and does not follow the rules of Udayana University, he or she is not entitled to get a refund of the tuition fee or to extend his or her participation in the GoBali program.

Attendance Attendance at lectures is compulsory. An attendance rate of 75% is needed to be admitted to the final exams.

Certificates The student will receive the official certificate in digital form (PDF) approximately 8-10 weeks after the final exams to the email address stated in the application.  On request, the original certificates can be delivered via DHL Express to the student. The student will be charged with the additional costs, which he has to provide together with the address before the official end of the semester.

Cancellation Cancelling your application until 31.1. for the summer semester and until 30.6. for the winter semester is free. In that case please send an email to info@gobali.org in order to inform us, containing your name and matriculation number. If your cancellation is made between 1.2. until 28.2. for the summer semester and between 1.7. until 31.7. for the winter semester, 50% of the tuition fee will be refunded. If you cancel later than 1.3. for the summer semester or after 1.8. for the winter semester or break off your studies in Bali, no refund of the tuition fee is possible. A transfer of the University place to another person is not possible. A number of at least 15 students is needed by application deadline in order to run the GoBali program. The program can be canceled by Udayana University if the minimum number of students is not reached. In this case the payed tuition fee will be fully refunded. The transfer fees for refunded tuition fees will be paid fully by the student. Udayana University is not responsible for other cancelation costs like flight, visa, insurances, bookings etc.

Postpone You can postpone your registration 1 (one) semester ahead. The cancelation deadlines remain the same as for the initially applied semester. A refund of the tuition fees after passing the deadlines for the initially applied semester is not possible anymore. In case the tuition fee differs from the initially applied semester, the student has to bear the fee difference and all additional transfer costs.

Passport and Visa Every student has to arrange for a valid passport and visa as well as for accommodation and travel, the costs of which are the student’s concern. Udayana University is not responsible for obstacles in travel which are the result of missing or inadequate documents or insufficient travel preparation.

Insurance All international students participating in the GoBali program have to have a valid health and accident insurance. A travel health insurance is strongly recommended. Students are responsible for effecting all necessary insurances before the commencement of travel. Students are advised to inform themselves at their insurance company. An insurance covering the return transport to the respective home country of the student is especially important as Udayana University does not compensate for that.

Changes Udayana University reserves the right to change the study program and the fees after the conclusion of the contract between the student and Udayana University, if these changes are caused by reasons that cannot be affected by GoBali, like changes in official fees, taxes, currency rates, etc. Udayana University does not assume liability for literal errors and reserves the right to change contract conditions and information about the program. Udayana University aims to inform students about possible changes as quickly as possible.

Force Majeure  Udayana University does not take responsibility for failing to fulfill their obligations if the reasons for that are beyond control of Udayana University, e.g. in case of force majeure or strikes and the like. In case of force majeure no refund can be given. Udayana University offers the students in these cases to postpone their semester for free up to 1 year ahead by maintaining the deadlines for cancelations as for their original semester. Udayana University reserves the right to make changes.

Liability GoBali does not assume liability for personal injury, damage caused to someone’s health or property, and financial loss. GoBali does not assume liability for failing to fulfill their obligations if the reasons for that are beyond control of GoBali, e.g. in case of force majeure or strikes and the like.

Choice of Law and Legal Venue The law of the Republic of Indonesia is applied to the contractual agreements between the student and the University. The United Nations Convention on Contracts for the International Sale of Goods (CISG) cannot be applied. The venue for all legal dispute between the university and the student resulting from the contract is the domicile of Udayana University

Severability Clause If a provision of these terms and conditions is or becomes illegal, invalid or unenforceable, that shall not affect the validity or enforceability of any other provision of these terms and conditions.

Data protection policy

Data Protaction Policy

Go Abroad Study Programs holds Personal Data about our users, employees, clients, suppliers and other individuals for a variety of business purposes.

