Privacy Policy
Your privacy is extremely important to us and we are committed to protecting your Personal Data. This Privacy Policy informs you about how we collect, use, disclose, manage and protect the Personal Data you provide to us when accessing or using the Platform and the Platform Services (regardless of where you visit it from), what we do with your Personal Data, how you can control what Personal Data we collect from you and what your privacy rights are.
Unless specifically defined, terms used throughout this Privacy Policy have the same definitions as those given in Edways’ General Terms and Conditions.
Please read this Privacy Policy carefully before using the Platform or submitting any information to us.
This Privacy Policy will apply when you visit the Platform, sign up for, access, or use our Services, features, technologies or functions offered on or through our Platform. When you access and use the Platform, or otherwise provide any Personal Data to us, you acknowledge that you have read, understood, and agreed to this Privacy Policy, as amended from time to time, including the manner in which we use your Personal Data. We may, from time to time, amend this Privacy Policy or parts of it in accordance with clause 2.3 below. If you do not agree to this Privacy Policy, or to any changes we subsequently make to this Privacy Policy, you must immediately stop using the Platform and/or the Platform Services or otherwise providing any Personal Data or information to us.
1. Definitions
a. “ Applicable Law” means all the laws, rules, regulations, notifications, guidelines, ministerial decisions or cabinet resolutions in force and effect, as of the date hereof and which may be promulgated or brought into force and effect hereinafter in the United Arab Emirates, including judgments, decrees, injunctions, or orders of any court of record, as may be in force and effect during the subsistence of this Privacy Policy;
b. “Account Connection”has the meaning given to it in clause 6.8;
c.“Aggregated Data”has the meaning given to it in clause 4.3;
d. “comply with a legal or regulatory obligation” means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to in accordance with the Applicable Law;
e. “Data” means personal and non-personal User’s data that is submitted, generated, featured and displayed through the Platform, collected from the use of the Platform Services and stored on Edways’ servers;
f. “ Edways’ General Terms and Conditions ” means all of the terms, conditions and notices contained or referenced in our General Terms and Conditions and all other Edways rules, policies (as amended from time to time) available at www.edways.com, as amended from time to time;
g. “Legitimate Interest(s)” means the interest of our business in conducting and managing our Platform Services to enable us to give you the best services and the best and most secure experience. We consider and balance any potential impact on you and your rights before we process your Personal Data for our legitimate interests;
h. “Performance of our Services” means processing your Data where it is necessary for the performance of the Platform Services;
i. “Personal Data” means information that specifically identifies an individual (such as a name, address, photo, telephone number, mobile number, e-mail address, birthday, office location, professional and personal interests, company name, title, department, spoken languages) or information about that individual that is directly linked to personally identifiable information;
j. “Privacy Policy” means all of the privacy policies, practices and notices contained or referenced in this document (as amended from time to time) and all other Edways rules, policies available on the Platform that may be published from time to time on the Platform.
k. “Edways” “we” “our” and “us” collectively mean One Stop Skool FZ-LLC; and
l. “User”, “you” and “your” collectively mean the person, company, or organization that has visited and/or is browsing and/or using the Platform and/or the Platform Services. A User may be, without limitation, an Edways Parent, a School (or its Authorized Users), both or neither.
2. Important Information
1. Who We Are and How to Contact Us
a.The Platform is owned and operated by One Stop Skool FZ LLC, a UAE company organized under the laws of the Dubai Development Authority with a commercial license number 99940.
b. If you have questions or concerns regarding this Privacy Policy, or any feedback pertaining to your privacy and the Platform Services that you would like us to consider, please contact us at info@edways.com.
2. Purpose of this Privacy Policy
c. This Privacy Policy aims to give you information on how Edways collects and processes your Personal Data through your use of this Platform, including any Data you may provide through the Platform when you register an Account, use any Platform Services and/or sign up to our newsletter.
d. It is important that you read this Privacy Policy together with the Edways’ General Terms and Conditions, and any fair processing notice we may provide on specific occasions when we are collecting or processing your Personal Data so that you are fully aware of how and why we are using your Personal Data. This Privacy Policy supplements any other privacy notices we may provide to you from time to time and is not intended to override them.
e. This Privacy Policy applies to your use of our Platform and/or Platform Services and all information we collect through our Platform Services. By accessing and using the Platform, you (i) agree irrevocably and without condition to this Privacy Policy, (ii) consent to your Personal Data being collected, processed, used and shared in accordance with this Privacy Policy, and (iii) agree that we may provide notices to you on the terms and conditions set forth in this Privacy Policy and Edways’ General Terms and Conditions.
f. Schools are independent of Edways and may have privacy policies which differ from this Privacy Policy. Schools are responsible for their own privacy policies and privacy practices. Please contact Schools directly for further information on their privacy policies.
