Last Updated: Jan 3021, 2021

QuraZone Holdings LTD. (“ApplyClever,” “CleverProof”, “we,” “us,” or “our”) provides users with the ability to investigate the process of becoming a student at certain schools around the world, including information respecting visa applications and program information. We also provide the ability to apply for admission to certain programs of such institutions through our recruitment partners and our website and to access ancillary services and products related to the international student journey (collectively, the “Services”).

To do this, ApplyClever collects your personal data. This Privacy Policy sets out the manner in which ApplyClever collects, uses, discloses, and otherwise manages personal data.

The changes made to this Privacy Policy go into effect as at the date listed above and your continued use of ApplyClever’s services and/or website after this date will be subject to our updated Privacy Policy.

General

In this privacy & cookies policy (“Policy”), we describe:

• the information that we collect and process about you (that you provide directly to us or is provided to us by third parties such as our recruitment partners);
• the purposes for which we collect and process information about you; and
• the basis on which we collect and process information about you, when you use this website located at https://ApplyClever.com or www.cleveryproof.com (our “Website”) and the services available through this Website, provided to our registered users (collectively, our “Services”).

In this Policy, the term “personal data” or “personal information” means personal data or data that relates to an identified or identifiable person.

We recommend that you read this Policy carefully in order to understand what ApplyClever and any affiliates and/or subsidiaries do with your personal data. Your use of our Website and Services and any dispute over privacy is subject to this Policy and any of our applicable Terms and Conditions for use of our Services, including their applicable limitations on damages and the resolution of disputes. Our Terms and Conditions for our Services are incorporated by reference into this Policy.] By visiting our Website, you are consenting to the practices described in this Policy.

Important Notes:

• SPECIFIC TERMS FOR EUROPEAN UNION (“EU”), UNITED KINGDOM (“UK”) AND EUROPEAN ECONOMIC AREA (“EEA”) CUSTOMERS ONLY: Please note that the whole of this Policy applies to you, together with additional provisions which are specific to EEA and UK customers, and can be found at Appendix 1.

SPECIFIC TERMS FOR CUSTOMERS FROM THE STATE OF CALIFORNIA ONLY: Please note that the whole of this Policy applies to you together with additional provisions which are specific to residents of California, and can be found at Appendix 2.

What We Collect and How

How does ApplyClever collect my personal data?

We collect personal data directly from you, about you from third parties such as our marketing affiliates and service providers used to verify your identity and prevent fraudulent activity, other ApplyClever users and other ApplyClever clients or customers for the purpose of providing the ApplyClever Services to you or as part of a customer referral program, and automatically as you use our Website and the Services. At this time, the use of our Services is only available to users who register for our Services.

We receive personal data about you from third parties, such as banking references, credit reporting agencies, affiliates, other ApplyClever users, events vendors, and other third parties (e.g., entities that assist us in validating your identity, for risk assessment purposes, for fraud prevention, etc.). We may combine this information with other information that we collect about you.

We, and our third-party service providers, automatically collect the following information about your use of our Website and our online Services through cookies, web beacons, log files and other technologies (subject to your consent where required by applicable law): your domain name, your browser type and operating system, web pages you view, links you click, your IP address, the length of time you visit our Website or use our Services, your activities on our Website, and the referring URL or the webpage that led you to our Website. Please see the section “Our Use of Cookies and Other Tracking Mechanisms” below for more information.

What personal data does ApplyClever collect?

The types of personal data we collect about you depend on your particular interaction with our Website and our Services, and generally includes, where permitted by applicable law:

