HOW WE USE YOUR INFORMATION
Data Privacy Notice
If you have come to this page because you want to access your marketing preferences please click here or the unsubscribe link in any marketing e-mail we send to you.
Background
This notice is to help you understand how and why we collect your personal data and what we do with it. It also explains the decisions that you can make about your personal data.
This privacy notice applies to the personal data of our campus’ visitors, website users, including but not limited to prospective clients as well as other people whom we may contact through our clients or prospective clients such as sponsors, employers, references and emergency contacts. It also applies to our suppliers whether partnerships and companies or atypical workers such as independent contractors and freelance workers, who provide services to Institute. This privacy notice also applies in addition to the Institute’s other relevant terms and conditions and policies.
If you are a member of Normae Limited (the “Institute”)’ staff you should refer to the staff privacy notice which is available on the intranet. Finally, if you are a current client, please refer to the Institute client privacy notice which is available on the client platform.
WHAT IS “PERSONAL DATA”?
Personal data is information that the Institute holds about you and which identifies you or could identify you when combined with other data which the Institute either holds or is likely to obtain.
WEBSITE USERS
Whenever you use our Institute’s websites, even though you do not create an account and log on with your user name and password, we collect a limited amount of data which we use to help us improve your experience when using our website and manage the services we provide. Indeed, our web server automatically records details about your visit, that does not, on its own, permit direct association with you including but not limited to your IP address, the website from which you visit us, the advertisements on which you have clicked, the type of browser software used, the pages that you actually visit including the date and duration of your visit, the language you choose and the way you navigate on our website – See “Cookies Policy” below for further information.
PROSPECTIVE CLIENTS
We may collect and process the following types of personal data about you:
your name, and contact information such as address, email address and telephone number, as well as your date and place of birth, gender, photo, country of domicile and your nationality including copy of legal documents issued by public bodies such as your ID or passport;
information relating to your education and employment history;
funding or financial details (income, sponsor);
information about your family or personal circumstances, and both academic and extracurricular interests, for example where this is relevant to the assessment of your suitability to receive a bursary or in order to provide you with appropriate help;
sensitive personal data and information in particular, information concerning your health and medical conditions;
access and authentication information (e.g., user name, passwords); and
records of interactions with Institute services. In particular, we may monitor or record calls to our enrolment/admissions line in case we need to resolve queries or issues. Conversations may also be monitored for staff training purposes and to help improve our service. Where applicable, we will notify you and take appropriate measures to ensure that sensitive data is not recorded.
The Institute doesn’t seek to collect personal data from individuals under age of 16. Individuals under age of 16 should receive permission from their parent or legal guardian before providing any personal data to us on the website.
SPONSORS, EMPLOYERS, REFERENCES AND EMERGENCY CONTACTS
We may collect and process the following types of personal data about you:
sponsors (e.g. parents or other legal guardians or relatives): your contact and financial details and confirmation that you agree to sponsor the client with tuition and other fees;
references: your contact details and confirmation of the information provided by candidates or prospective clients who have put your contact details down as a reference;
emergency contact: your contacts details where of one of our clients, candidates or a member of staff has put you down as their emergency contact;
employer: your contacts and company details and evaluation and related information when you have accepted one of our clients for an internship.
SUPPLIER DATA
We collect contact details of relevant individuals at your organisation.
Regardless of the category you belong to, the examples provided above are not all-inclusive. We also may collect similar or related information and in particular information you choose to share voluntarily about you.
WHERE DOES THE INSTITUTE GET YOUR PERSONAL DATA FROM?
WEBSITE USERS
We collect your data automatically via cookies, in line with cookie settings in your browser – See “Cookies Policy” below for further information.
PROSPECTIVE CLIENTS
We obtain personal data regarding you from the following sources:
You when you:
create an account on our websites;
provide information through one of our online forms such as Contact Us, Request information, Newsletter sign-up, Registration to an Event; Register for a private tour etc;
registered for one of our academic programs whether through an online application form, during a fair or otherwise; and
give us any info via email or other messaging channel, e.g. Instagram, Facebook, WhatsApp, SMS, phone calls etc.
Third party sources:
such as organisations that assist us with pursuing our purposes described below, including the Institute’ offices, partners institutions or organisations or your educational counsellor;
if you have expressed your interest in one of our programs to a friend or another person and agreed for them to share your contact details with the Institute as part of a Institute referral program as the case may be; and
if you follow our pages on social media (Facebook, Instagram, etc.) we will receive your personal information from those sites including any personal data you agreed with the respective websites to share
SPONSORS, EMPLOYERS, REFERENCES AND EMERGENCY CONTACTS
As a sponsor, we obtain personal data regarding you either directly from you where you actively communicated it to us or from one of our clients or prospective clients.
