Privacy Policy

Our Commitment to Your Privacy

Bright Mind International (“BMI”) is committed to protecting the privacy of our potential and existing customers. The BMI privacy policy (the “Privacy Policy”) applies to all Personal Data (as defined below) processed by us, including Personal Data collected or submitted through our websites, mobile applications or through our official social media pages or through other channels online and offline as further described below (collectively the “BMI Products”).

If you cannot, or will not, provide us with the personal information we reasonably require, we may be unable to provide you with the information, goods or services you have requested.

The BMI company that is the controller for the processing of your Personal Data as set out in this Privacy Policy can be found here and will depend on which BMI product(s) you are interested in or have engaged with. Being the controller means that this company is responsible for ensuring that your personal data is processed in compliance with applicable privacy and data protection legislation.

Personal Data

“Personal Data” is information or pieces of information that could allow you to be identified. We may collect, store and use the following information about you:

• Name and contact details (e.g. postal and email address, telephone      number)
• Account information or user ID (e.g. user name, profile picture or      social media account ID)
• Country of residence or citizenship
• Birth date
• Technical information, e.g. screen/user name, IP address, browser      and device data, information collected through cookies, pixel tags and      other technologies, server log file data, app usage data and location      data, page views and website navigation
• Preferences (e.g. shopping habits, preferred educational courses)
• Company or school name and address, teacher name and email,      occupation, academic record, language proficiency
• Credit and debit card number, payment data or bank account details
• Medical condition (e.g. allergies or illness), dietary needs,      smoking habits, immunizations
• Travel details, passport copy, visa information
• Insurance data
• Name and contact details of family members

How do we collect Personal Data?

We collect Personal Data in a variety of ways:

• Directly from you: Information      is collected directly from you, either by you providing the information      directly to us or you acting in a manner that provides us with the      information, for example:
  • Offline: We collect Personal Data from you       offline, for example when you contact customer service, enrol in a       product or service or provide information to us in writing.
  • Online: We collect your Personal Data through       the BMI Products, for example when you sign up for a newsletter or a       brochure, enrol in a product or service. We also collect Personal Data:
    • Through cookies. Cookies allow a web server to transfer        data to a computer or device for recordkeeping and other purposes. If        you do not want information collected through the use of cookies, there        is a simple procedure in most browsers that allows you to decline the        use of cookies. For detailed information about the cookies we use and        the purposes for which we use them, please see our cookie policy.
    • Through your use of a mobile application. When you download and use one of our        mobile applications, and to the extent allowed by your privacy settings        in the application, we track and collect mobile application usage data,        such as the date and time the mobile application on your device        accessing our servers and what information and files have been        downloaded to the mobile application based on your device number number        as well as statistics on malfunctions and crashes that the users        experience.
    • Through your device. Provided that you have enabled that        function on your device, we collect the physical location of it to        provide you with personalized location-based services and content. Read        more about such services under “How do we use Personal Data?”
• From our corporate affiliates, business partners, assistance      providers or claim handlers. We      may receive Personal Data from other parties in conjunction with your      course/program, including:
  • Our corporate affiliates, such as the local BMI company that       promotes the sales of our services and offers customer service in your       country of residence and provides us with the Personal Data that is       needed to come to an agreement with you on your order, or the school in       your country of destination that provides some of the services that you       have ordered, or the Swiss principal company that is located in       Switzerland and is responsible for the performance of the contract with       you for any of BMI’s offers.
  • Business partners, such as local sales agents that promote the       sales of our services in your country of residence.
  • Claims handlers who receive information about your insurance       claims in case of an insurance situation.
• From other sources. We      may receive your Personal Data from other sources, such as public      databases; joint marketing partners such as marketing agencies or      providers of software and services for digital marketing automation and      analytics; social media platforms, including but not limited to; Facebook,      Instagram, Snapchat, Musically, LinkedIn, Twitter, YouTube and messenger      services such as WhatsApp or Facebook Messenger; from people with whom you      are friends or otherwise connected with on social media platforms, as well      as from other third parties. For example, if you elect to connect your      social media account to your BMI Products account, such Personal Data that      you have registered in your profile, such as your email address, phone      number, postal address, date of birth, name and user name will be shared      with us. Furthermore, we use cookies to track members of social media      networks as further explained in our cookie      policy.
• If you browse our sites. We      may also collect information about your use of our services through your      browser to trace activity on our sites, such as your Media Access Control      (MAC) address, computer type (Windows or Macintosh), screen resolution,      operating system name and version, device manufacturer and model,      language, Internet browser type and version, service provider, and the      name and version of the BMI Product you are using. In addition, an IP      Address is identified and logged automatically in our server log files      whenever you visit the BMI Products, along with the time of the visit and      the page(s) that were visited. You can read more about collection of your      IP address and other browsing data in our cookie      policy.

