Privacy Policy

This outlines the data we collect and how we keep it safe.

This Privacy Policy describes our practices for collecting, using, protecting and disclosing the Personal Data we collect from you when you visit our website freeforstudents.org and use our services.

  1. 1. General Information
    1. 1.1. WHAT IS PERSONAL DATA? Personal data is any information about personal or factual circumstances relating to an identified or identifiable natural person. This includes, for example, your name, date of birth, email address, postal address or telephone number and online identifiers such as your IP address.
    2. 1.2. WHAT IS PROCESSING? "Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually any processing of data.
    3. 1.3. WHO IS RESPONSIBLE FOR DATA PROCESSING? The entity responsible for data processing is FreeForStudents ("FreeForStudents", "we", "us" or "our") as the responsible entity within the meaning of the UK's Data Protection Act ("DPA") and the EU General Data Protection Regulation ("GDPR").
      1. 1.3.1. If you have any questions about this policy or our data protection practices, you can contact us by email at [email protected].
    4. 1.4. WHAT ARE THE LEGAL BASES FOR PROCESSING? We will only process your personal data if there is at least one of the following grounds:
      1. 1.4.1. CONSENT - This is where we have asked for your explicit consent to process your data for a specific purpose.
      2. 1.4.2. CONTRACT - This is when we process your data to fulfil a contractual agreement with you or to respond to your messages, emails, calls etc.
      3. 1.4.3. LEGITIMATE INTERESTS - This is where we rely on our interests as the reason for processing. Generally, it is to provide you with the best products and services in the safest and most appropriate way. Before we invoke any of these legitimate interests, we will of course balance them against your interests and ensure that they are compelling enough and will not cause unwarranted harm.
      4. 1.4.4. LEGAL OBLIGATION - This is when we are required by law or otherwise to process the data, for example for archiving or investigating crime.
  2. 2. Data We Collect
    1. 2.1. LOG DATA - Even if you do not log in or register on our website, but simply surf our website, data is collected and stored and processed by us. In detail, this is the IP address of your computer, date and time of access, name and URL of the file accessed, browser used, number of bytes transferred, status of page retrieval, session ID, referrer URL. The legal basis for this processing is our legitimate interest.
    2. 2.2. HOSTING - We host our website using the services of DigitalOcean, Cloudflare and Vercel. In this sense, DigitalOcean, Cloudflare and Vercel process all data and communication data, including IP addresses, provided to us through our content platform and application. The legal basis for the processing is our legitimate interest.
    3. 2.3. GOOGLE FONTS - We use Google Fonts from Google on our website to display external fonts. To enable the display of certain fonts on our website, a connection to the Google server in the USA is established when our website is accessed. Through the connection to Google, which is established when our website is accessed, Google can determine from which website your request originates and to which IP address the display of the font should be transmitted. This constitutes a legitimate interest.
    4. 2.4. CONTACTING US - When you contact us, we store and process the following data from you: Name, email address, telephone number and other personal data that you provide when contacting us. This data is collected and processed solely for the purpose of contacting you and processing your enquiry and is subsequently deleted unless there is a legal obligation to retain it. The legal bases for processing are contract and our legitimate interest.
    5. 2.5. SUBMISSIONS - We also collect your Personal Data when you submit any of our forms and/or surveys. The precise data that is collected depends on how you are using our forms and surveys and on your responses. The data provided is typically processed using the services of Tally and or Survicate. The legal bases for processing are your consent and our legitimate interest.
    6. 2.6. STUDENT DEALS - If you wish to redeem any student deals displayed, you will be redirected to the relevant advertising partner. The redirection requires your IP address and other technical data. We have no influence or control over the data that the relevant advertising partner collects and processes when you are redirected and you can find out more about the data processing in the privacy policy of the relevant advertising partner.
  3. 3. Cookies
    1. 3.1. WHY DO WE HAVE A COOKIE POLICY? This Cookie Policy is in accordance with the UK's Privacy and Electronic Regulations ("PECR") and the EU Directive on Privacy and Electronic Communications ("PECD"). In accordance with these laws, we must inform you about the cookies we use and obtain your consent when we use certain types of cookies, namely functional, performance, analytical and advertising cookies.