As a reference or emergency contact, we obtain personal data regarding you from one of our clients, candidates or staff member.
As an employer, we obtain personal data regarding you either directly from you or your company where you contact us or register with our portal(s) or from one of our clients as part of their internships.
SUPPLIER DATA
We obtain personal data regarding you from the following sources:
You, your employer or organisation when you contact us proactively, usually by phone or email or where we contact you, either by phone or email; or
Third party sources such as organisations that assist us with pursuing our purposes described below including where relevant due diligence services providers, media articles, social networking posts or other public sources for example the world wide web.
WHY DOES THE INSTITUTE COLLECTS AND USES YOUR PERSONAL DATA?
WEBSITE USERS
We use your data to help us improve your experience of using our website. Our website also uses re-targeting, which allows us to make our online content more interesting for you. Retargeting technology means we can advertise recently viewed and related products on our partners’ websites, meaning our adverts, even on other companies’ sites, are relevant to what you would like to see. We do this by analysing user behaviour from data collected by our cookies even without having a user profile – See “Cookies Policy” below.
PROSPECTIVE CLIENTS
We will use the personal information you provide for the purposes of processing your application and providing you with the information and services you requested, including, but not limited to the following activities:
storing (and updating when necessary) your details on our databases;
verifying your account and providing a personalised experience for you;
allowing you to participate in the interactive features of our services, when you choose to do so;
communicating with you about the Institute (including its services and programs) and inviting you to events.
automated decision making: the marketing team use various modelling tools that will automatically process your data to assess the likelihood of you being interested in special promotions, new products and services, or upcoming events; and
assessing your application to one of our programs (any medical information required will only be used to ensure you are fit to start and continue learning at Institute or to make sure we can reasonably adjust our teaching methods or attend any special need).
If your application is successful and you become a client we will also use your personal data for study-related purposes.
SPONSORS, EMPLOYERS, REFERENCES AND EMERGENCY CONTACTS
As a sponsor, we store (and update when necessary) your details on our databases so that we can contact you in relation to the client you sponsor and process payments where relevant. We may also be conducting surveys. There is no requirement for you to take part in any of these surveys but participation assists the Institute in enhancing sponsor and client experience.
As an emergency contact, we store (and update when necessary) the information that our clients and candidates/staff members give us about you in order to put you down on our form as an emergency contact and we will contact you in the case of an accident or emergency affecting them.
As a reference, we will contact you in order to take up a reference.
As an employer, we may use your personal data as follows:
if you take one of our clients as a trainee, as part of our clients’ internships, you will be requested to evaluate your trainee and provide certain information;
if you decide to register on our Portal(s), clients may be allowed to access your information and reach out to you for, among other things, the purpose of internships and employment; and
we may contact/inform you about upcoming Career Fairs, client placement and institutional initiatives.
SUPPLIER
We will use the personal information you provide to ensure that things run smoothly including, but not limited to the following activities:
storing (and updating when necessary) your details on our databases, so that we can contact you in relation to our agreement(s);
communicating with you in relation to our agreement(s) including paying for the services you provide (if this is part of the contractual arrangements between us); and
performing due diligence: please note that if your services consist in acting on behalf of Institute for any reasons we may process your personal data, including information from the public domain, for due diligence purposes, in accordance with our then current policies.
OUR LEGAL GROUNDS FOR USING YOUR INFORMATION
WEBSITE USERS
Some cookies are necessary because otherwise the website is unable to function properly. We need your consent for using other cookies.
PROSPECTIVE CLIENTS
Contractual commitment
The Institute may be processing your personal data often on the basis that it is necessary to enable it to meet its contractual and pre-contractual commitments. For instance, if you have requested information from us through one of our online forms or otherwise or if you have filled out an application form, whether or not online, we assume that you are happy for us to collect and otherwise use your personal data to give you the requested information and where relevant evaluate your application. In case you are really interested in the Institute and in our programs, we also want to provide you with tailored programs recommendations to help you on your application. We therefore think it’s reasonable for us to process your data to make sure that we send you the most appropriate content. If, at any stage, you are concerned about the content, frequency or method of communications, you can unsubscribe or update your preferences using links provided at the bottom of the relevant correspondence.
Legal obligation
The Institute may also be required to process the above personal data in order to comply with its legal obligations.