How do we use Personal Data?

We will use your Personal Data for the following purposes:

• Your Personal Data will be processed by BMI for the purposes of      completing your booking, providing you with the products and services that      you have ordered (including travel insurance coverage), for customer      service, administrative services or as otherwise necessary to perform the      contract between you and us or as further described in this policy.
• We may also use Personal Data:
  • For statistical purposes, system maintenance, backup, calculating       usage levels, and helping diagnose server problems with the BMI Products,       for business development as well as to ensure that the BMI Products       function properly.
  • To allow you to contact and be contacted by other users through       the BMI Products, as permitted by the applicable product.
  • To provide customer service or send service related information,       via various channels such as SMS, messenger services like WhatsApp,       Facebook Messenger, chat bots or email.
  • To allow you to participate on message boards, chat, profile pages       and blogs and use other services enabling you to post information and       materials.
  • Where relevant, to establish, exercise or defend legal claims;
  • To detect, investigate or prevent information security incidents,       fraud, misrepresentation, security incidents or crime;
  • To meet applicable legal, regulatory and compliance requirements
  • If you have given your consent:
    • To analyse and improve our offers by identifying        usage trends, determining the effectiveness of our promotional campaigns        and tailoring the BMI Products experience and content based on your past        activities on the BMI Products. For example, depending on what BMI        Product you have searched for on our website, or in previous browsing,        the offer presented to you on the BMI Products may be limited to a        specific language, course length or budget.
    • To provide you with personalized        location-based services and content through the use of your device’s        physical location. For example, you will be redirected to the local BMI        website in your language if your device indicates that you are browsing        from that country, or you may be suggested the nearest BMI office to        your location for visits or information.
    • To market our products and services,        including special promotions based on your interests, for example        through email marketing solutions such as Salesforce Marketing Cloud’s        management software which maintains mailing lists and schedules and        modifies email messages based on what recipients read, click-on or        forward, or through other channels such as SMS, other instant messenger        services or chat bots, telephone calls with operator (so-called        telemarketing) or traditional mail. All such communication will include        a clear unsubscribe link or offer another opt-out function.
    • For the transmission and communication to        third-party companies or other BMI companies for their marketing        purposes, including direct marketing activities and telemarketing.
    • We may offer a possibility to pay for the BMI        Products via payment solutions, including but not limited to, Klarna        Bank AB (publ), Sveavägen 46, 111 34 Stockholm (“Klarna”). In order to        offer you Klarna’s payment methods, we might share your personal data in        the form of contact and order details to Klarna, in order for Klarna to        assess whether you qualify for their payment methods and to tailor those        payment methods for you. Your personal data transferred is processed in        line with Klarna’s own privacy notice.

How do we share Personal Data?

We share your Personal Data as described below and in this Privacy Policy, and as permitted by applicable law:

• Corporate affiliates

Our corporate affiliates include, for example, a local BMI company that promotes the sales of our services and offers customer service in your country of residence, or the school in your destination country that provides some of the services that you have ordered, or BMI companies that provide internal service functions such as IT, legal or other shared services. If we have obtained your consent, we may also share your Personal Data with our BMI corporate affiliates for their own marketing purposes. A list of those affiliates can be found here as well as International Care Ltd, Selnaustrasse 30, 8001 Zürich.

• Third party service providers

We share Personal Data with third parties in connection with the delivery of services to you and the operation of our business. For example, we may share Personal Data to providers of IT systems in order to manage customer relations, process credit cards or other payment solutions, schedule classes or store learning results; or to providers of software and services for digital marketing automation and analytics; to advertising platforms; and to other third parties to provide customer service, business analytics, and fraud prevention and compliance services to serve you with advertising tailored to your interests [and to visa processing agencies.