This policy sets out how we seek to protect Personal Data and ensure that staff understand the rules governing their use of Personal Data to which they have access in the course of their work. In particular, this policy requires staff to ensure that the Data Protection Officer (DPO) be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed.

Go Abroad Study Programs operates in several jurisdictions, including Europe, the United Kingdom and Singapore. This policy describes principles and procedures which ensure Go Abroad Study Programs complies with the various regulations across all the regions in which we operate.

The procedures described in this policy must be followed at all times by Go Abroad Study Programs, its employees, agents, contractors, or other parties working on behalf of Go Abroad Study Programs.

Go Abroad Study Programs is committed not only to the letter of the law but also to the spirit of the law and places a high premium on the correct, lawful and fair handling of all Personal Data, respecting the legal rights, privacy and trust of all individuals with whom it deals.

Scope

This policy applies to all staff. You must be familiar with this policy and comply with its terms. This policy supplements our other policies relating to internet and email use. We may supplement or amend this policy by additional policies and guidelines from time to time. Any new or modified policy will be circulated to staff before being adopted.

Our Data Protection Officer has overall responsibility for the day-to-day implementation of this policy.

Training

All staff will receive training on this policy. New staff will receive training as part of the induction process. Further training will be provided at least every year or whenever there is a substantial change in the law or our policy and procedure.

Training is provided through in-house seminars and online training on an annual basis, and covers the applicable laws relating to data protection, and Go Abroad Study Programs’ data protection and related policies and procedures.

Completion of training is compulsory.

If you have any questions or concerns about anything in this policy, do not hesitate to contact the DPO.

Applicable legislative considerations

UK Data Protection Act 1998 (DPA)

Under the UK Data Protection Act 1998, Personal Data is defined as data which relates to a living individual who can be identified from that data, or from that data and other information which is in the possession of, or is likely to come into the possession of, the data controller, and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.

The UK Data Protection Act 1998 also defines “sensitive Personal Data” as Personal Data relating to the racial or ethnic origin of the data subject; their political opinions; their religious (or similar) beliefs; trade union membership; their physical or mental health condition; their sexual life; the commission or alleged commission by them of any offence; or any proceedings for any offence committed or alleged to have been committed by them, the disposal of such proceedings or the sentence of any court in such proceedings.

Go Abroad Study Programs is registered with the Information Commissioner as a data controller under the register held by the Information Commissioner pursuant to Section 19 of the UK Data Protection Act 1998.

Singapore PDPA (PDPA)

Personal Data is defined in the PDPA as “data, whether true or not, about an individual who can be identified a) from that data; or b) from that data and other information to which the organisation has or is likely to have access.”

EU General Data Protection Regulation (EU) 2016/679 (GDPR)

The regulation applies if the data controller (organization that collects data from EU residents) or processor (organization that processes data on behalf of data controller e.g. cloud service providers) or the data subject (person) is based in the EU.

Regulation also applies to organizations based outside the European Union if they collect or process personal data of EU residents. According to the European Commission, Personal Data is: " any information relating to an individual, whether it relates to his or her private, professional or public life. It can be anything from a name, a home address, a photo, an email address, bank details, posts on social networking websites, medical information, or a computer’s IP address.”

Personal Data

Go Abroad Study Programs defines Personal Data as the broader of the definitions contained in the PDPA, DPA, and GDPR.

Go Abroad Study Programs defines Sensitive Personal Data as the broader of the definitions contained in the PDPA, DPA, and GDPR.

Any use of sensitive Personal Data is to be strictly controlled in accordance with this policy.

While some data will always relate to an individual, other data may not, on its own, relate to an individual. Such data would not constitute Personal Data unless it is associated with, or made to relate to, a particular individual.

For the purposes of the Singaporean PDPA, Go Abroad Study Programs is a Data Intermediary. From the Act: “data intermediary” is an organisation which processes Personal Data on behalf of another organisation but does not include an employee of that other organisation. Generic information that does not relate to a particular individual may also form part of an individual’s Personal Data when combined with Personal Data or other information to enable an individual to be identified.