    2. 3.2. WHAT ARE COOKIES? Cookies are small files containing configuration information that are stored on your device. Cookies can be divided into the following two broad categories:
      1. 3.2.1. TECHNICALLY NECESSARY COOKIES (ESSENTIAL) - Technically essential cookies are necessary for the proper functioning of our website; they allow you to navigate our website efficiently and use its functional features. An example of this is remembering recent actions (e.g. entering text) when you return to a page within the same session.
      2. 3.2.2. TECHNICALLY NON-ESSENTIAL COOKIES (PERFORMANCE, FUNCTIONAL, ANALYTICAL, ADVERTISING) - Technically non-essential cookies are not necessary for the proper functioning of our website, but allow us to improve the content of our website, compile statistics for internal market analysis, provide you with a more personalised online experience or provide additional functionality. In particular, we use analytical and advertising cookies.
        1. 3.2.2.1. Analytical cookies are used by third parties. These cookies allow third parties to recognise that you have visited our website. We and our third-party vendors may also combine the information obtained from these cookies with Personal Data available from other sources, including information collected about you when you use other websites and information collected about you when you are offline, whether on our website or in data maintained by the third-party vendor.
        2. 3.2.2.2. Advertising cookies may be set by our advertising partners through our website. They may be used by these companies to profile your interests and show you relevant advertising on other websites. They are based on uniquely identifying your browser type and the type of internet device you are using. If you do not allow these cookies, you will receive less targeted advertising.
    3. 3.3. Within the categories described, different types of cookies are used, which can be divided into the following three subcategories:
      1. 3.3.1. SESSION COOKIES - While you are active on a website, a session cookie is temporarily stored in the memory of your computer, which stores a session identifier, for example, to prevent you from having to log in again each time you change pages. Session cookies are deleted when you log out or lose their validity once the session has automatically expired.
      2. 3.3.2. PERMANENT OR PERSISTENT COOKIES - A persistent or log cookie stores a file on your computer for the period of time specified in the expiry date. These cookies allow websites to remember your information and settings for your next visit. This results in faster and more convenient access, as you do not have to enter your language settings for our portal again, for example. After the expiry date, the cookie is automatically deleted when you visit the website that generated it.
      3. 3.3.3. THIRD-PARTY COOKIES - Third-party cookies come from providers other than the website operator. They can be used, for example, to collect information for advertising, individual content and web statistics.
    4. 3.4. GOOGLE ANALYTICS - We use Google Analytics, a web analytics service provided by Google. Google Analytics also uses cookies to enable our website to analyse how users use our website across multiple devices. The information generated by the cookies about your use of our website is transferred to and stored by Google, including transfer to the United States. The following data is processed through the use of Google Analytics:
      1. 3.4.1. 3 bytes of the IP address of the system of the website visitor (anonymised IP address);
      2. 3.4.2. the website accessed;
      3. 3.4.3. the website from which the user reached the accessed page of our website (referrer);
      4. 3.4.4. the sub-pages accessed from the website;
      5. 3.4.5. the time spent on the website; and
      6. 3.4.6. the frequency with which the website is accessed.
      7. 3.4.7. Google declares that it will not associate your IP address with any other data held by Google. The use of this service is based on your consent.
    5. 3.5. HOTJAR - We use Hotjar, a web analytics service provided by Hotjar Ltd, to better understand usage patterns, the needs of our users and to optimise our services and user experience. Hotjar uses cookies and other technologies to collect information about user behaviour and user devices (in particular, a device's IP address (which is collected and stored in anonymized form), screen size, device type (unique device identifiers), browser information, geographic information (on a country-by-country basis only), preferred language for viewing my website).
      1. 3.5.1. Hotjar stores this data in a pseudonymized user profile. Neither Hotjar nor we will use this information to identify individual users, nor will the data be merged with other data about individual users. The use of Hotjar is based on your consent.
    6. 3.6. GOOGLE ADSENSE - We use Google AdSense, a web advertising service provided by Google. Google AdSense uses so-called "DoubleClick DART Cookies" ("Cookies"). In addition, Google AdSense also uses so-called "web beacons" (small invisible graphics) to collect information, through the use of which simple actions such as user traffic on our website can be recorded, collected and evaluated. The information generated by the cookie and/or web beacon (including your IP address) about your visit to this website will be transmitted to and stored by Google on servers in the United States.
