Note: This policy is subject to change at any time. Please check all StudentRoomStay Concierge (“SRS Concierge”) Policies on a regular basis for updates.
This policy has been designed and implemented for users of StudentRoomStay Concierge, or future entities that will come under the collective (StudentRoomStay Concierge). For further information please go to: www.concierge.studentroomstay.com
StudentRoomStay Concierge provides administrative and support services to hosts, students/guests/users, agents, educators and other persons involved in the international student homestay industry (“Services”) through various channels, including via our website/s and the Homestay Management System accessible through the Website/s.
Personal Information (“PI”), What PI do we collect?
The type of PI we collect depends on your relationship with us, as follows:
Public: if you submit a query via our online ‘contact us’ form, or otherwise email or call StudentRoomStay Concierge, we may collect your name, email address, phone number, address and location.
Registration: when you register with us as a host, student/guest/user, educator or agent, we will collect your name, your chosen username and password, email address, mailing address and profile picture (should you choose to provide one). If you register as a host, we will also ask you to provide information about your background to help us assess your suitability to be a host, and banking details for payments. If you register as a student/guest/user, we will also ask you to provide your bank or credit card details for payments, passport and nationality details, student registration details, and other information about you that will help us to find the right placement for you.
What other information do we collect?
Log Files: Any time you visit any of our websites, our servers automatically gather information from your browser (such as your IP addresses, browser type, Internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks) to analyze trends, administer the site, prevent fraud, track visitor movement in the aggregate, and gather broad demographic information. For example, we may log your IP address for system administration purposes. IP addresses are logged to track a user’s session. This gives us an idea of which parts of our site users are visiting. We do not share the log files externally.
Purchase Information: To process purchases, we will require your name, address, phone number, email address and credit card information. Such information is used to process your order or as otherwise described herein. Credit card transactions are processed through a PCI Level 1-certified industry leading provider, which only uses your information for that purpose.
How your “PI” is collected, why is it needed and how is it used?
How we collect your PI
We collect your PI as part of offering or providing our Services and answering your questions. This includes PI you provide through our Website (e.g. via our online contact us form, or when you register an account with us) and during telephone calls. Generally, we collect your PI directly from you but may also collect your PI from other people or organizations if you have given consent for them to do so (e.g. an Education Agent for student/Student/users)
Why do we need your PI?
We need your PI to provide you with our Services which include:
a) assessing your eligibility and monitoring your compliance with host or student/Student/user (as relevant) contractual obligations,
b) providing you and other persons involved in your homestay arrangement with the Services,
c) administering your account, including facilitating matters in relation to payment, insurance, and complaints,
d) informing you (including by direct marketing) about our Services and the goods and/or services of third parties available in connection with our Services,
e) creating and updating our database(s),
f) ensuring compliance with our contractual and other legal obligations to you,
g) monitoring your use of the Website and contacting you about changes to the Website or for customer service purposes,
h) administering our relationship with you by responding to your enquiries; and
i) any other act we are required or authorized to do by law,
These are referred to as the “Main Purposes”.
If you do not provide us with your PI, we may not be able to carry out some or all of the Main Purposes.
How do we use your PI?
By submitting your PI to us, you consent to us using your PI for the Main Purposes or any purpose that could be reasonably expected at the time your PI was collected. We may also disclose your PI to agencies, service providers and other businesses (including those owned by us) to help us do these things.
We may also use your PI:
a) for any purpose disclosed to you in an information collection statement at the point where we collect your PI; or
b) for a purpose related or ancillary to one of the Main Purposes.
We may use certain non-personally identifiable information (such as anonymous usage data, IP addresses, browser type etc.) to improve the quality and design of our Website, and to create new features, promotions, functionality and services by storing, tracking, analyzing and processing user preferences and trends as well as user activity and communications.
Can you remain anonymous or use a pseudonym?
We will, if practicable, allow you to use a pseudonym or to not identify yourself unless this is impractical or against the law.
In some instances, if you do not provide us with certain PI we may not be able to provide you with the relevant product, Service or information (including fulfilling the Main Purposes)). This may have an effect on whether we can begin or continue a relationship with you or allow you to use our Services.
What disclosures will we make?
In general, we will only disclose your PI for the Main Purposes. PI may be communicated electronically or verbally by phone. We may also disclose your PI in other ways with your consent or as required or permitted by law.
