PRIVACY POLICY

1. What is this Privacy Policy for?

Introduction

Academic Programs and Services, LLC and our related entities (“Academic Programs and Services”, “we”, “us”, or “our”) are committed to protecting your privacy. This Privacy Policy outlines how we collect, use, share, and process identifiable information about you (“Personal Data”) across all websites, applications, and platforms that we own or operate, as well as all services we provide (“Services”). Unless specified otherwise, Academic Programs and Services acts as the controller of your Personal Data. This Privacy Policy also explains your privacy rights.

Third Party Links and Platforms

Our Services may include links to websites, applications, platforms, and services maintained by third parties. The privacy practices of those third parties, including social media platforms that host our branded content, are governed by their own privacy policies. We encourage you to review those policies to better understand their privacy practices.

Academic Programs and Services’ Role as a Processor

This Privacy Policy does not apply to the extent that Academic Programs and Services processes Personal Data in the role of a processor or service provider on behalf of our customers. For example, where our customer is an employer, school, or organization that has purchased our Services for its own employees, students, or users, that customer controls the data processing, and their privacy practices apply. Academic Programs and Services is not responsible for the data privacy and security practices of its customers.

2. What Personal Data do we collect?

Directly or Automatically

We may collect Personal Data both directly from you, and automatically when you interact with our Services. The Personal Data we collect from you may include identifiers, financial information, commercial details, educational records, visual data, professional or employment-related information, internet activity, as well as any other such information from time-to-time. Below are the situations in which we collect this information and the types of Personal Data involved:

Situation	Types of Personal Data
Expressing an interest in obtaining additional information about our products or Services; requesting customer support; using our “Get In Touch” form or similar features; registering to use our websites or to receive communications; signing up for an event, webinar or contest; or downloading certain content	Contact information, such as your name, residential address, phone number, email address, educational information, username and password, and other information you have voluntarily chosen to share
Making purchases via our websites or registering for an event or webinar	Contact information, financial and billing information, such as billing name and address, credit or debit card number or bank account information
Attending an event in person	Contact information, such as your name, residential address, phone number, email address, educational information, username and password, and other information you have voluntarily chosen to share
Interacting with our websites or emails	Information about your device and your usage of our websites or emails (such as Internet Protocol (IP) addresses or other identifiers), which may qualify as Personal Data (please see Section 4 below) using cookies, web beacons, or other similar technologies
Using and interacting with our products and Services	Information about your device and your usage of our products or Services through log files and other technologies; your IP address, contact information such as your name; your voice image and video; your educational information; and other information you voluntarily share
Communicating with us via a call (phone, video, or otherwise)	Contact information such as your name, phone number, email and username; your voice, image and video; and other information you voluntarily share
If you are employed or contracted by a company or organisation that that purchased our Services	Any information you voluntarily choose to provide to us
Applying for a job with us	Contact information such as your name, phone number and email; professional or employment-related information; educational information; and any other information you voluntarily share
Voluntarily submitting certain information to us, such as filling out a survey, responding to a questionnaire or participating in other forms of research	Any information you voluntarily choose to provide to us
If you are a supplier or service provider to Academic Programs and Services, LLC (or work for a supplier or service provider)	Contact information, financial and billing information, such as billing name and address and/or bank account information; any other information you voluntarily choose to provide to us
If you are a student at a school or organisation which has purchased our Services	Any information you voluntarily choose to provide to us

Indirectly

We may also collect Personal Data indirectly from third-party sources such as marketing and research partners, or from publicly available sources including social media profiles and professional networking sites. In accordance with applicable law, we may generate additional information by combining Personal Data you provide with data obtained from these third-party or public sources. This information may be used to detect, prevent, or address fraudulent, deceptive, or illegal activity, misuse of our Services, or security and technical issues, as well as to protect the rights, property, and safety of Academic Programs and Services, our staff, customers, students, or the public.

We may also infer or generate insights based on the Personal Data we collect to enhance your user experience and maintain accurate and up-to-date records.

If you provide us or our affiliates with Personal Data relating to other individuals, you confirm that you have the authority to do so and have obtained any necessary consent where required. You acknowledge that such Personal Data may be used in accordance with this Privacy Policy. If you believe your Personal Data has been shared with us improperly, or if you wish to exercise your rights under applicable law, please contact us using the details provided in Section 11 below.