      1. 3.6.1. Google uses the information thus obtained to carry out an evaluation of user behaviour with regard to the AdSense ads. The IP address transmitted by your browser as part of Google AdSense will not be merged with other Google data. The information collected by Google may be transferred to third parties where required to do so by law, and/or where such third parties process the information on Google's behalf. For further information please refer to our Cookie Policy. The legal basis for the processing of your data is our legitimate interest in the targeted use of advertising.
    7. 3.7 OPT OUT
      1. 3.7.1. GOOGLE ANALYTICS - You can deactivate tracking by Google Analytics with effect for the future by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser at this link: http://tools.google.com/dlpage/gaoptout.
      2. 3.7.2. HOTJAR - You can object to the creation of user profiles, the storage of data about your use of our website by Hotjar, and the use of tracking cookies by Hotjar on other sites at any time by following this link: https://www.hotjar.com/opt-out.
      3. 3.7.3. GOOGLE ADSENSE - You can opt out of showing ads that are based on your interests, demographics, and Google Account information by following this link: https://myadcenter.google.com/.
      4. 3.7.3. GENERAL - If you do not wish to participate in our personalised advertising or retargeting/tracking, you can opt-out of behavioural advertising at the following websites:
        1. 3.7.3.1. YOUR ONLINE CHOICES - https://www.youronlinechoices.com
        2. 3.7.3.2. DIGITAL ADVERTISING ALLIANCE OF CANADA - https://youradchoices.ca
        3. 3.7.3.3. NETWORK ADVERTISING INITIATIVE - https://optout.networkadvertising.org
        4. 3.7.3.4. ADCHOICES - https://youradchoices.com
        5. 3.7.3.5. EUROPEAN INTERACTIVE DIGITAL ADVERTISING ALLIANCE - https://youronlinechoices.eu
    8. 3.8. HOW CAN I DELETE OR BLOCK COOKIES? As cookies are not stored on our system but locally on your computer/phone/tablet, we cannot retrieve or delete cookies. However, you can delete existing cookies and generally disable the use of cookies by following the instructions of your browser Google Chrome, Mozilla Firefox, Microsoft Edge, Opera, Safari.
    9. 3.9. COOKIE CONSENT - When you visit our website for the first time, you will be asked if you agree to cookies being stored on your device. You can accept all cookies or adjust your cookie settings so that only some of the above categories of cookies are stored on your device. You can also refuse all cookies except for essential cookies, i.e. cookies that are necessary for the proper functioning of the website.
      1. 3.9.1. You should be aware that we will not be able to provide you with the best possible user experience on our website if you disable/reject certain cookies, as there may be services and features that you will not be able to use if cookies are required for us to remember the choices you have made.
      2. 3.9.2. You can withdraw your consent or change your cookie settings at any time.
    10. 3.10. COOKIE CONSENT TOOL - Our website may use a cookie consent tool to obtain your consent to the storage of cookies and to document this consent. When you visit our website, the following personal data is transmitted to us: your consent(s) or the revocation of your consent(s); your IP address; information about your browser; information about your device; the time of your visit to our website. The basis for the processing is our legitimate interest and your consent.
    11. 3.11. LINKS TO OTHER WEBSITES - Please note that if you use a link from our website to a third party website, that third party may also set new cookies that are not covered by this policy. In such cases, we recommend that you read the cookie policy on the third party website itself.
  4. 4. Marketing
    1. 4.1. GENERAL - Where you have given us your separate consent to process your data for marketing and promotional purposes, we are entitled to contact you for these purposes through the communication channels for which you have given your consent.
      1. 4.1.1. You can give us your consent in a number of ways, for example by ticking a box on a form asking us for permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, this is based on you having a reasonable expectation of receiving a marketing communication as a result of your interactions or contractual relationship with us.
      2. 4.1.2. Direct marketing is usually in the form of emails but may also include other less traditional or new channels. These forms of contact are managed by us or by our appointed service providers. Any direct addressed marketing sent or carried out by us or on our behalf will include an option for you to opt out or unsubscribe.
    2. 4.2. BUSINESS ANALYSIS AND MARKET RESEARCH - For business reasons, we analyse the data we have about business transactions, contracts, enquiries, surfing behaviour, etc., whereby the group of persons concerned may include contractual partners, interested parties and users of our services.