Categories of Personal Data Collected	Specific Personal Data	Source of Personal Data
Identifiers	Name, email address, phone number, billing or mailing address, IP address, date of birth, national identification numbers and documents that may include your photograph and/or government identifier.	Directly from you, third parties on your behalf and as instructed by you, other ApplyClever users and customers, our service providers and affiliates.
Financial Information	Bank and credit account information, credit history as applicable, details of any transactions carried out using any of the Services	Directly from you, third parties on your behalf and as instructed by you, other ApplyClever users and customers, our service providers and affiliates.
Internet or Other Similar Network Activity	Other information collected through Cookies and other tracking technologies as listed above and as described in the section below entitled “Our Use of Cookies and Other Tracking Mechanisms”	From you directly and our third-party analytic tools and cookies usage (See the section below entitled “Our Use of Cookies and other Tracking Mechanisms”).
Commercial Information	Information about your business	Directly from you, third parties on your behalf and as instructed by you, other ApplyClever users and customers, our service providers and affiliates.
Geolocation Data	Geolocation	Directly from you and/or [through your use of the Mobile Application] and/or our third party analytic tools and cookies usage (See the section below entitled “Our Use of Cookies and other Tracking Mechanisms”).
Professional or Employment Information	Name and contact information, professional credentials and skills, educational and work history, salary, evaluations, references, interviews, certifications, disciplinary matters and other information of the type included on a resume, curriculum vitae or cover letter.	Directly from you or when another party, such as a recruiter or external website, provides it to us.
Other categories	Any other information that you choose to provide to us (e.g., when you send us an email/otherwise contact us).	Directly from you, third parties on your behalf and as instructed or permitted by you.

When We Collect Your Information and How We Use It

ApplyClever collects your personal data whenever you do any of the following and uses it as described:

Create an Account: To access certain features on the Website, you are required to create an account and provide your email address and password or sign in with Facebook or Google. Your login information is used to create your account, and otherwise provide and administer the service you requested.

Explore What Programs You Are Eligible To Apply To: You do not have to create an account to visit and browse certain features of our Website, such as to browse various schools and programs, read other content portions of the Website, or determine your eligibility for certain programs. If you choose to use our Website to discover programs you are eligible to apply for, we collect personal data such as your nationality, country of education, highest education, grading scheme, grade average, English/French exam score(s) and the disciplines or programs that you are interested in pursuing. ApplyClever uses this information to create a list of programs and schools  to which you are eligible to apply.

Create a Student Profile and/or Apply to an Educational Program: In order to apply to an educational program, you (or the recruitment partner acting as your legal representative) are required to create a student profile on our Website. The personal data we collect in your student profile helps us match you with schools and programs that fit your preferences and qualifications. This information may also be required by the school for the purposes of processing your application. This information may include your first and last name, email address, gender, date of birth, home and mailing address, passport details, marital status, emergency contact information, English or French language test score(s), educational preferences (such as preferred study destination and educational fields of interest), education history, volunteer experience, and other educational information.

Throughout the application process, you have the option to provide additional information such as documentation of awards and school projects. This information is not required to process your application but is recommended to enhance the success of your application.

We may use your profile information and other information about your use of the Website (such as search queries or other links you click on) to provide you with tailored school recommendations through the Website.

Use a student Email Account: We may create and provide you with a student email account to facilitate your communications with certain schools of interest. Student email accounts are only used for applying to educational programs through ApplyClever. ApplyClever monitors the incoming and outgoing emails from student email accounts and may collect information from those emails so that you do not miss any important information regarding your application. You can disable the functionality of this email account by contacting us as set out below.

Use of Our Services for Visa Processing: We offer students the option of processing their student visas through ApplyClever. If you choose to use this service, we may collect personal data for the purposes of processing your visa application (if necessary), including passport details and information included on a visa application form.

Use the CleverProof service for document verification: You may have the option to use CleverProof. CleverProof is an online solution that enables efficient and secure document verification. The document validation platform is designed to help partners and institutions single-source review documents for a variety of uses, from streamlining study permit VISA applications to validating student viability for education programs.   If you use CleverProof you will also be subject to applicable CleverProof terms and conditions, as well as this Privacy Policy.

CleverProof, powered by ApplyClever’s advanced SaaS services team, is another example ApplyClever supporting our mission to “Study For a Better Future”

Post On Our Website or Social Media Channels (including direct messages): You have the ability to post information (e.g. questions, comments and opinions) through ApplyClever’s services or on social media platforms, such as Facebook, LinkedIn, or Instagram, as well as send us direct messages via these platforms. Please be advised that any personal data that you voluntarily post to any public forum will be available to other individuals and you should exercise caution when posting any personal data. The content you post on sites owned by third parties (such as social media platforms) is subject to the privacy policies of those third parties.

Register to take any Courses:  You will have the ability to access our course content and provide voluntary personal data so we can register you as an individual taking the course.  As a certificate of completion may be issued, we will keep a record of you have registered and/or completed the course offering.

