At Virtual Internships, we are committed to protecting and respecting your privacy.
This Privacy Policy (“Policy”) (together with any other documents referred to therein) describes how Virtual Internship Partners Ltd. of 80-83 Long Lane, London, UK EC1A 9ET, and its affiliates (collectively, “Virtual Internships”, “we”, “us” and “our”) collect and process personal information we collect from your or that you provide us.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
- OUR APPOINTED DATA PROTECTION OFFICER
You may contact our Data Protection Officer with regards to any issue related to the processing of your personal data by email to [email protected].
- OUR APPOINTED REPRESENTATIVE IN THE EUROPEAN ECONOMIC AREA (EEA) AND SWITZERLAND
We have appointed Data Protection Representative Limited (DataRep), a company incorporated in Ireland with registered number 616588, to be our representative within the EEA and Switzerland. If you are based in the EEA or Switzerland and wish to raise a question to us, or otherwise exercise your rights in respect of your personal data, you may do so by:
- Sending an email to DataRep at [email protected] quoting ‹Virtual Internship Partners Ltd› in the subject line,
- Contacting DataRep on their online webform at www.datarep.com/data-request; or
- Mailing your inquiry to DataRep at the most convenient of the addresses listed in Schedule 3 to this Policy.
PLEASE NOTE: when mailing inquiries, it is ESSENTIAL that you mark your letters for ‘DataRep’ and not ‘Virtual Internship Partners Ltd.’, or your inquiry may not reach DataRep. Please refer clearly to ‘Virtual Internship Partners Ltd.’ In your correspondence. On receiving your correspondence, we are likely to request evidence of your identity, to ensure your personal data and information connected with it is not provided to anyone other than you.
- YOUR PERSONAL INFORMATION
- Information we collect from you
We collect and process some or all of the following types of information from you in the course of your use of https://www.virtualinternships.com and any other websites we operate with the same domain name and a different extension (“Website”), including but not limited to https://app.virtualinternships.com (the “Platform”) or providing our services:
- Information that you provide by filling in forms on the Website or on the Platform or filing in forms as part of the registration process, or while using our Website chat. This includes information provided when subscribing to our service or signing up for our program curriculum (CareerBridge) or requesting further information or services. We may also ask you for information when you have successfully signed up to an internship program.
- Specifically, personal details such as name, email address, location, country of residence, dates of internship, phone number, education details (university attended, major and expected graduation date), work experience (internships previously completed), CV, passport and identification details, medical records, date of birth or any information input by you when using the Website or the Platform, completing our survey forms, or using our services.
- If you are between the ages of 13 – 18 years of age, we will also require your date of birth and the name, email address and relationship of your parent or guardian.
- If you contact us, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for your personal development and research purposes, although you do not have to respond to them.
- Details of your visits to the Website or the Platform including, but not limited to, device information, traffic data, location data, weblogs and other communication data, and the resources that you access.
The provision of your name, email address, location information and country of residence is required from you to enable us to provide you with our services. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
- Information we collect from other sources
We may also obtain personal data from other sources as follows:
- Video interviews conducted using the software Videoask; and
- Your university, higher education provider, high school, pathway provider, referral agent or any other similar partner (together, “Partner Institutions”).
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USES MADE OF YOUR INFORMATION
- Lawful basis for processing
We rely on the performance of the contract we signed with you and/or your Partner Institution as the lawful basis on which we collect and use your personal data. Our legitimate interests are to fulfil our contractual obligations to you.
For children aged 13 – 18 years of age, we rely on the performance of the contract we signed with you and/or your Partner Institution, and the parental consent form signed by your parent or guardian, as the lawful basis for collecting your date of birth and the name, email address and relationship of your parent or guardian.
We may further rely on legitimate interests in providing our services to you as the lawful basis on which we collect and use your personal data.
When processing your medical records we rely on your explicit (clearly given) consent (permission) as a lawful basis for the processing.
- Purposes of processing
We use information held about you in the following ways:
- To provide you with our services.
- To ensure that content on the Website and Platform are presented in the most effective manner for you and for the device(s) you use to access and view the Website or Platform.