3. What do we use Personal Data for and under which legal bases?

Academic Programs and Services processes the Personal Data collected about you for several purposes, including:

(1) To perform a contract or to take steps prior to entering into a contract:

Delivering, administering, or providing our Services to you, including those you have purchased or received through a free trial
Verifying your identity
Processing payments
Sending you necessary communications
Providing you with customer service or support

(2) Where you have given consent to the processing of your Personal Data:

Sending you information about Academic Programs and Services’s products and Services
Sharing your Personal Data with third parties for their own marketing purposes
Accessing Personal Data stored on your browser relating to your use of our Services
Placing cookies and other similar technologies through our products, Services, and email communications, in accordance with our Cookies Policy

(3) Where necessary to conduct our business and pursue our legitimate interests:

Delivering or providing our Services to you
Sending you information about our products and Services, including through direct marketing activities
Analysing and measuring the effectiveness of our Services to better understand usage, improve engagement, and increase user satisfaction
Diagnosing and resolving any issues with our Services
Investigating and responding to any comments or complaints from you
Conducting market research to understand user interests, advertising effectiveness, and customer satisfaction
Analysing the use and navigation of our Services to detect, prevent, or address fraudulent, deceptive, or illegal activity or misuse

(4) Where necessary to protect the vital interests of another individual:

Protecting personal property or safety, including safeguarding the rights, property, or welfare of our users or the public
Ensuring the safety and well-being of children, consistent with applicable safeguarding policies, guidelines, regulations, or laws

(5) Where necessary for legal reasons:

Responding to requests from government or law enforcement authorities, including for compliance, regulatory, or investigative purposes
Complying with judicial proceedings, court orders, or other legal processes
Using or disclosing Personal Data as reasonably necessary to detect, prevent, or address fraudulent, deceptive, or illegal activity, misuse of our Services, security issues, or piracy, in order to protect both you and Academic Programs and Services

If we are required by law or by an agreement with you to collect and process certain Personal Data, and you fail to provide it, we may not be able to perform our agreement with you. Where we process your Personal Data based on legitimate interests, you may object in certain cases. If you do, we will stop processing such data unless we have overriding legitimate grounds or legal obligations to continue. Where a particular legitimate interest is not a recognised legal basis in a given jurisdiction, we will rely on other available legal grounds for the collection and processing of Personal Data as described above.

4. How do we use cookies?

Academic Programs and Services uses cookies when you interact with our website or Services. Cookies are small text files stored by your web browser when you visit websites. In addition to cookies, we may use other similar technologies such as HTML5 Local Storage, local shared objects, web beacons, and embedded scripts. These tools help us remember your preferences when you return to our sites, analyse how you use the website, conduct market research, and collect information about the ads you view or engage with.

You can control how Academic Programs and Services uses cookies and similar technologies by adjusting your browser settings or by using our cookie management tool available in the footer of this page. By allowing cookies, we can improve your experience by:

tailoring our website and content based on your preferences,
keeping track of your settings and preferences for future visits,
better understanding your likely interests to provide you with more relevant Academic Programs and Services content and advertisements on other websites and apps, and
enhancing the overall performance of our website.

If you choose to disable cookies and similar technologies, some parts of our websites may not function properly, and your experience may differ from what you expect. We will not be able to remember your preferences across sessions, and certain features may be limited. You will still have access to our website content, but features that rely on cookies may not work as intended. You will continue to see advertisements, but they may not be relevant to your interests.

There are also strictly necessary cookies. These cookies are essential for our website to function and cannot be disabled through our systems. They are typically set in response to actions you take, such as setting your privacy preferences, logging in, or filling out forms. While you can configure your browser to block or alert you about these cookies, doing so may prevent parts of our website from functioning properly. These cookies do not store any Personal Data.

5. Who do we share Personal Data with?

Academic Programs and Services may share your Personal Data with various parties, either with your consent or when consistent with a purpose and legal basis outlined in this Privacy Policy. These parties may include:

Affiliates: Entities, affiliates, or subsidiaries within the Academic Programs and Services, corporate group, including any future acquisitions that become part of the group.
Partners: Entities or individuals we collaborate with to sell, promote, or advertise our Services, including those who sponsor, organise, or run events and webinars with us.
Service Providers: External entities, contractors, or suppliers engaged to help us deliver our Services, such as IT and system administration, credit card processing, market research, customer analytics, marketing, event planning, customer support, and accounting. Some service providers may use artificial intelligence technologies to analyse Personal Data, identify trends, make predictions, or create AI-generated responses or content.
Other Users with Whom You Are Affiliated: Individuals associated with your use of our Services. For example, (a) for students or children, this may include their parents, guardians, or caregivers, and (b) for authorised users, it may include their employer, school, or other organisation.
Third Parties: Social media platforms, recruitment and job posting websites, advertising networks, and internet service providers.
Professional Advisers: Service providers such as lawyers, bankers, auditors, accountants, and insurers who provide legal, financial, auditing, accounting, insurance, and consultancy services.
Third Parties Involved in a Corporate Transaction: The prospective or actual purchaser of all or substantially all of Academic Programs and Services’’s assets or shares (through merger, reorganisation, acquisition, dissolution, or other corporate changes), and their professional advisers, to the extent necessary. Your Personal Data may be transferred as part of such a transaction.
Public Authorities: Regulatory, governmental, compliance, or judicial bodies, at the federal, state, or local level, as required by law.

Academic Programs and Services, may also share aggregated information, such as statistical data, to demonstrate general trends in the use of our Services. Where such information is disclosed publicly, it will only be shared in an anonymised form.