Aggregated data is not Personal Data.

Go Abroad Study Programs gathers Personal Data for two purposes: for student enrollment, and for internal operations.

Personal Data for student enrollment relates to identifiable individual users and may include:

user profile information such as Full name, Photograph, Address , Date of Birth, Mobile telephone number, and Personal email address;
travel-related data such as passport number, ID number and flight ticket data
study-related data such as enrolment documents and reference letters

Personal Data we gather for internal operational purposes relates to identifiable individuals such as job applicants, current and former employees, contract and other staff, clients, suppliers, and marketing contacts, and the data gathered may include individuals' contact details, educational background, financial and pay details, details of certificates and diplomas, education and skills, marital status, nationality, job title, and CV.

Principles

Go Abroad Study Programs collects and processes Personal Data in compliance with the following data protection principles:

Consent - The user (data subject) must give their explicit, active consent to the collection and processing of their Personal Data. This consent can be revoked at any time.

Notification - Go Abroad Study Programs notifies all users about the intended purpose of any collected data prior to collection.

Purpose Limitation - Personal Data can be used only for the purposes explained to the user, and for which they have explicitly given consent. The data collected must be necessary for the performance of the purpose, and not excessive with respect to the purposes for which it was collected.

Right to Access and Correction - Users should be able to access their personal, wearable, and messaging data, and to correct said data where applicable.

Accuracy - Go Abroad Study Programs should take all reasonable steps to ensure users’ data is accurate and up to date.

Protection - Go Abroad Study Programs should take all reasonable steps to ensure user data is secured and protected against unauthorised or unlawful processing, accidental loss, destruction, or damage.

Retention Limitation - Go Abroad Study Programs should not keep personal user data for any longer than necessary to fulfil the purposes for which the user gave their consent.

Openness - Go Abroad Study Programs publicly publishes our Data Protection Policy and the direct contact details of our Data Protection Officer.

Data Portability - Upon request, a user should have the right to receive a copy of their data in a structured format. These requests should be processed within one month, provided there is no undue burden and it does not compromise the privacy of other individuals.

Right to be Forgotten - A data subject may request that any information held on them is deleted or removed, and any third parties who process or use that data must also comply with the request. An erasure request can only be refused if an exemption applies.

Privacy by Design and Default - Privacy by Design is an approach to projects that promote privacy and data protection compliance from the start. The DPO will be responsible for conducting Privacy Impact Assessments and ensuring that all IT projects commence with a privacy plan. When relevant, and when it does not have a negative impact on the data subject, privacy settings will be set to the most private by default.

Data Audit and Register - Go Abroad Study Programs will keep a register of annual data audits & their outcomes to manage and mitigate risks. The register will detail what data is held, where it is stored, how it is used, who is responsible and any further regulations or retention timescales that may be relevant.

Purposes

The purposes for which Personal Data may be used by us include:

Providing a personalised study information and enrollment service to our users
Research and Development of AI and chat technology in support of our information service
Compliance with our legal, regulatory, and corporate governance obligations and good practice
Gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests
Ensuring business policies are adhered to (such as policies covering email and internet use)
Operational reasons, such as recording transactions, training and quality control, ensuring the confidentiality of commercially sensitive information, and security vetting
Investigating complaints
Checking references, ensuring safe working practices, monitoring and managing staff access to systems and facilities and staff absences, administration, and assessments
Monitoring staff conduct & disciplinary matters
Marketing our business
Improving our services
Risk modelling for our partners

Responsibilities

The Data Protection Officer’s responsibilities include:

Overseeing the implementation of, and compliance with this Policy, working in conjunction with the relevant employees, managers and/or department heads, agents, contractors and other parties working on behalf of Go Abroad Study Programs;
Keeping the board updated about data protection responsibilities, risks, and issues
Reviewing all data protection procedures and policies on an annual basis
Arranging data protection training and advice for all staff members and those included in this policy
Answering data protection queries or complaints from users, clients, staff, board members, and other stakeholders
Responding to individuals such as clients and employees who wish to know which data is being held on them by Go Abroad Study Programs
Checking and approving with third parties that handle Go Abroad Study Programs’s data any contracts or agreement regarding data processing

The Engineering Manager’s responsibilities include:

Ensuring all systems, services, software, and equipment meet acceptable security standards;
Researching and reviewing third-party services Go Abroad Study Programs uses to store or process data (such as cloud computing services) on a regular basis; and Managing authentication and authorisation for engineering staff to access Go Abroad Study Programs’ infrastructure, including cloud services, databases, and application servers.

Responsibilities of the Marketing Manager

The Marketing Manager’s responsibilities include:
Approving data protection statements attached to emails and other marketing copy; and
Coordinating with the DPO to ensure all marketing initiatives adhere to data protection laws and Go Abroad Study Programs’s Data Protection Policy.

The Staff Manager is responsible for: - Ensuring all Staff complete training in Go Abroad Study Programs’ policies and procedures, including the Data Protection Policy; - Managing the authentication & authorisation of Go Abroad Study Programs’ staff.

Organisational measures

Go Abroad Study Programs shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

All employees, agents, contractors, or other parties working on behalf of Go Abroad Study Programs are made fully aware of both their individual responsibilities and Go Abroad Study Programs’s responsibilities under this Policy, and shall be provided with a copy of this Policy;
Only employees, agents, sub-contractors, or other parties working on behalf of Go Abroad Study Programs that need access to and use of personal data in order to carry out their assigned duties correctly shall have access to personal data held by Go Abroad Study Programs;
All employees, agents, contractors, or other parties working on behalf of Go Abroad Study Programs handling personal data will be appropriately trained to do so;
All employees, agents, contractors, or other parties working on behalf of Go Abroad Study Programs handling personal data will be appropriately supervised;
Methods of collecting, holding and processing personal data shall be regularly evaluated and reviewed;
The performance of those employees, agents, contractors, or other parties working on behalf of Go Abroad Study Programs handling personal data shall be regularly evaluated and reviewed;
All employees, agents, contractors, or other parties working on behalf of Go Abroad Study Programs handling personal data will be bound to do so in accordance with the principles of this Policy by contract;
All agents, contractors, or other parties working on behalf of Go Abroad Study Programs handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of Go Abroad Study Programs arising out of this Policy;
Where any agent, contractor or other party working on behalf of Go Abroad Study Programs handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless Go Abroad Study Programs against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

Our procedures

Consent - Go Abroad Study Programs ensures consent is given by making informed, explicit, active consent a requirement of the mobile app’s registration process, including a clear identification of what the relevant data is, why it is being processed, and to whom it will be disclosed.

Notification -Go Abroad Study Programs ensures Consent is informed by notifying users in plain language about the intended Purpose of any data prior to collection, and by requiring users to give their consent to that Purpose as part of the mobile app registration process.

Fair and lawful processing

We must process Personal Data fairly and lawfully in accordance with individuals’ rights. This generally means that we should not process Personal Data unless the individual whose details we are processing has consented to this happening.

The processing of all data must be:

Necessary to deliver our services
In our legitimate interests and not unduly prejudice the individual's privacy
In most cases this provision will apply to routine business data processing activities.

Purpose Limitation

Go Abroad Study Programs staff must not use Personal Data for any Purpose other than that consented to by the user. In the general case, this means that it must be for the purpose of study related and enrollment services and or supporting activities.

Go Abroad Study Programs staff should not access Personal Data except where required to do so in the course of their work.

Right to Access, Correction, and Accuracy

Users can use the Go Abroad Study Programs apps to access their personal, wearable, and messaging data, and to correct their profile data at any time.