Communicate with Us: When you contact us with a comment, question or complaint, you may be asked for information that identifies you (such as your name, address and a phone number) along with additional information we need to help us promptly answer your question or respond to your comment or complaint. We may also retain this information to assist you in the future and to improve our customer service, products, service offerings, events and promotions.

Provide Information to Third Parties With Whom We Work: We may obtain personal data about you through your legal representative, or a recruitment partner(s) who you are working with and who are using our services to process your application to schools. Occasionally, ApplyClever will obtain information about you from third parties, such as mailing list providers and third-party service providers. Third-party providers are responsible for obtaining consent to provide personal data to us.

Payment Processing and transaction tracking: ApplyClever uses, with your consent, third-party PCI-certified payment service providers including but not limited to Western Union, Flywire or Stripe. When you directly make a payment using these payment service providers, you are subject to their privacy policies. They are independent of ApplyClever and ApplyClever is not responsible for their privacy practices.

Our applications are designed to directly connect our users securely, transparently and cryptographically to the PCI-certified payment processor. This helps ensure we maintain the privacy of your financial transactions. The payment processor provides ApplyClever with a transaction number and status. This information is often required for visa applications as proof of program payment as well as a demonstration of student commitment to their selected program. ApplyClever maintains a list of payment processors that we may use to process payments to independent service providers and/or third-party contractors in connection with the Services.

Sign Up for Marketing Email and Other Communications: We may offer you the ability to sign up to receive ApplyClever marketing and promotional communications through the Website, on third-party websites (including through social media sites), or educational events and information sessions. In these circumstances, we collect certain personal data (such as first and last name, email address or mobile phone number) which we use to send you emails and other communications containing ApplyClever updates, tips, and other content that may be of interest to you. You can opt-out of receiving promotional emails from us by following the “opt-out” or “unsubscribe” instructions provided in your email or text message, or by contacting us as set out below. Please note that you may continue to receive messages from us regarding your application or other transactional and account-related electronic messages from us.

Participate in Our Surveys and Customer Research: From time to time, we may offer you the opportunity to participate in one of our surveys or other customer research. The information obtained through our surveys and customer research is used in an aggregated, non-personally identifiable format. We use this information to help us understand our customers and to enhance our product and service offerings, promotions, and events.

Sign Up for Contests and Promotions: When you participate in a contest or promotion, we may collect your name, address, phone number, email address, and other information you provide. We use this information to administer your participation in the contest or promotion.  If non-identifiable data is used for research purposes, then the limitation of liability and indemnity clauses if any contained within the Terms and Conditions are waived with respect to any harms suffered or liabilities incurred as a result of any research activities. 

Apply for Employment at ApplyClever: In connection with a job application or related inquiry regarding potential employment with ApplyClever, you may provide us with certain personal data about yourself (such as that contained in a resume, cover letter, or similar employment and education-related materials). We use this information for the purpose of processing and responding to your application for current and future career opportunities.

Apply To Become an ApplyClever Recruitment Partner: In connection with applying to become a potential recruitment partner with ApplyClever, you may provide us with certain personal data such as your first name, last name, address, email address, personal data about your education and employment background and banking data. We use this information for the purpose of processing and responding to your application to become an ApplyClever Recruitment Partner and for paying you as needed using third-party payment processors.

You are responsible for providing accurate and up-to-date information.

When Do We Share Your Information

We share your personal data with third parties, including service providers, regulated institutions (e.g., financial institutions), affiliated entities, and business partners as set out in the table below.

In the section below, we also list the reasons why we share information.