Legitimate interest
Certain activities are also necessary for the purposes of the legitimate interest of the Institute and other third parties, including clients. These interests are not overridden by the interests and fundamental rights or the freedoms of the data subjects concerned.
Consent
Where none of these legal bases apply, your consent to process your personal data will be sought. If we ask for your consent to use your personal data you can take back this consent at any time. Any use of your personal data before you withdraw your consent remains valid.
Sensitive personal data
Some of the information we collect and use may include sensitive personal data, the processing of which is either based on a legal obligation or on your consent as appropriate in each case. Also, please note that the Institute will be processing some of your data because you have clearly made it publicly available, in particular on the internet.
SPONSORS, EMPLOYERS, REFERENCES AND EMERGENCY CONTACTS
We need your consent only for those aspects of our activities which are not covered by our legitimate interests.
For instance, for photographs/videos taken on campus for use in publication materials, where you are not the subject of the image, i.e. if it is a “group” or “crowd” photograph, we may use such images without requiring your consent, however, where you are the subject of the photograph, you will be asked to provide your explicit consent to use the image.
If we ask for your consent to use your personal data you can take back this consent at any time. Any use of your personal data before you withdraw your consent remains valid.
SUPPLIER
Contractual commitment & Legal obligation
As a supplier, most of the time the Institute will be processing your personal data on the basis that it is necessary to enable it to meet its contractual and pre-contractual commitments or in order to comply with its legal obligations, for instance as regards to payments, taxes etc.
Legitimate interest
We may use your personal data for the above purposes if we deem this to be necessary for our legitimate interests.
Regardless of the category you belong it may also be necessary for us to process your personal data, where appropriate and in accordance with local laws and requirements, in connection with exercising or defending legal claims. This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.
In any cases, your personal data will be processed in accordance with applicable laws and regulation and the Normae Limited Data Protection Policy as amended from time to time.
SHARING INFORMATION WITH OTHERS
For operational reasons and as is necessary and proportionate for intended purposes, we may share your information with other entities in Normae Holding Co.
For the purposes referred to in this privacy notice and relying on the bases for processing as set out above, we may also share your personal data with certain third parties:
government departments and agencies and local authorities where we have a statutory obligation to provide information;
crime prevention or detection agencies (e.g. the police, the department for work); We may also need to share information with or our legal advisers;
contractors, suppliers, agencies, or any other parties acting on Institute’s behalf (collectively, “External Parties”) where there is a legitimate reason for their receiving the information, including but not limited to third parties contracted to provide IT services for us including cloud-based storage providers or if you are a prospective client:
o international agents (if you are an international applicant and you apply via an international agent;
o partner educational institutions and organisation involved in the delivery of our programmes, including those outside the EEA, if you apply to a programme partially delivered by such an institution.
The Institute contractually requires External Parties processing personal data on behalf of the Institute to follow this policy, whether they are utilizing the Institute’s and/or their own electronic systems and data management tools. Institute employees are responsible for ensuring that any External Parties they work with in support of Institute operations comply with this policy.
This website may contain advertising of third parties and links to other sites or frames of other sites where Institute does not control how your data is processed. In those situations, please ensure you read and understand the privacy policies and practices of such websites and be aware that we are not responsible for the privacy practices or content of those third parties or other sites.
HOW DO WE SECURE YOUR PERSONAL DATA?
We implement appropriate physical, administrative and technical measures designed to protect your personal data against accidental, unlawful or unauthorized destruction, loss, alteration, disclosure or access or use, and all other unlawful forms of processing.
The Institute contractually requires that External Parties provide equivalent levels of protection when handling your personal data and only process the data in accordance with our instructions.
In any cases, we limit access to personal data to those employees, agents, contractors and other third parties that have a legitimate business need for such access in accordance with this privacy notice.
FOR HOW LONG DO WE KEEP YOUR PERSONAL DATA?
If we have not had meaningful contact with you for a period of ten years, we will delete your personal data from our systems unless we believe in good faith that the law or other regulation requires us to preserve it.
When we refer to “meaningful contact”, we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services.
If you become a client of the Institute, a basic client record will be kept permanently by Institute, with more detailed records kept for defined retention periods.
FURTHER INFORMATION AND GUIDANCE
The Institute reserves the right to modify this notice as needed, for example, to comply with changes in laws, regulations, Institutes practices and procedures, or to respond to new threats or new requirements imposed by data protection authorities. Please just visit this page if you want to stay up to date, as we will post any change here.
If you have questions about your personal data, contact us via the form in the contact page.