Go Abroad Study Programs should take all reasonable steps to ensure users’ data is accurate and up to date.

Go Abroad Study Programs assumes that Personal Data collected directly from the user will be accurate and complete.

We will ensure that any Personal Data we process is accurate, adequate, relevant, and not excessive, given the purpose for which it was obtained. We will not process Personal Data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.

Individuals may ask that we correct inaccurate Personal Data relating to them. If you believe that information is inaccurate you should record the fact that the accuracy of the information is disputed and inform the DPO.

Protection

Go Abroad Study Programs should take all reasonable steps to ensure user data is secured and protected against unauthorised or unlawful processing, accidental loss, destruction, or damage.

In cases when data is stored on printed paper, it should be kept in a secure place where unauthorised personnel cannot access it. Printed data should be shredded when it is no longer needed.

Sensitive Personal Data should never be saved directly to local devices such as workstations, laptops, or smartphones – it should be kept secured on remote storage provided by Go Abroad Study Programs’ selected cloud storage provider.

All digital services used by Go Abroad Study Programs should be protected on a per-user basis, by strong passwords, with role-based permissions.

We encourage all staff to use a password manager to create and store their passwords.

Personal Data should not be stored on local storage media such as CDs, DVDs, or memory sticks.

The DPO and Engineering Manager must approve any cloud service used to store data.

Data should be regularly backed up in line with Go Abroad Study Programs’s backup procedures.

All servers or services containing sensitive data must be protected by security software and firewalls.

All data should be transmitted over secure networks only. Transmission over unsecured networks is not permitted in any circumstances, including via email.

No personal data may be shared informally. If an employee, agent, sub-contractor, or other party working on behalf of Go Abroad Study Programs requires access to any personal data that they do not already have access to, such access should be formally requested from their relevant manager.

If Personal Data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it.

Under no circumstances should any personal passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of Go Abroad Study Programs, irrespective of seniority or department.

Retention Limitation

Go Abroad Study Programs should not keep personal user data for any longer than necessary to fulfil the purposes for which the user gave their consent.

Go Abroad Study Programs keeps personal user data for a maximum period of 12 months after the user’s most recent access, unless the user requests that their account be deleted.

Go Abroad Study Programs will (soft) delete the user’s account within 5 working days of confirmation of the request by the user.

Deleting a user account has the following effects:

The useris immediately disconnected from our service
User’s name is deleted from their profile
User’s messaging history is anonymised by redacting the user’s name wherever it appears
User’s email address & mobile phone number are deleted
User account is soft deleted
Messaging history is retained

Openness

Go Abroad Study Programs publicly publishes our Data Protection Policy and the direct contact details of our Data Protection Officer.

Right to be Forgotten / Erasure - A user may request that any information held on them is deleted, and any third parties who process or use that data must also comply with the request. An erasure request can only be refused if an exemption applies.

Go Abroad Study Programs allows users to request that their account be deleted by direct email to the DPO.

Transferring Data Internationally

No data may be transferred outside of the Go Abroad Study Programs data centres without prior approval from the DPO.

Specific consent from the user must be obtained prior to transferring their data outside their source region.

You must not transfer Personal Data to another geographic region unless 1) Go Abroad Study Programs can ensure an adequate level of protection of the rights and freedoms of users in relation to the processing of their Personal Data within the destination region, and 2) you have been given permission to do so by the DPO. Data Audit and Register

The DPO will conduct regular data audits to manage and mitigate risks, and record the data held by Go Abroad Study Programs in a Data Register.

The Data Register contains information on what data is held, where it is stored, how it is used, who is responsible and any further regulations or retention timescales that may be relevant.

User Access Requests

Individuals are entitled, subject to certain exceptions, to request access to information held about them.

If you receive a subject access request, you should refer that request immediately to the DPO. We may ask you to help us comply with those requests.

Please contact the Data Protection Officer if you would like to correct or request information that we hold about you. There are also restrictions on the information to which you are entitled under applicable law.

