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 website users as well as other people whom we may contact through our staff or candidates such as references and emergency contacts. It also applies to our suppliers whether partnerships and companies (including sole traders) or atypical workers such as independent contractors and freelance workers, who provide services to Sommet Education.

If you are a member of Sommet Education’ staff you should refer to the Sommet Education group ‘s staff privacy notice which is available on the Sommet Education intranet. If you are a student of one of the schools part of the Sommet Education group, you should refer to the privacy notice available on your school platform.

What is “personal data”?

Personal data is information that Sommet Education holds about you and which identifies you or could identify you when combined with other data which Sommet Education either holds or is likely to obtain.

WEBSITE USERS

Whenever you use our Sommet Education’s website 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.

REFERENCES AND EMERGENCY CONTACTS

We may collect and process the following types of personal data about you:

• references: your contact details and confirmation of the information provided by candidates who have put your contact details down as a reference; and
• emergency contact: your contacts details where of one of our candidates or a member of staff has put you down as their emergency contact.

SUPPLIER DATA

We collect contact details of relevant individuals at your organisation as well as your bank details.

Regardless of the category you belong, 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 Sommet Education get your personal data from?

WEBSITE USERS

We collect your data automatically via cookies. See “Cookies Policy” for further information.

REFERENCES AND EMERGENCY CONTACTS

We obtain personal data regarding you from one of our candidates or staff member.

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 Sommet Education collect and use your personal data?

All such data will be processed in accordance with applicable laws and regulation and the Sommet Education Group Data Protection Policy as amended from time to time.

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.

REFERENCES AND EMERGENCY CONTACTS

As an emergency contact, we store (and update when necessary) the information that our students 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.

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 agreements;
• communicating with you in relation to our agreements 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 Sommet Education 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.

REFERENCES AND EMERGENCY CONTACTS

The processing of your personal data as described above is covered by our legitimate interests or the one of our staff members or candidates. For further processing, not covered by our legitimate interests, your consent will be sought.

SUPPLIER

Contractual commitment & Legal obligation

As a supplier, most of the time Sommet Education 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.

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 the Sommet Education Group.

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); We may also need to share information with or our legal advisers;
• contractors, suppliers, agencies, or any other parties acting on Sommet Education’s behalf (collectively, “External Parties”) where there is a legitimate reason for their receiving the information, including, including but not limited to third parties contracted to provide IT services for us including cloud-based storage providers.

Sommet Education contractually requires External Parties processing personal data on behalf of Sommet Education to follow this policy, whether they are utilizing Sommet Education’s and/or their own electronic systems and data management tools. Sommet Education employees are responsible for ensuring that any External Parties they work with in support of Sommet Education operations comply with this policy.
The website may contain advertising of third parties and links to other sites or frames of other sites where Sommet Education 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.

Sending information to other countries

Some of the personal data we process about you will be transferred to, and stored at, a destination outside Switzerland or the European Economic Area (“EEA”), for example where it is processed by staff operating outside the EEA who work for us or for one of our suppliers, or where personal data is processed by one of our suppliers who is based outside the EEA or who uses storage facilities outside the EEA.

In these circumstances, your personal data will only be transferred on one of the following bases:

• a European Commission decision provides that the country or territory to which the transfer is made ensures an adequate level of protection;
• where the transfer is subject to one or more of the “appropriate safeguards” for international transfers prescribed by applicable law (e.g. standard data protection clauses adopted by the European Commission); or
• there exists another situation where the transfer is permitted under applicable law (e.g. where we have your explicit consent).

How Do We Secure you 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.

Sommet Education 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.

For how long do we keep your personal data?

We will only keep your information for as long as we are either required to by law or as is relevant for the purposes for which it was collected.

What decisions can you make about your personal data?

Sommet Education makes reasonable efforts to ensure that your personal data is reliable for its intended use. However, you are equally responsible for updating and checking the accuracy of the information provided to Sommet Education.

Moreover, you are able to make various decisions about your personal data. Your rights are as follows:

• to obtain access to, and copies of, the personal data that we hold about you;
• to require that we cease processing your personal data if the processing is causing you damage or distress;
• to require us not to send you marketing communications.
• to require us to correct the personal data we hold about you if it is incorrect;
• to require us to erase your personal data;
• to require us to restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);
• to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller;
• to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights.

Please note that:

• the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply;
• information request will be fulfilled free of charge unless in case of repetitive, manifestly unfounded or excessive requests or for further copies; and
• where our processing of your personal data relies on your consent and where you then withdraw that consent, it may affect the provision of the services.

Further information and guidance

Sommet Education reserves the right to modify this notice as needed, for example, to comply with changes in laws, regulations, Sommet Educations 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, email our Data Protection Officer at: dpo@sommet-education.com

If you are not satisfied with how we are processing your personal data, you can make a complaint to the relevant data protection authorities.

Version May 2023

The www.sommet-education.com website is operated under the Sommet Education name by Sommet Education Sàrl, a company registered in Switzerland at Rue Saint Martin 7, 1003, Lausanne.