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Privacy Policy – Students


 Last updated: June 20, 2025

Through this Privacy Policy, we inform you about how we collect, use, transfer, and protect your personal data. We process your data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “General Data Protection Regulation”, hereinafter “GDPR”), as well as applicable national legislation on data protection.

WHO ARE WE?

UPGRADE EDUCATION SRL provides educational counseling and mentoring services for students who aspire to study abroad. We support and guide young people through academic exploration, program selection, and the application process to top universities around the world. In this document, we refer to the company using the terms “we,” “the Company,” or “Upgrade Education.”

Our contact details are:
 Address: Bulevardul Dimitrie Pompeiu no. 10A, Conect 1 Building, 1st Floor, Office 10
 Email: gdpr@upgrade.education
 Phone: +40 31 630 5013

HOW DO WE PROCESS YOUR PERSONAL DATA?

We ensure that personal data are:

  • processed lawfully, fairly, and transparently;
  • collected for specified, explicit, and legitimate purposes, and not further processed in a manner incompatible with those purposes;
  • adequate, relevant, and limited to what is necessary;
  • accurate and kept up to date;
  • stored in a form that allows identification of data subjects for no longer than necessary;
  • processed securely, including protection against unauthorized or unlawful processing, and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.

WHAT TYPES OF PERSONAL DATA DO WE PROCESS AND FOR WHAT PURPOSES?

For students, we process the following personal data: full name, email address, phone number, home address, personal identification number (CNP), ID series and number, age, date of birth, gender, information about academic history, targeted universities, allocated study budget, extracurricular activities, preferences for services and products offered by the Company, image, voice, signature, or other data shared during interactions with mentors.

When completing and submitting the “Talk to a Mentor” form on our website [https://upgrade.education/ro/], we process: first name, last name, email, phone number, student/parent status, country, city, high school name, anticipated graduation year, type of school (public/private), last year’s GPA, intended study destinations (UK, US, Europe, Canada), confidence in studying in English, family study budget, desired major, and motivation for submitting the form.

For the “Join the Upgrade Education Movement” form, we process: first name, last name, email address, reasons for joining our team, LinkedIn profile, and any information included in the uploaded CV.

For the “Register for the Webinar” form, we process: first name, last name, student/parent status, phone number, email address, high school graduation year, confidence level in studying abroad, and annual study budget.

For the “Access the ICERI 2024 Paper” form, we process: first name, last name, email address, and role (e.g., journalist, educator, parent, student, other).

For contests or giveaways organized via our website or social media (Facebook, YouTube, Instagram, TikTok), we may process: full name, home address, email address, phone number, age, date of birth, and signature.

For the purpose of displaying student photos on the website and on our social media channels (Facebook, YouTube, Instagram, TikTok), we may process: full name, image, description, education, hobbies, cultural/culinary preferences, preparation journey, and extracurricular activities.

For website visitors, we may collect data via cookies or similar technologies, such as: IP address, browser type, location, pages visited on our website, time spent on the website, internet network, and device used. Please refer to our Cookie Policy for more details.

For the purpose of purchasing our book “Life After High School” via the website, we process the following personal data: first name, last name, email address, phone number, and delivery address.

We will not use your personal data for marketing communications (such as newsletters) unless you have explicitly provided your consent by ticking a checkbox. In such cases, we will process your first name and email address and ensure that you have an easy option to unsubscribe at any time and withdraw your consent.

WHAT ARE THE LEGAL BASES FOR PROCESSING PERSONAL DATA?

Your personal data is processed:

  • for the purpose of entering into and performing contracts;
  • to comply with legal obligations that apply to us;
  • based on your prior consent (e.g., for recruitment or marketing communications);
  • for the legitimate interests pursued by the Company (e.g., protection and security of employees, exercise or defense of legal claims, etc.).

HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

Personal data are stored and processed for the time necessary to achieve the purposes mentioned in this Policy or for the duration required by law (e.g., accounting, archiving).

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We do not disclose or transfer your personal data to any third party unless:

  • required by public authorities or institutions, under a legal obligation or legitimate interest (e.g., legal defense);
  • shared with partners or collaborators providing services such as web hosting, website development, maintenance, digital marketing, and communication services;
  • you have provided specific and explicit consent for the particular situation and data.

If personal data are transferred by the Company — directly or through partners — outside the European Economic Area, such transfers will be made in full compliance with the GDPR (especially Article 46), based on appropriate safeguards (e.g., standard contractual clauses approved by the European Commission), ensuring enforceable rights and effective legal remedies for data subjects.

WHAT SECURITY MEASURES DO WE APPLY?

We implement appropriate technical and organizational measures to ensure a high level of security and data protection. We use secure technologies, internal procedures, and policies — including control and audit mechanisms — to safeguard personal data in compliance with legal requirements.

WHAT ARE YOUR RIGHTS AS A DATA SUBJECT?

Under the GDPR, you have the following rights:

  • Right of access;
  • Right to rectification;
  • Right to erasure;
  • Right to restriction of processing;
  • Right to data portability;
  • Right to object to processing;
  • Right not to be subject to a decision based solely on automated processing, including profiling;
  • Right to lodge a complaint with the National Supervisory Authority for Personal Data Processing (www.dataprotection.ro) or with the competent courts.

To exercise your rights or for any questions regarding your personal data, please contact us at:
 Email: gdpr@upgrade.education
 Phone: +40 745 508 673
 Contact person: Ionel Orza
 Our Data Protection Officer (DPO) services are outsourced and provided by GDPRComplet.