Privacy policy

In this privacy policy we have summarised all essential information about Udrus’s handling of your personal data and your accompanying rights.

This privacy policy comes into force on September 27, 2022.

At Udrus, security and transparency are our top priorities when it comes to handling personal data. In this privacy policy, we have
summarised in detail what information we collect about you, how we use it and what rights you have.

  1. Scope of this privacy policy

    This privacy policy applies to your use of the Udrus online platform (“Website”), including all Udrus services, applications, products and tools (collectively, “Udrus Services”), regardless of how you access, view or use those services, including access via mobile devices or via an application.

  2. Updating our privacy policy

    Udrus reserves the right to update and amend this privacy policy from time to time to reflect changes in the way Udrus processes your personal data or to reflect changes in legal requirements. Any changes we make to our privacy policy in the future will be posted on our website (www.udrus.com) and, where appropriate, we will also notify you by email.

  3. Who is responsible for your personal data ?

    The responsible party within the meaning of the German Data Protection Regulation (DSGVO) is Neom GmbH, Neue Mainzer Str. 46-50, D-60311, Frankfurt am Main, as operator of the Services.

    Whenever this privacy policy refers to “Udrus”, “we” or “us”, this always means Neom GmbH as the responsible entity within the meaning of the DSGVO.

  4. What personal data do we collect and process ?

    Udrus may collect personal information from you when you use the Udrus Services, create a Udrus user account, upload or update information or documents in your Udrus user account, submit information to us via a web form or contact us otherwise. Udrus also collects personal information from other sources. These sources may include but are not limited to Udrus partners, educational institutions, credit institutions, data providers or payment processors.

    Udrus collects the following personal data in particular:

    1. Personal data that you provide independently when creating a Udrus user account, your application profile or when using our services

      • Data that you must provide when creating a Udrus user account such as name, title, address, email address, nationality, user name, mobile phone number or date of birth;
      • Data you provide when creating your application profile, such as your name, nationality, email address, mobile phone number, gender, date of birth, country of residence, educational background, certificates, achievements or results in educational, language tests or work experience, travel history, passport number or languages you speak;
      • Data that we need to authenticate, identify or verify your identity or that Udrus is required or authorised by law to collect and process;
      • Financial information required in connection with the use of our payment service providers (e.g. credit card and account numbers, payment data);
      • Content that you share with us, agents or third parties via our chat feature.
    2. Personal data from social networks

      • Udrus allows you to use social networks or similar service providers with which you already have an account to create an Udrus user account or to link your Udrus user account to the relevant social network. The providers of the social networks or similar service providers may provide us with certain personal data depending on your privacy settings.
      • For more information about the personal data we receive from the social network provider, please refer to the privacy policy of the respective provider.
    3. Personal data that is automatically collected by us when you use our services

      • Data that arises in the course of using our services and is linked to your Udrus user account, such as searches for educational institutions or study programs;
      • Data about your interaction with our services and your communication with us;
      • Location data, including the approximate location (e.g. region derived from IP address) and the exact location of your mobile device;
      • Information about your visit and usage when accessing our services, such as information about the device and browser you are using, your IP address and location, your advertiser identifier, the duration and time and the time of your visit, traffic information to and from the sites, referral URL, browsing history and your language preferences.
    4. Personal data we collect through the use of cookies and similar technologies

      Cookies are small packets of data that your browser stores on your device when instructed by a website you visit to “remember” information about you, such as your language preferences or login information. We use cookies and similar technologies to collect data when you use our services, in particular the Udrus platform. Udrus collects the data from the device (including mobile devices) you use to access the service.

      The data collected includes the following usage and device-related information:

      • The IP address of the terminal device with which you access our services;
      • Information about your terminal device, operating system and version, browser settings, ID for advertisements and device identifier;
      • Location data of the terminal device from which you use our services;
      • For further information please refer to chapter 11 “Use of cookies and similar technologies”.
    5. Personal data we obtain from third parties or public sources:

      Udrus also collects personal data from public sources or third parties to the extent permitted by applicable law. Udrus may merge and combine this data with the data you provide to us.

      Among other things, the following data are collected:

      • Data from third parties, such as banks, credit reporting parties, affiliates or support service providers;
      • Data from information parties;
      • Data from public sources such as public registers.
  5. On what legal basis do we process your data ?

    Udrus processes your personal data on different legal bases and for different purposes which allow us to do so.

    Among other things, Udrus processes your personal data to enable you to use and continuously improve our platform, to provide a personalised user experience on our platform, to display customised advertising to you, to provide customer service or to protect you from fraud and similar unlawful activities. To enable these purposes, Udrus also needs to share the data with third parties.