6. What are your rights relating to Personal Data?

Your rights

Where permitted under applicable law, you may have the following rights concerning your Personal Data:

to request a copy of the Personal Data we hold about you
to request correction, deletion, or restriction of the processing of your Personal Data
to obtain more information about how we process your Personal Data
to object to the processing of your Personal Data in certain circumstances, such as opting out of direct marketing communications

These rights apply only to Personal Data that Academic Programs and Services, actually holds and may be limited in certain cases. For instance, we may fully or partially deny a request if fulfilling it would disclose personal information about another individual. Similarly, requests to delete Personal Data may be limited where the information must be retained to comply with legal, regulatory, or reporting obligations, or where it may be necessary to defend against legal claims.

You also have the right not to provide your Personal Data to us. However, in such cases, we may be unable to deliver certain Services or perform our contractual obligations. As described in Section 4, you may also adjust your web browser or operating system settings to restrict automatic data collection, but this may result in certain features of our Services not functioning as intended.

Exercising your rights

To exercise your rights, please contact us using the information provided in Section 11 below. In order to process and respond to your request, we may need to use certain Personal Data. We will make every effort to respond to legitimate requests within a reasonable timeframe, unless a specific deadline is required by law. In some cases, additional time may be needed, depending on the complexity and number of requests. If we are unable to fulfil your request, we will provide an explanation for the refusal.

You may also be able to exercise some of your rights directly by logging into your account and accessing the “My Account”, “My Profile”, or similar section within the Service you use. Through these features, you can view, update, or delete certain Personal Data.

Academic Programs and Services, may send you direct marketing communications using the Personal Data you have provided. You can opt out of receiving such communications at any time by clicking the unsubscribe link included in our emails, or by contacting us at admissions@oxbridgesummerscholars.com

7. How do we keep your Personal Data safe?

Academic Programs and Services takes appropriate technical, organisational, and physical measures to safeguard Personal Data against accidental, unlawful, or unauthorised alteration, destruction, loss, or disclosure. Our security controls include encryption, two-factor authentication, identity verification, staff training, and contractual confidentiality obligations for employees and contractors.

While we follow recognised industry standards to protect Personal Data, no storage or transmission method can be guaranteed to be completely secure. You are responsible for limiting access to your devices, protecting your passwords, and signing out of websites and applications after each session.

8. How long do we keep Personal Data?

Academic Programs and Services will retain and process your Personal Data for as long as there is a lawful basis to do so. We will delete certain Personal Data once there is no longer a business reason to retain it. However, some types of Personal Data may need to be retained even after you stop using our Services in order to meet legal, contractual, or reporting obligations. This may include information connected to our business transactions or agreements with you, which will be stored for as long as required to comply with those obligations.

After the applicable retention period expires, your Personal Data will be deleted. If some information cannot be completely deleted from our systems for technical reasons, we will apply appropriate safeguards to ensure it is no longer used or accessible.

9. Do we transfer your Personal Data internationally?

Academic Programs and Service is an international organisation. Your Personal Data may be collected, transferred, and stored by Academic Programs and Services, its affiliates, or third parties located within your jurisdiction or in other countries. As a result, your Personal Data may be processed outside your country or region, including in places that do not have the same level of data protection or are not covered by an adequacy decision from the European Commission or your local authority.

We take steps to ensure that any party receiving your Personal Data provides a comparable level of protection and security. This includes implementing safeguards that ensure your data is processed in accordance with this Privacy Policy and applicable legal requirements.

10. Will this Privacy Policy Change?

This Privacy Policy may be updated periodically to reflect changes in our practices, legal requirements, technologies, or other relevant factors. When updates are made, the “last updated” date at the top of the page will be revised, and the new version will be published.

We encourage you to review this Privacy Policy regularly to stay informed about how we collect, use, and disclose your Personal Data. If we make any significant changes or where required by law, we will notify you before those changes take effect. This may include posting a notice on our website or contacting you directly. Where applicable, we will seek your consent to material changes.

11. Contacting us

Academic Programs and Services, has appointed a Data Protection Officer (DPO) to oversee compliance with data protection laws and to manage requests and inquiries regarding Personal Data.

If you wish to exercise your rights or have questions about this Privacy Policy or our privacy practices, please contact us at:

Academic Programs and Services, LLC
Attn: Harry Rillstone, Data Protection Officer
Email: privacy@oxbridgesummerscholars.com
Address: 1201 N Orange Street, Suite 7175
Wilmington, Delaware 19801
United States

Please include all relevant details in your message, such as your country or state of residence, so we can assist you effectively.

Academic Programs and Services, LLC is committed to working with you to fairly resolve any complaint or concern about privacy. However, if you believe that we have not been able to assist with your complaint or concern, you may wish to exercise your right to lodge a complaint with the appropriate authority in your jurisdiction. If you work or reside in a country that is a member of the European Union or that is in the European Economic Area, you may find the contact details of the appropriate authority here. Otherwise, you may be able to locate the contact details of the appropriate authority in your jurisdiction here.