For the purpose of the General Data Protection Regulation (GDPR), the UK General Data Protection Regulation (UK GDPR) and the UK Data Protection Act 2018 the Data Controller is Virtual Internship Partners Ltd (Virtual Internships).
OUR APPOINTED REPRESENTATIVE IN THE EUROPEAN ECONOMIC AREA (EEA)
As we are based in the United Kingdom, we have appointed Data Protection Representative Limited (DataRep), a company incorporated in Ireland with registered number 616588, to be our representative within the EEA. If you wish to raise a question to us, or otherwise exercise your rights in respect of your personal data, you may do so by:
- Sending an email to DataRep at email@example.com quoting ‹Virtual Internship Partners Ltd› in the subject line,
- Contacting DataRep on their online webform at www.datarep.com/data-request; or
- Mailing your inquiry to DataRep at the most convenient of the addresses listed in Schedule 1 to this Policy.
PLEASE NOTE: when mailing inquiries, it is ESSENTIAL that you mark your letters for ‘DataRep’ and not ‘Virtual Internship Partners Ltd.’, or your inquiry may not reach DataRep. Please refer clearly to ‘Virtual Internship Partners Ltd.’ In your correspondence. On receiving your correspondence, we are likely to request evidence of your identity, to ensure your personal data and information connected with it is not provided to anyone other than you.
YOUR PERSONAL INFORMATION
Information we collect from you
We collect and process some or all of the following types of information from you in the course of your use of https://www.virtualinternships.com/ (the “Website”) or providing our services:
- Information that you provide by filling in forms on the Website or filing in forms as part of the registration process, or while using our Website chat. This includes information provided when subscribing to our service or our learning management system, Talent LMS, if you sign up for our program curriculum, CareerBridge or requesting further information or services. We may also ask you for information when you have successfully signed up to an internship programme.
- Specifically, personal details such as name, email address, location, country of residence, dates of internship, phone number, university attended, CV, passport and identification details, medical records, date of birth or any information input by you when using the Website, completing our survey forms, or using our services.
- If you are between the ages of 13 – 18 years of age, we will also require your date of birth and the name, email address and relationship of your parent or guardian.
- If you contact us, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for your personal development and research purposes, although you do not have to respond to them.
- Details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.
The provision of your name, email address, location information and country of residence is required from you to enable us to provide you with our services. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
Information we collect from other sources
We may also obtain personal data from other sources as follows:
- Video interviews conducted using the software InterviewStream; and
- Your university, high school or pathway provider.
USES MADE OF YOUR INFORMATION
Lawful basis for processing
We rely on legitimate interests as the lawful basis on which we collect and use your personal data. Our legitimate interests are to fulfil our contractual obligations to you.
For children aged 13 – 18 years of age, we rely on legitimate interests in providing our services to you as the lawful basis for collecting your date of birth and the name, email address and relationship of your parent or guardian.
When processing your medical records we rely on your explicit (clearly given) consent (permission) as a lawful basis for the processing.
Purposes of processing
We use information held about you in the following ways:
- To provide you with our services.
- To ensure that content on the Website is presented in the most effective manner for you and for the device(s) you use to access and view the Website;
- To provide you with information and offers that you request from us or which we feel may interest you.
- To allow you to participate in interactive features of our service, when you choose to do so.
- To notify you about changes to our service.
- To provide progress reports to universities.
In addition to the above uses we may use your information, to notify you about services which may be of interest to you. Where we do this, we will contact you by electronic means (e-mail or SMS) only if you have consented to such communication. If you do not want us to use your data in this way please either (i) tick the relevant box situated on the form on which we collect your data (for example, the registration form); (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) inform us at any time by contacting us at the contact details set out below.
DISCLOSURE OF YOUR INFORMATION
We routinely disclose your personal data to third parties as follows:
- We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (e.g. to host our servers).
- We provide your name, a copy of your CV and your video interview to the organisation hosting the internship.
- We may pass your information including progress reports to your university, high school or pathway provider.
We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).
We may also disclose your personal data to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
- if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; or
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions and other contractual agreements; or
- to protect our rights, property, or safety or that of our affiliated entities and our users and any third party we interact with the to provide the Website; or
- in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be if interest to you.
Other than as set out above, and save insofar as is necessary in order for us to carry out our obligations arising from any contracts entered into between you and us, we will not share your data with third parties unless we have procured your express consent to do so.
STORING YOUR PERSONAL DATA
We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Keeping your personal data up to date
If your personal details change you may update them by contacting us at firstname.lastname@example.org or by using our chat service on the Website. If you have any questions about how we use data collected which relates to you, please contact us by sending a request by email to the contact details below.
We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to us, in order to ensure that the personal data we hold about you is as accurate and up to date as possible.