If you are not satisfied with how we are processing your personal data, you can make a complaint to the relevant data protection authority.
Last update: June 2024
The www.normae.co website is operated under the Normae name by Normae Limited for the benefit of Normae Limited, a company registered in Hong Kong.
COOKIES POLICY
WHAT ARE COOKIES?
Our websites, email messages and advertisements may use “cookies” and other technologies.
A cookie is a small text file that is stored on your computer, smartphone or any other device optimized for the Internet when visiting a website. This text file stores information that can be read by the website when visiting it again at a later date being understood that can be distinguished:
• Session cookies: only stored on your computer during your web session and automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any information from your computer;
• Persistent cookies: stored as a file on your computer and remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. For instance we use persistent cookies such as Google Analytics and for personalisation (see below).
Some of these cookies are necessary because otherwise the website is unable to function properly. Cookies are also used to optimise the performance of the website.
Other cookies are convenient for the visitor: they remember your username in a secure way as well as your language preferences, for example. The Institute uses such cookies to help us provide you with a better user experience tailored to your personal preferences. By using cookies we make sure that you do not receive or need to enter the same information every single time you visit the website.
Information collected by cookies and other technologies are most of the time non-personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by certain laws, we also treat these identifiers as personal data. Similarly, to the extent that non-personal information is combined with personal data, we treat the combined information as personal data for the purposes of this privacy notice.
PREVENT COOKIES FROM BEING STORED ON YOUR COMPUTER
For certain cookies, your consent will be required. More generally, you can manage the settings in your browser. Usually, your browser’s help section will provide information on how to change your cookie settings. You can find detailed information on how to change your browser settings by clicking here.
When you save your cookies settings, they should also apply to your future visits to the Site. However, for technical reason beyond our control, this cannot be guaranteed.
Your attention is drawn to the fact that our cookies improve your browsing experience on the website and allow you to access to certain secure areas where necessary. Where this is the case, certain website functions may be altered or blocked. If you would like to accept Institute’s cookies but block our partners’ cookies, you can set your browser to block third party cookies.
SPECIFIC COOKIES WE USE
Cookies may be set either by our website or by a third-party website. The tables below identify the cookies we use and explain the purposes for which they are used. However, we continue to collect information about third-party cookies and the tables below are based on the work completed to date.
Accordingly, we may update the information contained in this section from time to time.
Google Adwords User Lists
This cookie enables us to create, transact and manage digital advertising. https://policies.google.com/privacy
Google Analytics
Google Analytics is a web analytics service provided by Google, Inc. Google Analytics uses cookies to help us analyse how visitors use our site. Google will use this information for the purpose of assessing your use of the website, compiling reports on website activity for us and providing other services to us relating to website activity and internet usage. http://www.google.com/intl/en /policies/privacy/
Google Tag Manager
This cookie is associated with sites using Google Tag Manager to load other scripts and code into a page. The cookie helps us to classify information on our website and label it in a way which makes it easier to be found in future searches. http://www.google.com/intl/en /policies/privacy/
Google Dynamic Remarketing
This cookie enables us to create, transact and manage digital advertising. http://google.com/intl/en/policiea/privacy/
Google Adwords Conversion
This cookie enables us to create, transact and manage digital advertising. http://www.google.com/intl/en/policies/privacy/
Facebook Connect
Facebook Connect is a single sign-on application which allows you to login to and interact with our website through your Facebook account to avoid having to take the basic registration steps on our website. https://www.facebook.com/abo ut/privacy/
Facebook custom audience
This cookie enables us to create custom lists of existing customers. We can then send relevant advertising to the customers on different lists depending on the specific interests of the custom audience on each list. https://www.facebook.com/full_data_use_policy
Bing
This cookie enables us to create, transact and manage digital advertising.
https://advertise.bingads.microsoft.com/en-gb/resources/policies/microsoft-bing-ads-privacy-policy
Baidu Analytics
Baidu Analytics (Baidu Tongji) is a web analytics service provided by Baidu Inc., the largest search engine in China. Similar to Google Analytics, Baidu Analytics also uses cookies to help us analyse how visitors use our site. Baidu will use this information for the purpose of assessing your use of the website, compiling reports on website activity for us and providing other services to us relating to website activity and internet usage. This cookie is only placed on the Chinese websites.
https://www.baidu.com/duty/yinsiquan.html
Baidu SEM Analytics
Baidu SEM Analytics works exactly like regular web analytics. It is used to track paid search campaigns on Baidu. This cookie is only placed on the Chinese websites.