• Travel suppliers

We share Personal Data with travel related suppliers, including hotels, airlines, bus or train service providers, as well as course leaders, activity leaders or other contractors in connection with the management of any of our programs; or a travel insurance company that prepares the travel insurance for you. Please note that travel suppliers may contact you to obtain additional information if and as required to facilitate your booking or to otherwise provide the travel or associated services.

• Business partners

We may share your Personal Data with business partners. This may happen, for example, when we promote a program or offer a service or product in conjunction with a third-party business partner or when we use local sales agents to promote the sales of our services in your country of residence. In most of those cases, the program or offer will include the name of the third-party business partner, either alone or with ours, or you will be redirected to the website of that business with notice.

• Other third parties

If you log in to an BMI product/service by using a single sign-on through a third party app or platform, you will share certain information with that social media platform, such as the fact that you have visited or interacted with us.

• Corporate transactions

In the event that our business is directly or indirectly sold or combined with another business, your Personal Data may be disclosed to our advisers, a prospective purchaser and any prospective purchaser’s advisers and may be transferred to the new owners of the business.

• Legal rights and obligations

We also share Personal Data as we believe to be necessary: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions or a contract; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

International Data Transfers

BMI has business activities in several different countries, and your Personal Data may be shared with affiliates of BMI or other recipients as described above that have a need to receive such data for the purpose of performing the services you have requested, or according to this policy. Such recipients may be located outside your own country, including countries outside the EEA/Switzerland that do not ensure the same level of protection as the country where you are domiciled. Unless the European Commission has decided that a country ensures an adequate level of protection for personal data, BMI will use contracts based on the European Commission’s standard data protection clauses for international transfers of personal data to ensure compliance with applicable law. You have a right to ask us for a copy of the standard data protection clauses (by contacting us as set out in the Contact Us section below).

On what do we base our right to collect and use Personal Data?

We have documented the lawful bases for our processing activities in Annex 1.

On some occasions, we process your Personal Data on the basis of your consent (for example, when you agree that we may set cookies other than those that are strictly necessary). To the extent we use sensitive Personal Data, we base this on your explicit consent. Sensitive data can for example be information about health, ethnicity or religious beliefs - read more under “Sensitive data”. Where we process data based on consent, your consent is revocable at any time.

The processing of some of your Personal Data is necessary in order to provide services to you pursuant to the agreement that you enter into with us. Without this information, we would not be able to provide certain services to you.

On other occasions, we process your data when we are required by law (for example, if we are required by court order or any applicable law to process data).

We also process your Personal Data when it is in our, or a third party’s, legitimate interests to do so, provided that your data protection rights do not override these interests. This may be to market products or services similar to the one(s) you have already purchased from that same legal entity. Where we are not relying on consent, legal requirements or contractual necessity, we process your Personal Data based on legitimate interests as described in this Policy.

Security

We use appropriate organizational, technical and administrative measures to keep the Personal Data under our control accurate and up-to-date, as well as to protect the Personal Data against unauthorised or unlawful processing and the accidental loss, destruction or damage of the Personal Data.

Unsubscribe

If at any time you wish to stop receiving marketing communications from us you can use the unsubscribe feature in the marketing communication you received or let us know by using the contact information listed in the “Contact Us” section. In your request, please indicate that you wish to stop receiving marketing communications from us.

Please note that changes may not be effective immediately. We will endeavour to comply with your request(s) as soon as reasonably practicable.

Third Party Sites

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site to which the BMI Product contain a link. The inclusion of a link on BMI Products does not imply endorsement of the linked site by us or by our affiliates.

Additionally, we may provide you with access to third-party functionality that permits you to share your activities on BMI Products to your social media account(s), for example Facebook or LinkedIn. Please note that any information that you provide through the use of this functionality is governed by the applicable third party’s privacy policy, and not by this Privacy Policy. We have no control over, and shall not be responsible for, any third party’s use of information that you provide through use of this functionality.

How long do we store personal data?

We will only keep your Personal Data for as long as it is necessary for the purposes for which it has been collected or in accordance with time limits stipulated by law and market practice, unless further retention is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims or unless a specific time period has been communicated.

We will keep limited parts of your Personal Data which are necessary for marketing purposes until you withdraw your consent, but in no event for longer than 10 years after your last completed service or delivery of product.

If you are under the age of 16

If you are under the age of 16, you should review this text together with your parent or guardian to make sure you both understand them. We are not responsible for checking your age but sometimes we still do verification checks. If we learn that you are under the age of 16 and that we have collected information about you without consent from your parent or guardian, we will delete the information as soon as possible and you will not be able to use BMI Products.