- To communicate with you directly through emails, calls, chats, video conferencing.
- To provide you with information and offers that you request from us or which we feel may interest you.
- To carry out our obligations arising from any contracts entered into between you and us or between us and your Partner Institution.
- To allow you to participate in interactive features of our service, when you choose to do so.
- To notify you about changes to our service.
- To provide progress reports to Partner Institutions.
- Otherwise, as disclosed to you at the point of collection or as required or permitted by law.
We do not sell your information to any third party.
- Marketing
In addition to the above uses we may use your information, to notify you about services which may be of interest to you. Where we do this, we will contact you by electronic means (e-mail or SMS) only if you have consented to such communication. If you do not want us to use your data in this way please either (i) tick the relevant box situated on the form on which we collect your data (for example, the registration form); (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) inform us at any time by contacting us at the contact details set out below.
- Integrations
Google APIs. Our use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. Information from Google APIs includes information from any Gmail account or Google Calendar account from your visits to the Website or the Platform. We will not use information from your Gmail account or Google Calendar account for any other purpose than those described in this Policy.
Microsoft Clarity. We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with the Platform through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.
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DISCLOSURE OF YOUR INFORMATION
We routinely disclose your personal data to third parties as follows:
- We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (e.g. to host our servers).
- We may share your name, email, education, work experience and video interview with potential host organisations for the purpose of matching you in an internship, and display such information on a Platform dashboard.
- We may pass information regarding your participation in a program, including progress reports, to your Partner Institution.
We sign contractual agreements to such third parties to protect your personal information, to only use it to deliver the contracted services to us, to prohibit them from selling it and not to disclose it without our knowledge and permission.
We may also disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).
We may further disclose your personal data to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
- if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; or
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions and other contractual agreements; or
- to protect our rights, property, or safety or that of our affiliated entities and our users and any third party we interact with the to provide the Website; or
- in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be of interest to you.
Other than as set out above, and save insofar as is necessary in order for us to carry out our obligations arising from any contracts entered into between you and us, we will not share your data with third parties unless we have procured your express consent to do so.
- STORING YOUR PERSONAL DATA
- Security
We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Website or the Platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
The Website or the Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms of use and that we do not accept any responsibility or liability for these policies and terms of use. Please check these policies before you submit any personal data to these websites.
- Keeping your personal data up to date
If your personal details change you may update them by contacting us at [email protected] or by using our chat service on the Website. If you have any questions about how we use data collected which relates to you, please contact us by sending a request by email to the contact details below.
We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to us, in order to ensure that the personal data we hold about you is as accurate and up to date as possible.
- How long we keep your personal data
- Any medical records (special category data) we obtain about you as an active programme participant will be kept only until the programme is completed. At which point it will be deleted.
- All other personal data (as specified above) we will hold for the period we are required to keep this information by applicable UK tax law (currently 6 years)
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Where we store your personal data
All information we hold about you is stored on data centres secure servers located in the United States and Singapore.
The data that we collect from you is transferred to, and stored at, a destination outside the United Kingdom and/or the European Economic Area (“EEA”). It may also be processed by staff operating outside the United Kingdom and/or EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the processing of your internship applications and the provision of support services.
In the event we transfer your personal data to a country without an adequacy decision from the United Kingdom, any such transfer will be subject to standard contractual clauses approved by the United Kingdom.
If you would like further information please contact us using our contact details (see ‘Contact’ below).
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CHANGES TO OUR PRIVACY POLICY
We reserve the right to modify this Policy at any time. Any changes we may make to our Policy in the future will be notified and made available to you using the Website or the Platform. Your continued use of the services and the Website or the Platform shall be deemed your acceptance of the varied privacy policy.
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CONTACT
All questions, comments and requests regarding this Privacy Policy should be addressed by email to [email protected] or write to us by courier service at 80-83 Long Lane, London, England EC1A 9ET.
Schedule 1 – For individuals based in the European Economic Area and United Kingdom
This section provides additional specific information for consumers based in the European Economic Area and the United Kingdom as required respectively by General Data Protection Regulation (EU Regulation 2016/679, the “GDPR”), the UK General Data Protection Regulation (the “UK GDPR”) and the UK Data Protection Act 2018 (the “DPA 2018”), as amended from time to time.