      1. 4.2.1. The analyses are carried out for the purpose of business evaluation and market research. The analyses serve us alone and are not passed on to outside parties and are processed by means of anonymous analyses with summarised and or anonymised values. Furthermore, we take into account the privacy of the users and process the data for analysis purposes as pseudonymously as possible and, if possible, anonymised (e.g. as summarised data), which constitutes a legitimate interest.
  5. 5. Social Media
    1. 5.1. We have a presence on social media based on our legitimate interest. If you contact or interact with us via social media platforms, we and the respective social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contractual performance, if any.
  6. 6. Principles of Processing Personal Data
    1. 6.1. STORAGE AND RETENTION - To the extent necessary, we process and store your personal data for the duration of our business relationship, which includes, for example, the initiation and execution of a contract as mentioned above and on our Amazon Web Services (Amazon). In addition, we are subject to various retention and documentation obligations, which result, among other things, from the statutory minimum retention periods. Depending on the document and the statutory provision, the retention and documentation periods specified therein are 2 to 6 years.
    2. 6.2. SECURITY - Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content such as orders, login data or contact requests that you send to us. In addition, we have taken numerous security measures ("technical and organisational measures"), such as encryption or "need to know" access, to ensure the most comprehensive protection of personal data processed via our website.
      1. 6.2.1. Nevertheless, internet-based data transmissions can always have security vulnerabilities, so that absolute protection cannot be guaranteed. And databases or records containing personal data may be breached inadvertently or by unlawful intrusion. As soon as we learn of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as soon as possible after the breach is discovered.
    3. 6.3. WHAT WE DO NOT DO
      1. 6.3.1. We do not request personal data from minors and children;
      2. 6.3.2. We do not use automated decision making, including profiling; and
      3. 6.3.3. We do not sell your personal data.
    4. 6.4. SHARING AND DISCLOSURE - We will not disclose or otherwise disseminate your personal data to third parties unless it is necessary for the provision of our services, including our forwarding services; and you have consented to the disclosure; or where we are required to do so by law, for example by a court order, or where it is necessary to support a criminal or legal investigation or other legal process or proceeding, whether domestic or international, or to meet our legitimate interests.
    5. 6.5. INTERNATIONAL TRANSFER - We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer.
  7. 7. Your Rights and Privileges
    1. 7.1. PRIVACY RIGHTS - You can exercise the following rights:
      1. 7.1.1. Right to information;
      2. 7.1.2. Right to rectification;
      3. 7.1.3. Right to erasure;
      4. 7.1.4. Right to data portability;
      5. 7.1.5. Right to object;
      6. 7.1.6. Right to withdraw consent;
      7. 7.1.7. Right to lodge a complaint with a supervisory authority; and
      8. 7.1.8. Right not to be subject to a decision based solely on automated processing.
    2. 7.2. UPDATE YOUR INFORMATION - If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and you wish to request that it be corrected or deleted, or to object to the processing, please contact us.
    3. 7.3. WITHDRAWAL OF YOUR CONSENT - You can withdraw the consent you have given us at any time by contacting us. The lawfulness of the data processing carried out until the withdrawal remains unaffected by the withdrawal.
    4. 7.4. REQUEST FOR ACCESS - If you wish to make a request for access to your data, you may notify us in writing. We will respond to requests for access and correction as soon as possible. If we are unable to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with Personal Data or make a correction you have requested, we will tell you why.
    5. 7.5. COMPLAINT TO A SUPERVISORY AUTHORITY - You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in relation to our services is The Information Commissioner's Office (ICO), Wycliffe House, Water Ln, Wilmslow SK9 5AF, UK. The ICO website can be found at https://www.ico.org.uk. However, we would appreciate the opportunity to address your concerns before you contact the ICO.
  8. 8. Will This Privacy Policy Change?
    1. 8.1. We may update our privacy policy from time to time. This may be for a number of reasons, for example to reflect a change in the law or to reflect a change in our business practices and the way we use cookies. We recommend that you check here regularly for any changes to our privacy policy. This privacy policy was last updated on Monday, 30 October 2023.
  9. 9. Who Should I Contact for More Information?
    1. 9.1. If you have any questions about this policy or our privacy practices, you can reach us by email at [email protected].

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