Processing data in accordance with the individual's rights

Do not send direct marketing material to someone electronically (e.g. via email) unless you have an existing business relationship with them in relation to the services being marketed.

Please contact the DPO for advice on direct marketing before starting any new direct marketing activity.

PDPA & GDPR Provisions for users

Privacy Notice - Transparency of Data Protection

Being transparent and providing accessible information to individuals about how we will use their Personal Data is important for our organisation. The following are details on how we collect data and what we will do with it:

What information is being collected?

Go Abroad Study Programs collects Personal Data about users including, but not limited to:
Full name
Photograph
Mobile telephone number
Personal email address
Travel-related information such as passport number and ID number
Study-related data such as enrollment documents, certificates and recommendation letters

How is it collected?

Go Abroad Study Programs collects data using the Go Abroad Study Programs websites and apps.
Go Abroad Study Programs specifically asks the individual for permission to collect their data for the purpose of study and enrolment related services & obtains the user’s consent as part of the registration process. Users can not access the Go Abroad Study Programs service if they withhold their consent.
Go Abroad Study Programs also requires explicit consent to collect Personal Data for any additional purposes required by our clients.
Go Abroad Study Programs only collects data from third parties once the user has provided their permission. (User permission is explicitly required to enable the retrieval of any data from third parties.)
All of Go Abroad Study Programs’ third-party wearable providers explicitly ask the user’s consent before collecting their data.

Why is it being collected?

Go Abroad Study Programs collects Personal Data for the purpose of providing study and enrollment related services.
If Go Abroad Study Programs’ clients intend to use Personal Data for any purpose other than for study and enrollment related service, then Go Abroad Study Programs will explicitly request permission from the user to collect, store, and process their data for that purpose.
Go Abroad Study Programs requires its clients to disclose any and all ways they use the Personal Data collected by Go Abroad Study Programs.

How will it be used?

The data is used by Go Abroad Study Programs strictly to provide study and enrolment related services, and all supporting activities necessary to provide and improve that service.
Personal Data is accessible only to authenticated and authorized Go Abroad Study Programs administrative, managerial, content, research, technical, engineering, compliance, support, and coaching staff for the purposes of:
Providing study and enrollment services
Monitoring and improving the quality of services
Monitoring and improving the in-app experience and user engagement
Research & Development of Artificial Intelligence agents to provide study and enrolment related services
Administering the technology platform and sub-systems
Personal Data is accessed by Go Abroad Study Programs staff only where necessary to perform the tasks of their job.(eg: Coaches and Researchers do not have access to the users’ email addresses or mobile numbers.)
All user data is stored remotely in databases secured & hosted in data centres.
Go Abroad Study Programs users do not extract, copy, or use local copies of user data unless it has been anonymised or aggregated.
Database access by Go Abroad Study Programs staff is authorized on a IP-whitelisted, per-user basis according to the requirements of their job, and authenticated using strong passwords.
Go Abroad Study Programs does not print or save to local storage any Personal Data.
Go Abroad Study Programs does not transfer Personal Data to any third parties excepting our clients on whose behalf we are the data intermediary.
Go Abroad Study Programs transmits Personal Data only: Between servers on our platform,
To and from a user’s authenticated installation of the Go Abroad Study Programs apps, and
To our clients, on whose behalf we are the data intermediary.

The Personal Data is disclosed to the following:

Go Abroad Study Programs AI agents
to generated suggested responses to user messages
Go Abroad Study Programs coaching staff
to provide QA over AI responses, and to respond to user requests where the AI cannot
Go Abroad Study Programs research and service staff
to improve the study and enrollment service
Go Abroad Study Programs management staff (for QA & service management)
to ensure the service conversations meet the standard of quality required by Go Abroad Study Programs
Our client, on whose behalf Go Abroad Study Programs is acting as a data intermediary
for their own purposes, as negotiated on a per-contract basis.
Go Abroad Study Programs requires its clients to handle any Personal Data (transferred to them via Go Abroad Study Programs) to the standard required by PDPA.
Go Abroad Study Programs does not provide Personal Data to third parties excepting the clients on whose behalf we are the intermediary.