A. DATA CONTROLLER
For the purpose of the GDPR, UK GDPR and DPA 2018, the Data Controller is Virtual Internships.
B. YOUR RIGHTS
Under the GDPR, UK GDPR and DPA 2018, you have a number of important rights free of charge. In summary, those include rights to:
- access to your personal data and to certain other supplementary information that this Policy is already designed to address
- require us to correct any mistakes in your information which we hold
- require the erasure of personal data concerning you in certain situations
- receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal data concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal data
- otherwise restrict our processing of your personal data in certain circumstances
- claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email or write to us,
- provide us with enough information to identify you e.g. name, email address, any subscription details and any background information that is relevant to your inquiry,
- provide us with proof of your identity (a copy of your driving licence or passport), and
- identify the information to which your request relates including any reference number if you have one.
B. HOW TO COMPLAIN
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you the right to lodge a complaint with 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 telephone: 0303 123 1113.
Schedule 1 – For individuals based in California
This section provides additional specific information for consumers based in California as required by the California Consumer Privacy Act of 2018 (the “CCPA”), as amended from time to time.
A. Collection and Use of Personal Information
In the last 12 months, we have collected the following categories of personal information:
- Identifiers, such as your name, mailing address, email address, zip code, telephone number, or other similar identifiers.
- California Customer Records (Cal. Civ. Code § 1798.80(e)), such as username and password, company name, job title, business email address, and department.
- Internet/Network Information, such as your browsing history, log and analytics data, information about the device(s) used to access the Services and information regarding your interaction with our Website or Services and other usage data.
- Geolocation Data, such as information about your location (at country and city level) collected from your IP address.
- Sensory Information, the content, audio and video recordings of conference calls between you and us that we record where permitted by you and/or the law.
- Profession/Employment Information that you include in your CV, cover letter and send to us when applying for a position.
- Other Personal Information, such as personal information you provide to us in relation to a survey, comment, question, request, article download or inquiry and any other information you upload to our Application.
We collect personal information directly from you, from your browser or device when you visit our Website or Platform, from third parties that you permit to share your information or from third parties that share public information about you and as stated above.
See the sections above,”Your Personal Information” and “Use Made of Your Information,” to understand how we collect and use the personal information collected from California consumers.
B. Recipients of Personal Information
We share personal information with third parties for business purposes. The categories of third parties to whom we disclose your personal information may include: (i) our service providers and advisors, (ii) host companies, and (iii) Partner Institutions.
Please see the “Disclosure of Your Information” section of the Privacy Policy above for more information.
C. California Privacy Rights
As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):
- The right to know any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:
- The specific pieces of personal information we have collected about you;
- The categories of personal information we have collected about you;
- The categories of sources of the personal information;
- The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
- The categories of personal information we have sold and the categories of third parties to whom the information was sold. However, we do not sell your personal information; and
- The business or commercial purposes for collecting or selling the personal information. However, we do not sell your personal information.
- The right to request delletion of personal information we have collected from you, subject to certain exceptions.’
- The right to opt-out of Personal Information sales to third parties now or in the future. However, we do not sell your personal information.
- The right to correct inaccurate Personal Information we have collected from you.
- The right to limit the use and disclosure of sensitive personal information.
You also have the right to be free of discrimination for exercising these rights.
Please note that if the exercise of these rights limits our ability to process personal information (such as a deletion request), we may no longer be able to provide you with our products and services or engage with you in the same manner.
D. How to Exercise Your California Consumer Rights
To exercise your right to know and/or your right to deletion, please submit a request by contacting us at [email protected].
We will need to verify your identity before processing your request.
In order to verify your identity, we will generally require sufficient information from you so that we can match it to the information we maintain about you in our systems. Sometimes we may need additional personal information from you to be able to identify you. We will notify you.
We may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity or locate your information in our systems or as permitted by law.
You may choose to designate an authorized agent to make a request under the CCPA on your behalf. No information will be disclosed until the authorized agent’s authority has been reviewed and verified. Once a request has been submitted by an authorized agent, we may require additional information (i.e. written authorization from you) to confirm the authorized agent’s authority.