How long we keep your personal data
- Any medical records (special category data) we obtain about you as an active programme participant will be kept only until the programme is completed. At which point it will be deleted.
- All other personal data (as specified above) we will hold for the period we are required to keep this information by applicable UK tax law (currently 6 years)
Where we store your personal data
All information we hold about you is stored on CRM data centres secure servers in the United States of America.
The data that we collect from you is transferred to, and stored at, a destination outside the United Kingdom and/or the European Economic Area (“EEA”). It may also be processed by staff operating outside the United Kingdom and/or EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the processing of your internship applications and the provision of support services.
In the event we transfer your personal data to a country without an adequacy decision from the United Kingdom, any such transfer will be subject to standard contractual clauses approved by the United Kingdom.
If you would like further information please contact us using our contact details (see ‘Contact’ below).
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- access to your personal data and to certain other supplementary information that this Policy is already designed to address
- require us to correct any mistakes in your information which we hold
- require the erasure of personal data concerning you in certain situations
- receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal data concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal data
- otherwise restrict our processing of your personal data in certain circumstances
- claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email or write to us,
- provide us with enough information to identify you e.g. name, email address, any subscription details and any background information that is relevant to your inquiry,
- provide us with proof of your identity (a copy of your driving licence or passport), and
- identify the information to which your request relates including any reference number if you have one
HOW TO COMPLAIN
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
Schedule 1 – DataRep Mailing Addresses
|Austria||DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria|
|Belgium||DataRep, Place de L’Université 16, Louvain-La-Neuve, Waals Brabant, 1348, Belgium|
|Bulgaria||DataRep, 132 Mimi Balkanska Str., Sofia, 1540, Bulgaria|
|Croatia||DataRep, Ground & 9th Floor, Hoto Tower, Savska cesta 32, Zagreb, 10000, Croatia|
|Cyprus||DataRep, Victory House, 205 Archbishop Makarios Avenue, Limassol, 3030, Cyprus|
|Czech Republic||DataRep, IQ Ostrava Ground floor, 28. rijna 3346/91, Ostrava-mesto, Moravska, Ostrava, Czech Republic|
|Denmark||DataRep, Lautruphøj 1-3, Ballerup, 2750, Denmark|
|Estonia||DataRep, 2nd Floor, Tornimae 5, Tallinn, 10145, Estonia|
|Finland||DataRep, Luna House, 5.krs, Mannerheimintie 12 B, Helsinki, 00100, Finland|
|France||DataRep, 72 rue de Lessard, Rouen, 76100, France|
|Germany||DataRep, 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany|
|Greece||DataRep, 24 Lagoumitzi str, Athens, 17671, Greece|
|Hungary||DataRep, President Centre, Kálmán Imre utca 1, Budapest, 1054, Hungary|
|Iceland||DataRep, Kalkofnsvegur 2, 101 Reykjavík, Iceland|
|Ireland||DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland|
|Italy||DataRep, BPM 335368, Via Roma 12, 10073 , Ciriè TO, Italy|
|Latvia||DataRep, 4th & 5th floors, 14 Terbatas Street, Riga, LV-1011, Latvia|
|Liechtenstein||DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria|
|Lithuania||DataRep, 44A Gedimino Avenue, 01110 Vilnius, Lithuania|
|Luxembourg||DataRep, BPM 335368, Banzelt 4 A, 6921, Roodt-sur-Syre, Luxembourg|
|Malta||DataRep, Tower Business Centre, 2nd floor, Tower Street, Swatar, BKR4013, Malta|
|Netherlands||DataRep, Cuserstraat 93, Floor 2 and 3, Amsterdam, 1081 CN, Netherlands|
|Norway||DataRep, C.J. Hambros Plass 2c, Oslo, 0164, Norway|
|Poland||DataRep, Budynek Fronton ul Kamienna 21, Krakow, 31-403, Poland|
|Portugal||DataRep, Torre de Monsanto, Rua Afonso Praça 30, 7th floor, Algès, Lisbon, 1495-061, Portugal|
|Romania||DataRep, 15 Piaţa Charles de Gaulle, nr. 1-T, Bucureşti, Sectorul 1, 011857, Romania|
|Slovakia||DataRep, Apollo Business Centre II, Block E / 9th floor, 4D Prievozska, Bratislava, 821 09, Slovakia|
|Slovenia||DataRep, Trg. Republike 3, Floor 3, Ljubljana, 1000, Slovenia|
|Spain||DataRep, BPM 335368, Avd. Castilla La Mancha Nº 70-1 (Nave A), 45270, Mocejon-Toledo, Spain|
|Sweden||DataRep, S:t Johannesgatan 2, 4th floor, Malmo, SE – 211 46, Sweden|