3. Changes to the Privacy Policy and your duty to inform us of any changes in your Personal Data
a.We reserve the right, in our sole discretion, to amend this Privacy Policy at any time by publishing the varied terms on the Edways Platform, with or without notice. Although we will use our best endeavors to notify you of any amendment to this Privacy Policy through a dedicated link available at our Platform, we will not be required to provide you with prior notification of such amendments or changes to this Privacy Policy. You are responsible for regularly reviewing information posted on our Platform, including this Privacy Policy to obtain timely notice of such changes. As such, we recommend that you check the Platform each time you visit our Platform and/or prior to each use of our Platform Services to ensure you are aware of the applicable terms. Your continued use of the Platform constitutes your acceptance of any amendments or changes to the Privacy Policy.
b. Please note that it is crucial to the Performance of our Services and functionality of the Platform that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us. You can review and update your Personal Data in your Family Profile at any time by logging in to your Account.
4. Third-party services and links
a.We may allow you to log in to the Platform through various online third-party services, such as social media and social networking services like Google, Facebook or Twitter. In order to use these features and capabilities, we may ask you to authenticate, register for, or log into third-party services on the websites of their respective providers. As part of this integration, the third-party services may provide us with access to certain Data you have provided to them, and we will use, store, and disclose such information in accordance with this Privacy Policy.
b. Third-party services use, store, and disclose your information solely in accordance with their own policies. We encourage you to read the privacy policy of such third-party services. We assume no responsibility or liability for the privacy practices or any other actions of any third-party website or service that may be enabled within the Platform Services or of which a link is included on the Platform. Further, we assume no responsibility or liability for any damage or loss caused or alleged to be caused by or in connection with the use of or reliance on any such third-party services.
3. Age of Consent
1. The Platform and Platform Services are intended for Users who are at least 18 years old. Users under the age of 18 are not permitted to register for the Platform. By accessing the Platform and using the Platform Services, you represent and warrant that you are at least 18 years old.
2. Any Users who is a minor in the jurisdiction in which they reside (generally under the age of 18) must have the permission of, and be directly supervised by, their parent or legal guardian to use or access the Platform or Platform Services. If you are a minor, you must have your parent or legal guardian read and agree to this Privacy Policy prior to you using or accessing the Platform or Platform Services.
4. Personal Data We Collect
1. To let us operate the Platform effectively and to let you use the Platform, we may collect, use, and store Personal Data described below depending on which of our Platform Services you use and how you interact with our Platform. We also disclose certain information to third-parties, as described further below. The information we collect is received directly or indirectly from you and generated in the course of your use of the Platform. The data we collect is not used for marketing or any other purposes except as specified in this Privacy Policy. See examples of the data we collect below:
- Identity Data includes first name, last name, address, username or similar identifier, job title, company name, date of birth, gender, nationality, passport details, photos, or third-party application IDs.
- Contact Data includes country of residence, address, email address and telephone numbers.
- Academic Data includes school and other academic reports and academic and disciplinary history.
- Application DataincludesIdentity Data, Contact Data, Academic Data, Medical Data, religion, start date and entry year group.
- Medical Dataincludes allergies and other medical conditions and learning disabilities.
- Payment Data includes bank account and payment card details, payment history.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, device type, time zone setting and location, browser plug-in types and versions, operating system, and other technology identification on the devices you use to access the Platform.
- Account Registration Dataincludes any Account information provided by you in connection with the Account registration process whether you registered using any third party services and whether you verified your email address or phone number through the Platform.
- Usage Data includes information about how you use our Platform and the Platform Services, including information on interactions with other Users and how you use your devices to access our Platform, including the screens you visit and searches you make, list of Schools shortlisted, School of choice, with whom you chat, number of your School applications, School offer details, name of School enrolled into, Schools that you toured and number of School assessments.