We may disclose your PI to our service providers and partners in order to assist us in providing the Services to you. We use a network of global third-party service providers in order to ensure that the Services we provide to you are of the best possible standard. Some of our service providers, or the services they provide (like cloud-based storage solutions), are based outside of the USA. This could include places like Europe, Asia and Australia. In order to protect your information, we take care where possible to work with service providers who we consider maintain acceptable standards of data security compliance, and we do our part to meet those standards as they apply to StudentRoomStay International Corporation
Disclosure to Other Users. As an integral part of providing the Main Purposes, we may disclose your profile information to other Student, Students and Users. Photos and other profile information provided by you will be available to profiles that are matched with you. PI may be communicated to your matches electronically or verbally by phone.
Disclosure by Law. You acknowledge and agree that we may disclose information you provide if required to do so by law, at the request of a third party, or if we, in our sole discretion, believe that disclosure is reasonable to (1) comply with the law, requests or orders from law enforcement, or any legal process (whether or not such disclosure is required by applicable law); (2) protect or defend StudentRoomStay International Corporation, or a third party’s, rights or property; or (3) protect someone’s health or safety, such as when harm or violence against any person (including you) is threatened.
Access, Confidentiality & Security
Is your PI confidential and secure?
We take all reasonable steps to keep the PI we hold secure and to ensure it is protected against misuse, loss, unauthorized access, modification or inappropriate disclosure. We may hold PI in both hard copy and electronic forms in secure systems accessible only to authorized personnel.
‘Cookies’ and related software
Our software may issue ‘cookies’ (small text files) to your device when you access and use the Website and you will be asked to consent to this at the time (e.g. when you first visit our website). Cookies do not affect your privacy and security since a cookie cannot read data off your system or read cookie files created by other sites.
You can set your system not to accept cookies if you wish (for example by changing your browser settings so cookies are not accepted), however please note that some of our Website features may not function if you remove cookies from your system. For further general information about cookies please visit www.aboutcookies.org or www.allaboutcookies.org.
Links to other websites
Because many users tend to use our service at different points of their student or accommodation needs, we retain your personal information for continued service and convenience purposes until you advise us not to do so (See section “Contacting us about privacy” below). Notwithstanding the foregoing, we may retain personal information in order to comply with applicable laws, keep accurate records, resolve disputes, prevent fraud, enforce our Terms and Conditions of Service or other agreements, or for any other legally permissible purpose.
What will SRS Concierge do if there is a “Data Breach”
SRS Concierge is committed to managing personal information in accordance with privacy principles. We have systems and processes in place to ensure your data is secured and appropriately managed, including in the event of a suspected or known data breach. Any questions about data security can directed to us via the contact details below.
Contacting us about privacy
You are responsible for ensuring that your PI is accurate, current and complete. If you have a registered account with us, you can update or change your PI and email preferences at any time via your account’s profile page.
You may ask us to provide you with the PI we hold about you, subject to certain limitations under law. For your protection, we may require you to confirm your identity before access to your PI is granted. In most cases, we can provide you with a summary of your PI free of charge. However, in some circumstances, reasonable costs may be charged to you in accessing your PI, subject always to the law.
If you have a question or want to make a complaint about how we handle your PI, please contact us using the details below. We will review your complaint and will respond to you after we have carefully considered it. We may require further information from you in order to resolve any complaints. Requests may take up to 20 working days to complete.
We can be contacted via:
Contacting us about receiving a summary of your “PI”
If you wish for SRS Concierge to provide you with your currently held “PI” on your profile, across any of our services, please contact us as below:
Contacting us about removing your “PI” from the system
If you wish for SRS Concierge to remove your “PI” from our system, across any of our services, please contact us as below:
Please note that such removal may impact on your ability to access or use the Services that we provide.
Changes to this policy
Acceptance of Privacy Statement
Your use of our website(s), including any dispute concerning privacy, is subject to this privacy statement and the applicable Terms and Conditions of Service. BY USING OUR WEBSITE, YOU ARE ACCEPTING THE PRACTICES SET OUT IN THIS PRIVACY STATEMENT AND THE APPLICABLE TERMS AND CONDITIONS OF SERVICE.
Your continued use of any portion of our website following posting of the updated privacy statement will constitute your acceptance of the changes.
Updated August 15, 2020