If you are an employee/former employee of a {{organization.name}} host company that uses our Platform and services, please direct your requests and/or questions directly to your designated VI Company Account Manager.
E. Minors Under Age 18
We collect personal information from consumers between the age of 13 and 18 who enroll in our programmes. We do not intentionally collect any personal information of consumers below the age of 13.
We obtain parental consent for the participation of all minors in our programmes, as well as for the processing of their personal information.
We do not sell the personal information of California consumers.
Please see the “Your Personal Information” and “Use of Your Information” sections of the Privacy Policy above for more information.
Schedule 3 – DataRep Mailing Addresses
| Country | Address |
| Austria | DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria |
| Belgium | DataRep, Place de L’Université 16, Louvain-La-Neuve, Waals Brabant, 1348, Belgium |
| Bulgaria | DataRep, 132 Mimi Balkanska Str., Sofia, 1540, Bulgaria |
| Croatia | DataRep, Ground & 9th Floor, Hoto Tower, Savska cesta 32, Zagreb, 10000, Croatia |
| Cyprus | DataRep, Victory House, 205 Archbishop Makarios Avenue, Limassol, 3030, Cyprus |
| Czech Republic | DataRep, Platan Office, 28. Října 205/45, Floor 3&4, Ostrava, 70200, Czech Republic |
| Denmark | DataRep, Lautruphøj 1-3, Ballerup, 2750, Denmark |
| Estonia | DataRep, 2nd Floor, Tornimae 5, Tallinn, 10145, Estonia |
| Finland | DataRep, Luna House, 5.krs, Mannerheimintie 12 B, Helsinki, 00100, Finland |
| France | DataRep, 72 rue de Lessard, Rouen, 76100, France |
| Germany | DataRep, 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany |
| Greece | DataRep, 24 Lagoumitzi str, Athens, 17671, Greece |
| Hungary | DataRep, President Centre, Kálmán Imre utca 1, Budapest, 1054, Hungary |
| Iceland | DataRep, Kalkofnsvegur 2, 101 Reykjavík, Iceland |
| Ireland | DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland |
| Italy | DataRep, BPM 335368, Via Roma 12, 10073 , Ciriè TO, Italy |
| Latvia | DataRep, 4th & 5th floors, 14 Terbatas Street, Riga, LV-1011, Latvia |
| Liechtenstein | DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria |
| Lithuania | DataRep, 44A Gedimino Avenue, 01110 Vilnius, Lithuania |
| Luxembourg | DataRep, BPM 335368, Banzelt 4 A, 6921, Roodt-sur-Syre, Luxembourg |
| Malta | DataRep, Tower Business Centre, 2nd floor, Tower Street, Swatar, BKR4013, Malta |
| Netherlands | DataRep, Cuserstraat 93, Floor 2 and 3, Amsterdam, 1081 CN, Netherlands |
| Norway | DataRep, C.J. Hambros Plass 2c, Oslo, 0164, Norway |
| Poland | DataRep, Budynek Fronton ul Kamienna 21, Krakow, 31-403, Poland |
| Portugal | DataRep, Torre de Monsanto, Rua Afonso Praça 30, 7th floor, Algès, Lisbon, 1495-061, Portugal |
| Romania | DataRep, 15 Piaţa Charles de Gaulle, nr. 1-T, Bucureşti, Sectorul 1, 011857, Romania |
| Slovakia | DataRep, Apollo Business Centre II, Block E / 9th floor, 4D Prievozska, Bratislava, 821 09, Slovakia |
| Slovenia | DataRep, Trg. Republike 3, Floor 3, Ljubljana, 1000, Slovenia |
| Spain | DataRep, BPM 335368, Avd. Castilla La Mancha Nº 70-1 (Nave A), 45270, Mocejon-Toledo, Spain |
| Sweden | DataRep, S:t Johannesgatan 2, 4th floor, Malmo, SE – 211 46, Sweden |
| Switzerland | DataRep, Leutschenbachstrasse 95, ZURICH, 8050, Switzerland |
