Privacy and Cookie Policy
This privacy and cookie policy (the “Policy”) describes the personal data collected or generated (“processed”) when you use www.thefreshstudent.com (the “Site”).
This Policy describes the types of personal data collected and how your personal data is used, shared and protected. It also explains the choices you have relating to your personal data and how you can contact us.
It is important that you read this Policy together with any other privacy notice or fair processing notice that we may provide at or around the time that we collect or process personal data about you so that you are fully aware of how and why we are using that data. This Policy supplements the other notices and is not intended to override or replace them.
Please note that the Site is not intended for children (anyone aged under 16) and we do not knowingly collect data relating to children.
For ease of reading, we have divided this Policy into several sections:
1. Who we are.
2. What information we collect on you and how is it collected.
3. How we use the information collected on you.
4. Why The FreshStudent is allowed to use your information this way.
5. How long we keep your data.
6. With whom we share your data.
7. Your rights.
8. When will we contact you.
9. Web browser cookies.
10. Apps and Devices.
11. Contact Details.
12. How to complain.
This Policy was last updated on 10 June 2024.
Who we are.
The Site is run by The Fresh Student Ltd. registered in England and Wales under company number 15681268.We are a student advice and discount platform trading as The FreshStudent. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this Policy, or if you think it has not been followed, please contact the data privacy manager on [email protected].
What information we collect on you and how is it collected.
When you sign up to a The FreshStudent account, we collect personal data about you so that we can optimize the services we offer on the Site. The data you provide may include, but not limited to: your email address, date of birth, gender and institution of study. Once signed-in we will know how you use The FreshStudent which gives us a better understanding of what type of service to offer you in future. We may receive and store any information you provide in the usage of our website and/or service. You provide information to us when you: search for products or services; create a discount code; compile your favourites; communicate with us by phone, social media, e-mailor otherwise; complete a questionnaire; a support ticket; or a contest entry form; upload images, videos or other files to your account; compile playlists, watchlists, wishlists or gift registries; etc. We automatically receive and store certain types of information when you use our services, such as information about your use, including your interaction with content and services available through our services. Like many websites, we use cookies and other unique identifiers and we obtain certain types of information when your web browser or device accesses The FreshStudent and other content served by or on behalf of The FreshStudent on other websites.
Examples of the information we collect and analyse include, but are not limited to:the Internet protocol (IP) address used to connect your computer to the Internet; login data; emailtracking pixels; location of your device if switched on; device metrics; purchase and content use history; Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); cookie number; products and/or content viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs); phone numbers used to call our customer service number. We may also use device identifiers, cookies, and other technologies on devices, applications and our web pages to collect browsing, usage or other technical information for fraud prevention purposes. We may receive information about you from other sources such as: account information, purchase or redemption information and page-view information from brands with which we operate, co-branded businesses or for which we provide technical, fulfilment, advertising or other services.
How we use the information collected on you.
Information about your gender, age and location helps us see how different people use the Site and to ensureour advice and discounts are accessed exclusively by students.
Based on what we know about you, we may also show you adverts about The FreshStudent and related partners and also across platforms such as other websites and social media channels. We use your data to improve the Site as well asyour overall experience of The FreshStudent. Your data helps us operate, improve and maintain our business whilst at the same time enhancing your user experience. This allows us to do things like: provide advice or recommendation on information we know you have researched in the past; notify you of the things you have shown an interest in; personalise parts of The FreshStudent service to suit your tastes. We also use your data for business, regulatory and legal purposes such as: verifying your student status; getting in touch if we need to inform you of a change in policy or issue with service; and contacting you to re-verify your student status so you can keep receiving discounts.
At what point we deem it permissible to use your information.
The FreshStudent will only use your personal data in the following circumstances:where you have asked us to do soor consented to us doing so; where we need to do so in order to perform a contract we have entered into with you; where it is necessary for our legitimate interests (or those of a corresponding third party) and your fundamental rights do not override those interests; where we need to comply with a legal or regulatory obligation.
How long we keep your data.
Except if required otherwise by law, we retain your personal data for as long as necessary to fulfil the purposes for which we collect it and also where we have a legitimate interest in doing so, such as: to enable us to respond effectively to grievances that may arise after you cease engaging with us; or where you sign up to receive e-mail marketing from us we may retain your e-mail address after you ‘opt-out’ of receiving e-mails in order to ensure that we continue to honour and respect that request.You may ask us to access, rectify or, in some circumstances, delete your personal data (see ‘Your Rights’ below for more).We may also anonymise your 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. Not usingyou’re the FreshStudentaccount for a minimum of 12 months may have it classed as dormant or may be deleted in line with this Policy. You will be contacted (primarily) by email to inform you of this (check SPAM).
With whom we share your data.
We use your data to improve your experience. Our service means that we secure your personal data unless we are required by law to disclose your data or you ask us or give us your permission to share it. Other instances where your data may be shared include, but are not limited to:providing you with a discount or access to a partner’s platform; sending you marketing emails if you have consented to receiving them; sending you the latest edition of our newsletter if you have consented to receiving them. We may share your personal data with third party service providers who provide us with a variety of administrative, statistical, and/or technical services. Such a third party may manage and service our data, distribute emails, provide research and analysis, manage brand and product promotions as well as administer certain services and features.We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this information and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly consent to data protection and commit to assisting us in ensuring the same.
