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    Privacy Policy of Go! 21 Education
    
    Definitions
    
    “Go! 21 Education” means the company (company number 575655) which operates through its website www.go21.me or www.cn.go21.me  (the “Website”) and is the data controller (the “Data Controller”) for the purposes of the Data Protection Acts 1988 and 2003 (the “Data Protection Acts”).
    
    “Services” means acting as intermediary between the customers of the data controller and potential hosts, and on acceptance by both parties of the Irish college, university, institute of technology application arrangement and accommodation arrangement, placing the customers of the data controller and potential Irish higher education institutions and accommodation in contact.
    
    “Customers” are the subject of data for the purpose of the Data Protection Acts (hereinafter called the “Data Subject”).
    
    Privacy Policy
    
    The policy of the Data Controller is to comply with the Data Protection Acts. By visiting the website of the Data Controller, the Data Subject accepts the terms of this privacy policy.
    
    This Privacy Policy describes how we collect, use, process, and disclose your information, including personal information, in conjunction with your access to and use of the Go! 21 Education Website and the Payment Services.
    
    This Privacy Policy also applies to the Payment Services provided to you through Go! 21 Education, pursuant to the Payment terms laid out in our FAQ section.  When using our Payment Services, you will be also providing your information, including personal information, to Go! 21 Education, which will also be the Data Controller (the "Payments Data Controller") of your information related to the Payment Services.
    
    Data Collected By The Data Controller
    
    “Personal Data” means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller.
    
    “Non-Personal Data” means data that is not Personal Data.
    
    “Data” means Personal Data and Non-Personal Data.
    
    “Credit and Debit Card Details” means payment information details, credit and debit card numbers and bank details stored and encrypted in a PCI compliant data centre, managed by Stripe Payments UK Limited.
    
    1. INFORMATION WE COLLECT
    
    There are three general categories of information we collect.
    
    1.1 Information You Give to Us.
    
    1.1.1 Information that is necessary for the use of our services on the Go! 21 Education Website.
    
    We ask for and collect the following personal information about you when you use the Go! 21 Education website. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.
    
    Irish college and university application. When you apply to study in Ireland with Go! 21 Education, we require certain information such as your first name, last name, email address, home address, phone number and date of birth.
    
    Student Identity Verification Information. To help create and maintain a trusted environment, we ask you to give us some identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information such as your academic transcript results, resume and etc.
    
    Accommodation arrangement in Dublin and Cork. To book your accommodation through Go! 21 Education, we require you to provide certain personal information (if you have any pet or food allergies) in order to facilitate the processing of accommodation via ISA (International Student Accommodation, Eazycity). We also require that you tell us about your budget so we can arrange the most suitable accommodation for you (as well as other information such as location/college, duration of studies/internship etc).
    
    Communications with Go! 21 Education. When you communicate with Go! 21 Education we collect information about your communication and any information you choose to provide.
    
    1.1.2 Information you choose to give us.
    
    Additional Student  Information. Students may choose to provide us information when making an application. This may be additional information about their stay in Ireland and their studies/internship.
    
    1.1.3 Information that is necessary for the use of the Payment Services (Stripe).
    
    The Payments Data Controller needs to collect the following information, as it is necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to book accommodation with Go! 21 Education:
    
    Payment Information. When you use the Payment Services (Stripe), the Payments Data Controller requires certain financial information (like your bank account or credit card information) in order to process payments and comply with applicable law.
    
    Identity Verification and Other Information. The Payments Data Controller may require identity verification information (such as images of your government issued ID, passport, national ID card, or driving license) or other authentication information, your date of birth, your address, email address, phone number and other information in order to verify your identity, provide the Payment Services to you, and to comply with applicable law.
    
    1.2 Information We Automatically Collect from Your Use of the Go! 21 Education Website and Payment Services (Stripe).
    
    When you use the Go! 21 Education Website and the Payment Services, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Go! 21 Education website and Payment Services (Stripe).
    
    Geo-location Information. When you use certain features of the Go! 21 Education website, we may collect information about your precise or approximate location as determined through data such as your IP address.
    
    Usage Information. We collect information about your interactions with the Go! 21 Education Website, such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on the Go! 21 Education website.
    
    Log Data and Device Information. We automatically collect log data and device information when you access and use the Go! 21 Education website. That information includes, among other things: details about how you’ve used the Go! 21 Education website (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Go! 21 Education website.
    