- Login Data:includes information regarding logins and activity conducted during that log in.
- Marketing and Communications Dataincludes your preferences in receiving marketing and your communication preferences.
- Other Dataincludes :
o any other Data uploaded onto our Platform by you or shared with other Users of our Platform by you via our Platform;
o partner information related to how you use our partners, such as your reviews of our Partner Schools or other third-party service providers;
o communications with us via social media platforms, email, electronic messages and other electronic and non-electronic communications; and
o your networks and connections made available to us, depending on the permissions you have granted, from your mobile and desktop devices, address book contacts, and other social media.
2. We also get information about you and your activity outside the Platform from our affiliates, advertisers, partners and other third parties we work with. For example, online advertisers or third parties share information with us to measure, report on or improve the performance of ads, or to figure out what kinds of ads to show you.
3. We also collect, use and share high-level Data which is acquired by combining individual-level Data such as statistical or demographic Data (“Aggregated Data”) for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data as this Data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. We may provide aggregate information to our partners about how our Users, collectively, use our site, so that our partners may also understand how often Users use their services and our Platform Services. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat such combined Data as Personal Data which will be used in accordance with this Privacy Policy.
4. We do not collect any Personal Data about your race or ethnicity, or philosophical beliefs, sexual orientation, political opinions, and genetics. Nor do we collect any information about criminal convictions and offenses.
5. Where we need to collect Personal Data by Applicable Law, or under the terms of a contract we have with you and you fail to provide that Personal Data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the Platform Services). In this case, we may have to cancel the Platform Services which you have with us, provided that we will notify you if this is the case at the time.
5. How We Collect Your Personal Data
1. We collect Personal Data through one or more of the following ways:
a.From information you provide to us either directly or through your company;
b. When you communicate with us in writing, by telephone, fax, email or through the Platform or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
c. When you register an Account with our Platform;
d. From publicly available sources, third-parties and social media platforms, most commonly where we need to conduct background checks about you;
e. Your interactions. You may give us your and your child’s Identity Data, Contact Data, Academic Data, Application Data and Medical Data, including such data of your child or authorized representative by filling in forms or by corresponding with us by post, phone, and email or otherwise. This includes Personal Data you provide when you:
i.visit or interact with the Platform;
ii.use our Platform Services, including shortlisting and applying to Schools;
iii.subscribe to our publications;
iv.enter a competition, promotion or survey;
v.interact with other Users, including communicating with Edways Parents or Schools;
vi.enter data for installing or using any Edways powered application and/or installing;
vii.correspond with us (online or offline including via email addresses and phone numbers), if you contact us;
viii.elect to receive marketing communications from us;
ix.post Content on our Platform; and
x.give us feedback and/or review our Platform Services or other Users.
f. Automated technologies or interactions. As you interact with our Platform, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
g.Third parties or publicly available sources. We may receive Personal Data about you from various third-parties and public sources as set out above and Technical Data from the following parties:
i.analytics providers such as Google;
ii.advertising networks/agencies; and
iii.search information providers.
6. How do we share your Personal Data?
1. We will not sell your personal data to third-parties.
2. Information shared with everyone in the community: We may publicly share some of your Data such as School Profiles and Edways Parents’ reviews on the Platform.
3. Information shared with Schools: As an Edways Parent, if you access our Platform and use any of the Platform Services, we may share your Personal Data as may reasonably be required by the Schools to help them perform their respective services. For example, when an Edways Parent applies to a School, we will share the Application Data with the relevant School. Upon obtaining the Edways Parents’ consent, we may also share certain Identity Data and Academic Data of their child (e.g. child name, entry year, entry group) with a School prior to initiating a chat or scheduling a call with that School.
4. Information shared with Edways Parents: We may share Personal Data of the Authorized Users’ of a School, including first name, last name, position, mobile number, email and any other information as may be reasonably required by the Edways Parent to avail of the School’s services and/or the Platform Services.