    1. We process your personal data in order to be able to offer you our services and to fulfil the contract concluded with you (Art. 6 para. 1 lit. b) DSGVO). In particular, this includes the following purposes:

      • The provision of our services and the use of our platform, in particular to apply to educational institutions and to measure and continuously improve the quality of our services and to keep our platform operational;
      • To enforce Udrus’s Terms of Use, this privacy policy and other policies;
      • Udrus processes data relating to you or your company for the purposes of entering into and performing the contract between you and Udrus;
      • The execution of transactions between Udrus and the agents, the provision and continuous improvement of our services and the creation of the permanent functionality of our platform;
      • The provision of our support regarding your user account. For this purpose, we may contact you via your Udrus user account, email or mobile number;
      • The processing of general location data such as the IP address in order to provide you with location-based search results for example when searching for educational institutions.
    2. Udrus processes your personal data in order to comply with our legal obligations (Art. 6 para. 1 lit. c) DSGVO). This includes in particular the following purposes:

      • Udrus always tries to detect, contain and prevent illegal activities (e.g. fraud, money laundering, phishing or terrorist financing);
      • Participation in proceedings (including court proceedings) conducted by state authorities;
      • Ensuring the safe use of our services and platform;
      • To comply with the legal obligations to retain personal data.
    3. To the extent necessary, Udrus will transfer your personal data for the above purposes to the following selected recipients, among others:

      • To third parties who have a legal right to information against Udrus;
      • To law enforcement agencies, courts, other government agencies, intergovernmental or supranational bodies;
      • External service providers;
      • Third parties involved in legal proceedings, provided that they submit a legal order, court order or equivalent legal disposition to us;
      • Credit reference agencies, data verification services, debt collection agencies (e.g. information on late payments, defaults or other irregularities that may be relevant to your credit report);
      • Other companies within the scope of a company acquisition;
      • Udrus partners (e.g. educational institutions, recruitment partners);
      • Members of our group of companies, in particular uni-app.com;
      • Other third parties we work with to provide you with certain services.
    4. We process your personal data in order to protect your vital interests or the vital interests of another natural person (Art. 6 para. 1 lit. d) DSGVO). The following purposes are covered by this:

      • Udrus processes your personal data to detect, prevent, investigate and mitigate unlawful activities that may affect your vital interests or those of other individuals.
    5. We process your personal data in order to pursue our legitimate interests (Art. 6 para. 1 lit. f) DSGVO), but only to the extent that your interests, fundamental rights and freedoms are not overridden. On this basis, we process your data for the following purposes:

      • Udrus processes your personal data for the purpose of participating in proceedings (including legal proceedings) conducted by state courts, law enforcement agencies or other governmental, intergovernmental or supranational bodies, in particular for the purpose of prosecuting, clarifying and investigating unlawful acts, to the extent that we may assume that the disclosure of the personal data is necessary to prevent imminent danger or unlawful acts;
      • Udrus processes your personal data to prevent, mitigate, investigate, prosecute and detect fraud or other unlawful activities;
      • We process your personal data to carry out identity checks and for verification purposes;
      • We process personal data to protect the legitimate interests of third parties in the context of civil disputes in order to avert imminent disadvantages, insofar as Udrus may assume that it is necessary to disclose the personal data to such third parties;
      • Udrus processes personal data for the automatic filtering and, where necessary, subsequent manual review of messages sent via our messaging tools to protect against unlawful activity or breaches of Udrus’s terms of use;
      • Udrus processes your personal data to assess the effectiveness and success of our marketing campaigns;
      • Udrus processes your personal data in the event of the initiation, preparation and implementation of a company acquisition, merger or takeover.
  6. Storage period, storage location and deletion

    We will retain your personal information for as long as is necessary to fulfil the purposes set out in this privacy policy, for as long as we have not otherwise communicated this to you, or for as long as permitted by applicable law. We will treat the personal information we collect in accordance with our data retention and deletion policy. In addition to deletion, our policy also provides for the anonymization of certain data. Retention periods for personal data vary from country to country.

    The following is an exemplary list of common retention periods:

    • Data and information obtained by Udrus from technical means such as cookies or other analysis tools will be retained by us for a period of up to one year from the expiry of the cookies.
    • Your personal data will generally only be stored for as long as it is required for the purposes set out in this privacy policy. However, we may be required by law to retain your personal data for a longer period of time. These legal obligations may arise for accounting, auditing, or tax purposes, among others. The retention periods in Europe are generally between six and ten years.

      We may also restrict the processing of your data instead of deleting it if this is permitted or required by law. This applies in particular in cases where we still need the data for possible legal prosecution, legal defence or otherwise. The statutory limitation and retention periods are then decisive for the duration of the restriction and processing. The individual retention periods depend on the respective personal data, the applicable national law and the purposes for which we need them. After expiry of the relevant periods, the data will then be permanently deleted.