How and Why We Share Your Information

With whom we share your personal data	Reason
Schools	We share the information in your application with the schools that you are applying to (either directly or through a third party on your behalf, within Canada or abroad). Once ApplyClever has provided your information to these schools for your application for admittance, ApplyClever does not have any control over the use of such information by these schools and recommends that you contact them directly if you have any questions about the manner in which your personal data is treated.
Partners	From time to time, we may partner with third parties to provide benefits to registered members of the Website. We may provide certain personal data to third parties so that they can contact you with information about the benefits and/or we may share aggregated, non-identifiable profile and usage data with third-party partners for marketing and analytics purposes. We may use Facebook’s Custom Audiences to deliver advertisements to our subscribers on Facebook. Your personal information is not shared with Facebook; your email address is converted to a unique number that is matched with another unique number to identify you within Facebook. You can opt-out of Facebook Audience ads.
Service Providers	We may transfer (or otherwise make available) your personal data to third parties who provide services on our behalf. For example, we may use service providers such as cloud providers to send our emails, host the Website and data (including cloud providers) and operate certain of its features. Other service providers may assist us with the provision of the services, help us verify your identity, prevent, detect and protect against fraudulent activity or abuse of our services, conduct internal research and analytical assessments, process your transactions, maintain your account(s) and provide you with customer care services. These service providers include internet service providers, data and cybersecurity services, banks, financial institutions, payment processors, financial services providers, remote access services, service providers that help us verify your identity and help us comply with our legal and regulatory obligations; and our business, legal, tax, financial and other advisors, on a confidential basis. Your personal data may be maintained and processed by third-party service providers in the US or other jurisdictions. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal data for their own marketing or other purposes.
Parties to and those involved in a business transaction with ApplyClever	We may transfer any information we have about you as an asset in connection with a proposed or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of ApplyClever or as part of a corporate reorganization or other change in corporate control.
Researchers	With your consent, ApplyClever uses your data internally for research and development to improve our existing products and services and/or create new features to serve you better. ApplyClever also uses non-personal data (“Metadata”) for this same purpose. With your consent, we may share your personal data with third parties involved in research and development to improve our existing products and services and/or create new features to serve you better. Such third parties may include educational institutions, academics, and others in similar fields.
Lawyers, courts and law enforcement	ApplyClever and our Canadian, US and other service providers may provide your personal data in response to a search warrant or other legally valid inquiry or order, or to an organization in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by applicable Canadian, the US or other law. We may also disclose personal data where necessary for the establishment, exercise, or defence of legal claims, to detect, suppress or prevent fraud, and to investigate or prevent actual or suspected loss or harm to persons or property. Where you have engaged a Recruitment Partner to submit your application to ApplyClever, we may be required for legal, regulatory and/or compliance purposes to contact you directly to confirm certain information provided in connection with your application process.

Aggregated and de-identified information – we may disclose aggregate or de-identified information about users for marketing, advertising, research, or similar purposes?

With consumer reporting agencies, as permitted by law?

Affiliates?

If you do not want us to use your personal data for us to market to you, and/or to pass on to third parties for marketing purposes, please contact us through the various communication channels available, as listed under the Section titled “Contact Us, Questions, Updating Your Info,  Opting Out” below. You will also be able to unsubscribe from any marketing emails sent to you by ApplyClever using a link provided in such emails. We do not sell your personal data.

Where We Store Your Data

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Our servers are predominantly located in the USA excluding the CleverProof application which is hosted entirely in Canada. Many of our service providers are also located outside of Canada. While we use appropriate safeguards to keep your information secure, the laws in other places may differ from those in Canada and authorities in those jurisdictions may access your information in accordance with their local laws.

Safeguards

ApplyClever takes the safeguarding of your information very seriously. We have implemented reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of personal data in our custody and control, including limiting access to our database to legitimate users and employing device encryption and version tracking.

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 our Website; 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 unauthorized access.

Your Rights

You have the following rights:

• Access
• Correction (Right to rectification)
• The right to withdraw your consent/be forgotten
• The right to report or complain

You may access, update and correct inaccuracies in your personal data in our custody or control at any time, subject to limited exceptions prescribed by law. Simply log into your account, go to your account profile, and make the necessary changes.

You can also request access, corrections or updates to other personal data in our records by contacting us as set out below. We may request certain personal data for the purposes of verifying the identity of the individual seeking access to their personal data records.

You may request your data be withdrawn (forgotten); this type of request can be performed assuming ApplyClever is in a legal position to fulfill such a request. You must not have an active study application where financial or billing records are or may be in process should an application to a third-party service be engaged. Should ApplyClever be able to comply with your request, only the personal data you provided will be forgotten. Non-personal data (“Metadata”) will be maintained regardless.

Should you wish to lodge a concern or complaint to ApplyClever, please contact us as set out below. We will respond to your concerns in a reasonable time, typically within 10 business days