How can it be accessed or corrected?

Users can access and update their own Personal Data using the Go Abroad Study Programs apps or websites.
Go Abroad Study Programs assumes that Personal Data collected directly from the user will be accurate and complete. (As per Guidelines for Life Insurers c.43.)

How can Consent be Withdrawn?

The Go Abroad Study Programs app provides a single step process for users to retrieve data from third party providers.
Users can use the Go Abroad Study Programs apps to submit a request for their account be deleted (via chat with the service staff).

Details of transfers to third countries and safeguards

Go Abroad Study Programs stores data on hosting platforms in data centres in Europe.
Go Abroad Study Programs keeps all data secured in accordance with the standards required by relevant UK, EU, and Singaporean legislation.
Go Abroad Study Programs keeps all data encrypted both in transmission and at rest.

Identity and contact details of any data controllers?

Go Abroad Study Programs’ designated Data Protection Officer is: dpo@goabroadstudyprograms.com

Retention periods

Go Abroad Study Programs keeps personal user data for a maximum period of 12 months after the user’s most recent access of the app, unless the user requests that their account be deleted.
Go Abroad Study Programs will delete the user’s account within 5 working days of confirmation of the request by the user.
Deleting a user account has the following effects:
The user’s wearables (if any) are immediately disconnected from our service
User’s name is deleted from their profile
User’s messaging history is anonymised by redacting the user’s name wherever it appears
User’s email address & mobile phone number are deleted
User account is soft deleted
Wearable data is retained to train our AI
Messaging history is retained to train our AI

Conditions for processing

We will ensure any use of Personal Data is justified using at least one of the conditions for processing and this will be specifically documented. All staff who are responsible for processing Personal Data will be aware of the conditions for processing. The conditions for processing will be available to data subjects in the form of a privacy notice.

REPORTING BREACHES

All members of staff have an obligation to report actual or potential data protection compliance failures. This allows us to:

Investigate the failure and take remedial steps if necessary
Maintain a register of compliance failures
Notify the Supervisory Authority of any compliance failures that are material either in their own right or as part of a pattern of failures
Under the GDPR, the DPO is legally obliged to notify the Supervisory Authority within 72 hours of the data breach (Article 33). Individuals have to be notified if adverse impact is determined (Article 34). In addition, Go Abroad Study Programs must notify any affected clients without undue delay after becoming aware of a personal data breach (Article 33).
However, Go Abroad Study Programs does not have to notify the data subjects if anonymized data is breached. Specifically, the notice to data subjects is not required if the data controller has implemented pseudonymisation techniques like encryption along with adequate technical and organizational protection measures to the personal data affected by the data breach (Article 34).

Monitoring

Everyone must observe this policy.

The DPO has overall responsibility for this policy.
The DPO will monitor this policy regularly to make sure it is being adhered to.

Data protection complaints

Data Protection Complaints can be received via:

Go Abroad Study Programs website
Email or Phone Call to Data Protection Officer

The Complaint Process is:

Within 1 working day: DPO will respond to the complaint to notify the complainant that the complaint is being investigated
DPO to conduct investigation, escalating to client / board as required
DPO to investigate & resolve complaints within 5 working days where possible
DPO to regularly update complainant at least weekly on progress of investigation & expected time to resolution
Upon completion of investigation, DPO to provide written report to complainant containing the investigation findings and steps to resolution
DPO to carry out steps to resolution
DPO to confirm with user that complaint has been satisfactorily resolved

Consequences of failing to comply

We take compliance with this policy very seriously. Failure to comply puts both you and the organisation at risk. The importance of this policy means that failure to comply with any requirement may lead to disciplinary action under our procedures which may result in dismissal.

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