5. Vendors and service providers: We may also share your Personal Data with vendors and serviceproviders, including our data hosting and data storage partners, chatbot providers, analytics and advertising providers, and vendors providing technology services and support, payment processing, and data security. We also may share information with professional advisers, such as auditors, law firms, and accounting firms. We require all such vendors to respect the security of Personal Data and to treat it in accordance with the Applicable Law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
6. Business transfer: In the event that Edways is involved in a merger, acquisition, reorganization, sale of assets or bankruptcy, your information may be sold or transferred as part of that transaction. The promises in this Privacy Policy will apply to your information as transferred to the new entity.
7. Protection of the Edways and others: We may release Personal Data when we believe in good faith that release is necessary to comply with the Applicable Law; enforce or apply the Edways’ General Terms and Conditions and other agreements; or protect the rights, property, or safety of Edways, our employees, our Users, or others.
8. Other third-parties: We may share your Personal Data with other third parties with your consent or at your direction to do so, including if you authorize an account connection with a third-party account or platform. For the purposes of this Privacy Policy, an "account connection" with a third party is a connection you authorize or enable between your Account with us and any other account or platform that you lawfully control or own (“Account Connection”). When you authorize such a connection, we may receive information from the third-party about you and your use of the third-party’s service and we may share your Personal Data and other information, to be used in accordance with such third party’s privacy policy. Examples of account connections include, without limitation, linking your Account to an API provider, social media account or social messaging service. Information that we share with a third-party based on an Account Connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorizing an Account Connection, you should review the privacy notice of any third-party that will gain access to your Personal Data as part of the Account Connection.
9. Aggregated and Anonymized Information:We may share aggregated and anonymized information that does not specifically identify you or any User of our Platform Services with service providers or other third parties.
7. Purposes for which we will use your Personal Data
1. We will only use your Personal Data in accordance with the Applicable Law.
2. We use your Personal Data to operate, provide, develop, and improve the products and services that we offer our Users. These purposes include:
a. Performance of the Platform Services.We process your Personal Data because it is necessary for the Performance of the Platform Services and for any other purpose for which you provide us with your Personal Data.
b. Providing, troubleshooting, and improving our Platform and Platform Services. We use your Personal Data to provide functionality, analyze performance, fix errors, and improve the usability and effectiveness of our Platform and Platform Services.
c.Legitimate interests. We also process your Personal Data because it is necessary for our Legitimate Interests, or sometimes where it is necessary for the Legitimate Interests of another person.
d. Recommendations and personalization. We use your Personal Data to recommend features and services that might be of interest to you, identify your preferences, and personalize your experience on the Platform.
e. Issuing reports/analytics on a no name basis for business and marketing purposes.
f. Communication. We use your Personal Data to communicate with you and also enable Users to communicate with each other.
g. Marketing:We may send you marketing about the Platform Services we provide which may be of interest to you, as well as other information in the form of alerts, newsletters and invitations to the events or functions which we believe might be of interest to you or in order to update you with information (such as legal or commercial news) which we believe may be relevant to you. We may communicate this to you in a number of ways including through the Platform, telephone, SMS, email, post or other digital channels. You have the right to withdraw/unsubscribe your consent to marketing emails/newsletters at any time by contacting us at info@edways.com .
h. Comply with legal obligations. We will use your Personal Data for: (i) meeting our compliance and regulatory obligations, enforcing any Applicable Law, regulations, legal requirements, and industry standards (such as compliance with anti-money laundering laws) and responding to lawful requests for information from the government or in relation to any legal process; and (ii) as required by tax authorities or any competent court or legal authority.
3. Change of purpose: We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by Applicable Law.
8. Cookies
1. Our Platform uses web technologies such as cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you use our Platform. We use the following cookies:
1. Strictly necessary cookies. These are cookies that are required for the operation of our Platform. They include, for example, cookies that enable you to log into secure areas of our Platform.
2. Analytical/performance cookies. They allow us to recognise and count the number of Users and to see how Users move around our Platform when they are using it. This helps us to improve the way our Platform works, for example, by ensuring that Users are finding what they are looking for easily.
3. Functionality cookies. These are used to recognise you when you return to our Platform. This enables us to personalise our Content for you, greet you by your name and remember your preferences (for example, your choice of language or region).