Please note that some of our service providers may be based outside the EU (European Union) and/or the European Economic Area (the “EEA”). Where we transfer your data to a service provider that is outside of the EU/EEA we will ensure appropriate safeguards are in place to make sure your personal data is held securely. When registering for a The FreshStudentaccount you may be required to login via a third-party service. You’re the FreshStudentaccount will always be covered by the policies of the Site.Where you opt in for marketing from brands you chose to take codes from, we will share your profile information with the third party including name, email address, university and date of birth. The third party will become a Data Controller, distributing the marketing as governed by their privacy notice. Consent in relation to the third party data controller must be withdrawn directly with said third party. Erasure must also be sought direct with the third party.Please note that where we provide links to third party websites, plug-ins and applications that are not affiliated with The FreshStudent are out of our control and are not covered by this Policy. If you access third party websites using the links provided, the operators of these websites may collect information from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to these websites.
Your rights.
As a data subject you have a number of rights in relation to your personal data. Set out below are the different rights you have and how they can be exercised:
– Right of Access
You may, at any time, request access to the personal data that we hold relating to you. This right is known as a “subject access request.” Please note that this request can only be made by the subject in-person, in notorized form, and not on behalf of someone else. You can exercise this right at any time by writing to us using contact details set out on this website. We will then inform you of the next steps to prove your identity and then ensure a safe and orderly transfer of said information.
– Your Right to Rectification and Erasure
You may, at any time, request that we correct personal data we hold on you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe it is in our gift to continue retaining it, under a right known as “right to be forgotten.” Please note we may ask that youverify any new data that you provide us with and may take our own steps to check that such data is verified. Further, we are not always obliged to erase personal data when asked to do soif, for any reason, we believe we have good legal standing to continue processing such data. Should such a case arise, we will inform you of our reason(s). You may alsocontact us to replace inaccurate data with new data.
– Your Right to Restrict Processing
Where, as stated above, we process your personal data on the basis of a legitimate interest you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.You may also ask us to stop processing your personal data if:
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- you dispute the accuracy of that personal data and want us to rectify its accuracy;
- where it has been established that our use of the data was unlawful;
- where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims. Please note that if, for any reason, we believe that we are of good legal standing in our rights to not cease processing, we will give you our reason(s) in writing. You can exercise this right at any time by writing to us using the contact details set out on this website.
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– Your Right to Portability
Where you wish for us to transfer certain personal data that we hold on youto a third party, you may write to us and ask that we provide it to you in a commonly used machine-readable format. Because of the kind of work we do and systems we use, we do not envisage this right being often requested, certainly not by the majority of users. However, the consideration of such a request stands.
– Your Right to stop receiving communication and/or correspondence
Where a link to cease communication is not immediately evident (for example, an ‘Unsubscribe’ button on our newsletter) you may contact us with this specific request.
– Your Right to object to automated decision making and profiling
You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.
– Verifying yourself in order to exercise your rights
In exercising any of your rights listed here within, we are entitled to verify your identity by requesting one or more of the following: a passport, national ID card, driver’s license, student photo ID and/or utility bill.
When we will contact you.
We will contact you: in delivering the service you have signed up for; in responding to any correspondence we receive from you or any comment or complaint you make about our services; in relation to any personalised services you may be using; in relation to any contribution you may have submitted to The FreshStudent, e.g. via the comments’ section on our different platforms including this website; in inviting you to participate in surveys(participation is always voluntary); in updating you on any material changes to our policies and practices; and for marketing purposes. We will NEVER contact you to ask for your The FreshStudent account password or other login information. Please be cautious if you receive any emails or calls from people asking for such information and claiming to be from The FreshStudent. We will only send you marketing emails and/or newsletters or where you have consented to us doing so. Periodically, we may also contact you to ask your views on issues affecting The FreshStudent. We may personalise the message content based upon information you have provided to us via use of the Site. We may use information we hold on you to show you relevant advertising on third party websites (e.g. Facebook, Google, Instagram, Snapchat and Twitter).
Web browser cookies.
– What is a Cookie?
A cookie is a small amount of data, which often includes a unique identifier, that is sent to your computer, tablet or mobile phone (all referred to here as a “device”) from a website’s tracker that stores itself on your device’s hard drive. Each website can send its own cookie to your web browser if your browser’s preferences allows it. Many websites do this whenever a user visitssaid website in order to track online traffic flows. Similar technologies are also used within emails to understand whether the email has been read or if any links have been clicked. Cookies will continue to operate until the device’s user changes setting. On the Site, cookies record information about your online preferences and allow us to tailor our website to your interests.
– How does The FreshStudent use cookies?
Information supplied by cookies can help us understand the profile of our visitors and help us provide you with a better and more personalised user experience. It is important to note that restricting or blocking certain cookies may restrict you from taking full advantage of some features of the Site.
– Other information collected from web browsers.
Your web browser may also provide The FreshStudent with information about your device, such as an IP address and details about the browser you are using. When requesting advice and/or discounts, it may be possibleto choose to provide The FreshStudentaccess to your device’s location through the web-browser. We use information provided by your browser, or by the link that you click, to understand the webpage that directed you to the Site and this may be captured by performance cookies.
Apps and Devices.
When you download or use the The FreshStudent app on your mobile device, information may be accessed from or stored to your device. Most often this is used in a similar way to a web browser cookie, such as by enabling the app to ‘remember’ you or provide you with the content you have requested. Your web browser or device may also provide The FreshStudent with information about your device such your IP address. Device identifiers may be collected automatically, such as the device ID, MAC address, IMEI number and app ID (a unique identifier relating to the particular copy of the app you are running).When you sign-in to The FreshStudent app, your sign-in details may be stored securely on the device you are using so you can access them on the same device without needing to enter your sign-in details again.
Contact Details.
If you any questions or comments about this Policy please contact our Data Privacy Manager by emailing [email protected].
How to complain.
We hope that we can resolve any query or concern you raise about our use of your data so please, in the first instance, get in touch via the contact details already mentioned. You do however have the right to make a complaint under the General Data Protection Regulation to a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or via telephone on 0303 123 1113.