Last modified: December 18, 2018
This Policy addresses how we collect, use and protect any information about you including personal information that directly or indirectly identifies you (“Personal Data”). Personal Data includes:
WES is the Data Controller of your Personal Data as defined in the European Union General Data Protection Regulation (“GDPR”). We process your Personal Data in accordance with GDPR and in accordance with the Personal Information Protection and Electronic Documents Act (Canada) and substantially similar provincial laws in Alberta, British Columbia and Quebec.” We collect Personal Data for our Services from the following sources:
The Personal Data we collect from you may be required to enter into a contract with WES for our services to evaluate and verify your educational credentials. If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data, we may not be able to enter into the contract or fulfill our obligations to you under it.
As you navigate through and interact with our Website or use our Application, we may use the following automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns:
We use these technologies to collect information about your online activities on our Website, in our Application, or on other online services (behavioral tracking). Some web browsers and mobile operating systems permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such signal is broadcast or received.
The information we collect automatically may include Personal Data that we receive from third parties. This information helps us to improve our Website and our Application and to deliver a better and more personalized service, by enabling us to:
The technologies we use for this automatic data collection include:
Some content or resources on the Website and in the Application are served by third parties. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly through the links provided on the provider’s website. For information about how you can opt-out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
If you are in the European Union or Canada, the processing of your Personal Data is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for the processing of your Personal Data (except when an exception applies as described below):
WES does not ask for any Personal Data that is defined as any of the special categories under the GDPR (“Sensitive Personal Data”). Please do not provide information revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information about genetic data or data concerning health, your sex life or sexual orientation or any information not specifically requested on the WES online application form.
WES does not use Personal Data with any automated decision-making process that produces legal effects concerning you.
We use information including your Personal Data that we collect about you:
With your consent, we may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you wish to consent to this use, please check the relevant box located on the form on which we collect your data. If you no longer wish to receive this information, please inform us through our Contact Us page. For more information, see Choices About How We Use and Disclose Your Information.
We may also disclose your Personal Data:
We do not control the collection and use of your Personal Data by the recipients that you have designated or third parties described above in Section 7. These third parties may provide you with ways to choose not to have your information collected or used through the links referenced above in Section 2. When possible, these organizations are under contractual obligations to use Personal Data only for providing necessary services to us and maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.
You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info). You can also opt out of receiving targeted ads from members of the NAI on its website.
In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We offer the following mechanisms to provide you with control over your Personal Data:
Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data.
If you have contracted evaluation services with WES, you have the right to cancel your request (cancellation fees apply). WES will no longer contact you regarding your evaluation unless we receive verification of fraud in which case we will notify you and appropriate authorities.
You have the right to be forgotten when we do not have a lawful basis for refusing such a request. Your Personal Data that you have supplied to WES will be retained according to our Data Retention Policy below. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies.
California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Website or Application that are California residents and who provide Personal Data in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Data to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Data and the names and addresses of those businesses with which we shared your Personal Data for the immediately prior calendar year (e.g., requests made in 2018 will receive information regarding such activities in 2017). You may request this information once per calendar year. To make such a request, please contact us using the information below in Contact Information. If you make this request via email, please use the subject “California Shine the Light Request.”
We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. All browser and other network connections to the Website and to our servers through our Application are encrypted using SSL technology. All credit card processing is handled by a third party payment gateway that is compliant with the Payment Card Industry Data Security Standard (PCI – DSS). Any information sent to WES in a physical format such as paper, is scanned into an electronic format and physical copies are securely destroyed. All electronic information is stored securely using industry standard access control and data protection mechanisms. WES deploys various security measures to protect the integrity of our systems, including intrusion prevention and detection systems.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website or the Application, you are responsible for keeping this password confidential. We ask that you use a unique password for our site and that you not share your password with anyone. To protect your security, you may be prompted to change your password from time to time. In keeping with security best practices, WES stores a cryptographic hash of your password rather than the password itself. If you forget your password we can help you reset your account and choose a new password, but we will not be able to retrieve your old password.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website or through our Application. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained in our Application or on the Website or our servers accessed through our Application.
If you are a resident of the European Economic Area (“EEA”) or Canada, in order to provide our Services, we may send and store your Personal Data outside of the EEA and Canada, including in the United States. Accordingly, your Personal Data may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an adequate level of protection for your Personal Data. Your information may be processed and stored in the United States, and the United States’ federal, state, and local governments, courts, law enforcement, or regulatory agencies may be able to obtain disclosure of your information through the laws of the United States. By using our Services, you represent that you have read and understood the above and consent to the storage and processing of Personal Data that you provide to our Services in locations outside of the EEA and Canada, including in the United States.
Data gathered on users of our Website, Application, and marketing tools is maintained:
WES only provides services for children under the age of 16 if their parent or legal guardian provides us with their information. If you are under 16, do not register on the Website or in the Application, provide information to our Services, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received any information from a child under 16 without verification of parental or guardian consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at Contact Information below.
World Education Services
Bowling Green Station
P.O. Box 5087
New York, NY 10274-5087
WES Data Protection Officer
World Education Services
Bowling Green Station
P.O. Box 5087
New York, NY 10274-5087
If you are a resident of the EU or if you have a question or concern about our compliance with GDPR, you must also contact our representative in the EU using the contact information below. Our EU representative will not pass along any academic records to WES, and they will be deleted in compliance with GDPR.
For instructions on how to send academic documents to WES, please refer to our Required Documents page, or Contact Us for more information.
EU Data Protection Representative
Office 29, Clifton House
Fitzwilliam Street Lower