4. Targeting cookies. These cookies record your visit to our Platform, the pages you have visited and the links you have followed. We will use this information to make our Platform and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
2. While we set some of these automated technologies ourselves, some of them are set by third-parties who provide services to us. For example, we may use other companies’ web analytics services such as Google Analytics, which use automated technologies to help us evaluate how our Users use our Platform.
3. You can set your browser to refuse all or some browser cookies or to alert you when our Platform sets or accesses cookies. If you use a mobile device, you can manage how your device and browser share certain device data by changing the privacy and security settings on your mobile device. If you disable or refuse cookies, please note that some parts of our Platform may become inaccessible or not function properly.
9. How we make sure your Personal Data is secured
1. Your Personal Data shall be stored in accordance with the Applicable Law. To protect your Personal Data, we take reasonable precautions to try to ensure that it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
2. We implement and maintain appropriate technical, security and organisational measures in relation to the processing of your personal data so that the processing will meet the requirements of Applicable Law and ensure the protection of your rights.
3. Although we aim to create a safe and secure environment, we cannot guarantee absolute security of the transmission or storage of your information. To the extent permitted by applicable law, we expressly exclude any liability arising from any unauthorised access to your Personal Data.
4. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so under Applicable Law.
5. Please contact us at immediately if you become aware of any unauthorised use of your Account by anyone else or any other breach of security.
10. Retaining Personal Data
1. We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you or to comply with a legal or regulatory obligation.
2. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
3. In some circumstances, we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
11. Your Rights
1. You may have certain rights under Applicable Law in relation to your Personal Data. Such rights include:
a.Right to request access to your Personal Data (commonly known as a "data subject access request").This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
b. Right to request correction of the Personal Data that we hold about you.This enables you to have any incomplete or inaccurate Data we hold about you corrected, though we may need to verify the accuracy of the new Data you provide to us.
c. Right to object to processing of your Personal Data. You have the right to object where we are processing your Personal Data. For example, for direct marketing purposes.
d. Right to request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
i.If you want us to establish the Data's accuracy.
ii.Where our use of the Data is unlawful but you do not want us to erase it.
iii.Where you need us to hold the Data even if we no longer require it as you need it to establish, exercise or defend legal claims.
iv.You have objected to our use of your Data but we need to verify whether we have overriding legitimate grounds to use it.
e. Right to request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
f. Right to withdraw consent at any time where we are relying on consent to process your Personal Data. You may withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Platform Services to you. We will advise you if this is the case at the time you withdraw your consent.
2. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Personal Data (where consent is our legal basis for processing your Personal Data), please contact us via this e-mail address: info@edways.com.
3. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
4. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
5. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
6. Whilst we will always work with you to resolve any concerns you have about the use of your Personal Data, you may have the right to lodge a complaint with the supervisory authority in your country of residence if you have any concerns about our use of your Personal Data.
7. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during the period for which we hold it.
12. Protecting your fellow User’s privacy and intellectual property rights
1. We respect other people's rights, and expect you to do the same. We can remove any content or information you post on the Platform if we believe that it violates this Privacy Policy. If you collect information or Personal Data from Users, you will obtain their consent, make it clear you (and not us) are the one collecting their information or Personal Data, and post a privacy policy explaining what information or Personal Data you collect and how you will use it. You will not post anyone's Personal Data on the Platform. You will not tag fellow Users or send email invitations to non-Users without their consent.
13. Transfers
1. The Personal Data that we collect from you may be transferred to, and stored at, a destination outside of the United Arab Emirates in accordance with the Applicable Law. By using the Platform and availing the Platform Services, you agree that your Personal Data may be transferred to, and stored at, a destination outside of the United Arab Emirates.
2. Your Personal Data may also be processed by staff operating outside the United Arab Emirates who work for us or for one of our service providers. Such staff may be engaged in, among other things, the fulfilment of the Platform Services and the provision of support services. Your Personal Data may be transferred, stored, processed and used by our affiliated companies and/or non-affiliated service providers in one or more countries outside the United Arab Emirates.
14. Privacy Disputes
1. You will resolve any claim, cause of action or dispute (claim) you have with us arising out of or relating to this Privacy Policy exclusively before the Courts of Dubai. The laws of the United Arab Emirates will govern this Privacy Policy, as well as any claim that might arise between you and us, without regard to conflict of law provisions.
Effective as of 01 May 2023