    Cookies and Similar Technologies. We use cookies and other similar technologies, such as tags, pixels, heat maps and mobile identifiers. While you may disable the usage of cookies through your browser settings, the Go! 21 Education website currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted. For more information on our use of these technologies, see our Cookie Policy.
    
    Payment Transaction Information. Go! 21 Education Payments collect information related to your payment transactions through the Go! 21 Education website, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details. This information is necessary for the adequate performance of the contract between you and Go! 21 Education to allow the provision of the Payment Services (Stripe).
    
    1.3 Information We Collect from Third Parties.
    
    Go! 21 Education may collect information, including personal information, about you through third parties.
    
    Third Party Services. If you click on a link through Facebook, Instagram, Twitter, or another third party website, the third party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
    
    Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Go! 21 Education website through third parties.
    
    2. HOW WE USE THE INFORMATION WE COLLECT
    
    We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the Go! 21 Education website and our services to you, to create and maintain a trusted and safer environment and comply with our legal obligations.
    
    2.1 Provide, Improve, and Develop the Go! 21 Education Website.  
    
    Enable you to access and use the Go! 21 Education Website.
    
    Operate, protect, improve, and optimize the Go! 21 Education Website experience, such as by performing analytics and conducting research.
    
    Provide customer service.
    
    Send you service or support messages, updates, security alerts, and notifications.
    
    If you provide us with your contacts’ information, we may process this information: (i) to send you requests for references, (ii) for fraud detection and prevention, and (iii) for any other purpose you authorize at the time of collection.
    
    We process this information given our legitimate interest in improving the Go! 21 Education website  and where it is necessary for the adequate performance of the contract with you.
    
    2.2 Create and Maintain a Trusted and Safer Environment.
    
    Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
    
    Conduct security investigations and risk assessments.
    
    Verify or authenticate information or identifications provided by you (such as to verify your Accommodation address or compare your identification photo to another photo you provide).
    
    Conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required.
    
    Comply with our legal obligations.
    
    Resolve any disputes with between any of our hosts and students.
    
    Enforce our Terms & Conditions set out in our FAQ section.
    
    In connection with the activities above, we may conduct profiling based on your interactions with the Go! 21 Education website, your profile information and other content you submit to the Go! 21 Education website, and information obtained from third parties.
    
     
    
    We process this information given our legitimate interest in protecting the Go! 21 Education website, to measure the adequate performance of our contract with you, and to comply with applicable laws.
    
    2.3 Provide, Personalise, Measure, and Improve our Advertising and Marketing.
    
    Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Go! 21 Education) and social media advertising through social media platforms such as Facebook, Instagram or Google).
    
    Personalize, measure, and improve our advertising.
    
    Administer referral programs, rewards, surveys,, contests, or other promotional activities or events sponsored or managed by Go! 21 Education.
    
    We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of interest to you. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications.
    
    2.4 How the Payments Data Controller (Stripe) uses the Information Collected.
    
    Enable you to access and use the Payment Services.
    
    Detects and prevents fraud, abuse, security incidents, and other harmful activity.
    
    Conduct security investigations and risk assessments.
    
    Conduct checks against databases and other information sources.
    
    Comply with legal obligations (such as anti-money laundering regulations).
    
    Enforce the Payment Terms and other payment policies.
    
    With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.
    
    The Payments Data Controller (Stripe) processes this information given its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.
    
    2.5 Security
    
    Data is held on secure servers hosted by Hubspot. Data is encrypted using SSL.
    
    3. SHARING & DISCLOSURE
    
    3.1 With Your Consent.
    
    Where you have provided consent, we share your information, including personal information, as described at the time of consent.
    
    3.2 Sharing between Hosts, Irish universities and colleges and Students.
    
    To help facilitate bookings or other interactions between hosts, Irish universities and colleges and students, we may need to share certain information, including personal information, between the other parties and students, as it is necessary for the adequate performance of the contract between you and us, as follows:   
    
    When you as a Student submit a college application, certain information about you is shared with the Irish universities and colleges, including your full name, the description you submitted of yourself and the details of your studies along with other information you agree to share. When your application is confirmed, we will disclose additional information to assist with coordinating your application, like your payment instructions.
    
     When you as a Student submit an accommodation application through Go! 21 Education, certain information about you is shared with the accommodation provider, including your full name, the description you submitted of yourself and the details of your studies along with other information you agree to share. When your application is confirmed, we will disclose additional information to assist with coordinating your application, like your payment instructions.
     