Sensitive Data

We do not generally seek to collect any sensitive Personal Data. Sensitive Personal Data is data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, health or medical condition, criminal background or trade union membership. In certain situations, this might however be necessary (for example in order to provide you with the services and products you have ordered and in relation to your insurance). We will make sure that we receive your explicit consent to such processing and treat this information securely.

Updates To This Privacy Policy

Our Privacy Policy may change from time to time. We will not significantly reduce your rights under this Privacy Policy without informing you. We will post any Privacy Policy changes on this page and, prior to implementing such changes, we will provide a more prominent notice. Where required by law, we will seek your prior consent to any change.

Your Rights

We respect your rights to access and control your information and will respond to requests in according with applicable privacy and data protection legislation. We may ask you to verify your identity and to provide other details to help us to respond to your request.

Depending on the lawful basis for processing upon which we rely, you have a right to:

1. request access to your Personal Data;
2. request that we correct or complete Personal Data that is      inaccurate or incomplete;
3. request that we erase your Personal Data, which we will do where      required by applicable privacy and data protection legislation;
4. restrict our processing of your Personal Data, in certain      circumstances;
5. request that we provide you with copies of your Personal Data in a      machine-readable format or transfer it across different services;
6. object to certain types of processing, including where we process      your Personal Data on the basis of our legitimate interests and for direct      marketing purposes; and
7. where we have asked for your consent to process your data, to      withdraw this consent.

These rights are limited in some situations under applicable privacy and data protection legislation – for example, where we can demonstrate that we are under a legal obligation or have other legitimate grounds to process your data.

If you wish to exercise these rights, please contact us using the contact details below. We hope that we can satisfy any queries you may have about the way we process your data. However, if you have unresolved concerns you also have the right to complain to data protection authorities.

Contact Us

If you would like to have a copy of the information BMI holds about you; a copy of the standard data protection clauses or would like to exercise any of your rights, please contact one of our locations or click here.

If you have complaints about our handling of your Personal Data, you have a right to contact the supervisory authority in the country where you live.

Annex

Type of and purpose of processing

Lawful basis for processing

Completing your booking, providing you with the   products and services that you have ordered (including travel insurance   coverage), for customer service, administrative services.

Processing is necessary for the performance of a   contract to which you are a party or in order to take steps at your request   prior to entering into a contract.

For statistical purposes, system maintenance,   backup, calculating usage levels, and helping diagnose server problems with   the BMI Products, for business development as well as to ensure that the BMI   Products function properly.

Legitimate interest in administering and   improving the BMI Products for the benefit of users.

To allow you to contact and be contacted by other   users through the BMI Products

Processing is necessary for the performance of a   contract

To provide customer service or send service   related information, via various channels such as SMS, messenger services   like WhatsApp, Facebook Messenger, chat bots or email.

Processing is necessary for the performance of a   contract

To establish, exercise or defend legal claims

· Legal obligation

· Legitimate interest in   bringing and defending legal claims to protect the business.

To detect, investigate or prevent information   security incidents and/or report fraud, misrepresentation or crime

· Legal obligation

· Legitimate interest in   detecting, investigating or preventing information security incidents,   misrepresentation and crime to protect (a) users of the BMI Products, and (b)   our directors, employees and consultants.

To meet applicable legal, regulatory and compliance   requirements.

· Legal obligation

· Legitimate interest in   ensuring compliance with applicable laws and regulations.

To analyse and improve our offers by identifying   usage trends, determining the effectiveness of our promotional campaigns and   tailoring the BMI Products experience and content based on your past   activities on the BMI Products.

Consent

To provide you with personalized location-based   services and content through the use of your device’s physical location.

Consent

To market our products and services, including   special promotions based on your interests

· Consent

· Legitimate interest, for   direct marketing of products or services similar to the one(s) you have   already purchased from that same legal entity within a limited period of time

For the transmission and communication to   third-party companies or our affiliates for their marketing purposes,   including direct marketing activities and telemarketing.

Consent

For the transmission and communication to   third-party companies for the purpose of offering payment solutions, travel   arrangement or IT service

· Performance of contract

· Legitimate interest in running   a commercial enterprise which employs the services of appropriate third party   service providers