    • The data we collect from you may be stored and retained at a designated location outside the European Economic Area (EEA). Only selected third parties will transfer the data. Some countries outside the EEA may have lower levels of data protection or no data protection laws at all. Where this is the case, Udrus will ensure that personal data is adequately protected and only transferred through procedures approved by the EU Commission.
  7. Your rights

    Subject to possible restrictions under national law, as a data subject you have the right of access, accuracy, objection, porting, deletion and complaint.

    Your rights in detail:

    • You have the right to request a copy of the personal data Udrus holds about you. There are exceptions to this right, so that access to this data may be denied if, for example, personal data would be disclosed to a third party in this context or Udrus is legally prevented from disclosing this information.
    • Udrus strives to keep your personal data as accurate, up-to- date and complete as possible. If anything has changed in your personal data, you can adjust it yourself in your Udrus user account.
    • Under certain circumstances, you have the right to object to the processing of your personal data and to ask us to delete, restrict or block your personal data.
    • You have the right to request Udrus to provide you or another data processor with your personal data in a commonly used, machine-readable format.
    • You have the right to have your personal data deleted if the personal data is no longer needed for the purposes for which it was collected by Udrus or has been processed unlawfully, for example.
    • If you believe that your personal data may have been breached by Udrus, you have the right to seek redress from the competent courts or to lodge a complaint with the competent supervisory authority.
    • In principle, the processing of your application to enforce one of these rights is free of charge. However, if there are reasonable reasons to suspect that your application is manifestly unfounded or contrary to the principles of good faith, we reserve the right in individual cases to charge an appropriate fee in accordance with the statutory provisions, up to the amount of our actual costs or to refuse to process the application.
  8. Revocation of consent

    You have the right, if you have consented to the collection, processing and disclosure of personal data, to revoke your consent in whole or in part. To revoke your consent, please contact us at laurenz@uni-app.com.

    Udrus will no longer use your personal data for the purposes for which you originally consented once we have received your revocation. The lawfulness of the processing carried out on the basis of the consent until the revocation is not affected by the revocation.

  9. Our news tools

    Udrus offers you the possibility to send direct messages via our platform. All messages sent are first received by us and then forwarded to the addressee. In the process, we automatically filter the messages according to certain criteria and, if necessary, carry out a manual check afterwards.

    This process serves to protect legitimate interests such as protection against fraud or similar suspicious activities such as phishing or spam. In the event of violations of our terms of use, we reserve the right to temporarily block or permanently delete your user account.

    As a part of our free service, we will create an account for you in our platform, Udrus, where you can communicate with the schools and manage your preferences.

  10. Data security

    Udrus takes the protection of your personal data very seriously and therefore takes appropriate technical, digital, physical and organizational measures to protect your data from unlawful use, access, misuse by third parties or loss. These may include firewalls, access restrictions and authorization controls for data access only by certain employees.

  11. Use of cookies and similar technologies

    When you use our services, we or the companies we work with may place cookies and similar technologies on your computer or mobile device. These technologies help us to improve user behavior and tell us which parts of our website have been visited. Also the use of cookies enables personalised advertising and a personalised user experience. Udrus uses first-, third-party and session cookies.

    Our cookies and similar technologies have different functions:

    1. Essential cookies

      These types of cookies are necessary for our website to function and cannot be turned off by our system. They are usually only set in response to actions you take to request services (e.g. setting privacy preferences). In addition, the cookies that are strictly necessary include those that we use to prevent fraud.

    2. Performance / Analytics Cookies

      These types of cookies allow us to count visits and traffic sources in order to measure and improve the performance of our website. These cookies allow us to find out which pages get the most attention and which are the least popular with our users. All information collected by these cookies is anonymised.

    3. Functional cookies

      These types of cookies allow us to remember the choices you make on our website and to tailor our services to present content that is relevant to you.

    4. Advertising cookies

      We use these cookies to display advertising that is tailored to your surfing behaviour, among other things. These cookies are also used to measure the effectiveness of advertising campaigns. The cookies remember that you have visited a website and this information can then be passed on to other companies, such as advertisers. This means that after visiting our websites, you may be shown advertisements for our services on other websites.

    5. Elective options:

      You have the option to deactivate the use of cookies and similar technologies if your device supports this. You can adjust the cookie settings in your browser or in the device settings.

      You are free to disable the use of cookies and similar technologies if your device supports this. You can manage your cookie settings in your browser or device settings. In addition, you can decide whether we may use cookies and similar technologies to display personalised advertisements to you.

  12. Contact us

    If you have any questions regarding this privacy policy, please contact us at any time at laurenz@uni-app.com

    Neom GmbH (Udrus)
    Neue Mainzer Str. 46-5060311
    Frankfurt am Main
    Germany