    
    3.3 Profiles, Listings, and other Public Information.
    
    The Go! 21 Education website publishes Irish universities, colleges and institute of technologies listing profile and that is visible to the general public. For example:
    
    Institution description, courses available, scholarship information, short video introduction etc.
    
    
    The Go! 21 Education website also publishes accommodation listing profile and that is visible to the general public. For example:
    
    Accommodation renting prices, staying length, accommodation application fee, accommodation location and etc.
    
    
    3.4 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.
    
    Go! 21 Education may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Go! 21 Education, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms & conditions, or (v) to protect the rights, property or personal safety of Go! 21 Education, its employees, its Irish higher education partners, Students, Accommodation partners or members of the public.
    
    Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Go! 21 Education’s property.
    
    3.5 Social Media Platforms.
    
    Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Go! 21 Education website. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be of interest to you.
    
    The social media platforms with which we may share your personal data are not controlled or supervised by Go! 21 Education. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider.
    
    Please note that you may, at any time ask Go! 21 Education to cease processing your data for these direct marketing purposes by sending an e-mail with the subject title ‘Opt Out’ to hello@go21.me.
    
    3.6 Business Transfers.
    
    If Go! 21 Education undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.
    
    3.7 Aggregated Data.
    
    We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
    
    4. OTHER IMPORTANT INFORMATION
    
    4.1 Google Maps/Earth.
    
    Parts of the Go! 21 Education website uses Google Maps/Earth services, including the Google Maps API(s). Use of Google Maps/Earth is subject to Google Maps/Earth Additional Terms of Use and the Google Privacy Policy.
    
    5. THIRD PARTY PARTNERS & INTEGRATIONS
    
    The Go! 21 Education website may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). Go! 21 Education doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, Go! 21 Education, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
    
    6. YOUR RIGHTS
    
    6.1 Managing Your Information.
    
    As a Student, if you wish to update or edit any of the information on your application, you may do so at any time by sending a request to us by email at hello@go21.me. You are responsible for keeping your personal information up-to-date.
    
    6.2 Rectification of Inaccurate or Incomplete Information.
    
    You have the right to ask us to correct inaccurate or incomplete personal information concerning you..
    
    6.3 Data Access and Portability.
    
    In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
    
    6.4 Data Retention and Erasure.
    
    We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide Go! 21 Education services to you, you can request that we erase your personal information and delete your Go! 21 Education listing. Please note that if you request the erasure of your personal information:
    
    We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety.
    
    We may retain and use your personal information to the extent necessary to comply with our legal obligations.
    
    Because we maintain the Go! 21 Education website to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
    
    6.5 Withdrawing Consent and Restriction of Processing.
    
    Where you have provided your consent to the processing of your personal information by Go! 21 Education you may withdraw your consent at any time by sending an email to hello@go21.me specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of Go! 21 Education override your own.
    
    6.6 Objection to Processing.
    
    In some jurisdictions, applicable law may entitle you to require Go! 21 Education not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Go! 21 Education will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
    
    Where your personal information is processed for direct marketing purposes, you may, at any time ask Go! 21 Education to cease processing your data for these direct marketing purposes by sending an e-mail with the subject title ‘Opt Out’ to hello@go21.me.
    
    6.7 Lodging Complaints.
    
    You have the right to lodge complaints about the data processing activities carried out by Go! 21 Education before the competent data protection authorities, the Irish Data Protection Commissioner.
    
    7. GOVERNING LAW AND JURISDICTION
    
    This Privacy Statement is governed by the laws of Ireland and is subject to the exclusive jurisdiction of the Irish courts.
    
    8. SECURITY
    
    We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Go! 21 Education application information have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Go! 21 Education listing, please contact us by email at hello@go21.me.
    
    9. CHANGES TO THIS PRIVACY POLICY
    
    Go! 21 Education reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Go! 21 Education Website on the Privacy Policy section. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your application. If you do not cancel your application before the date the revised Privacy Policy becomes effective, your continued access to or use of the Go! 21 Education website will be subject to the revised Privacy Policy.
    
    9.1 EXCLUSION OF LIABILITY
    
    The Data Controller and its subsidiaries, affiliates, officers, agents and employees are not liable from and against any claim, liabilities, damages, losses and/or expenses, including, without limitation, reasonable legal and accounting fees, arising out of or in any way connected with: (i) any claims made by Data Subjects; (ii) the provision of Services; and (iii) third party use of Data.
    
    10. QUESTIONS OR COMMENTS
    
    If you have any questions or complaints about this Privacy Policy or Go! 21 Education’s information handling practices, you may email us at hello@go21.me