CampusConnect - Privacy policy 

Last updated: 10/01/25 

Welcome to CampusConnect! This Privacy Policy applies to CampusConnect iOS and Android Mobile Applications (our “App”). In the below policy, we inform you about the scope of the processing of your Personal Data.

WHAT IS CAMPUSCONNECT

CampusConnect is a white labeled applicant onboarding service designed to help and support new university entrants. We do this by connecting where accessible, applicants (pre-enrolment) together with others who they will be studying with (fellow applicants), current students (ambassadors), recent graduates or alumni, and staff from your chosen university. 

GENERAL INFORMATION

a) What law applies?

Our use of your Personal Data is subject to Ireland’s Data Protection Act (“DPA”) and the EU General Data Protection Regulation (“GDPR”), and of course we process your Personal Data accordingly. 

b) What is Personal Data?

Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address and device ID.

c) What is Special Category Data?

Special category data is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to consent to the processing.

d) What is processing?

Processing means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

e) Who is responsible for data processing?

The responsible party within the meaning of the DPA and the GDPR is CampusConnect of Unit 5, ManorHUB Business Hub, Park Road, Manorhamilton, County Leitrim, Ireland (“CampusConnect”, “we”, “us”, or “our”). Please direct any questions you may have to support@campusconnect.ie or write to us at the above address. 

f) The Legal Bases for processing Personal Data

In accordance with the above-mentioned laws, we have to have at least one of the following legal bases to process your Personal Data: a) you have given your consent, b) the data is necessary for the fulfillment of a contract / pre-contractual measures, c) the data is necessary for the fulfillment of a legal obligation, or d) the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

PROCESSING OF AUTOMATICALLY COLLECTED DATA

a) Downloading our App

The App can be downloaded from the “Google Playstore'' a service offered by Google LLC, or the Apple App service “App Store” a service of Apple Inc, to install our App. Downloading it may require prior registration with the respective App store and/or installation of the respective App store software.

b) Installing our App 

As far as we are aware, Google collects and processes the following data: License check, network access, network connection, WLAN connections, and location information. However, it cannot be ruled out that Google also transmits the information to a server in a third country. We cannot influence which personal data Google processes with your registration and the provision of downloads in the respective App store and App store software. The responsible party in this respect is solely Google as the operator of the Google Play Store. 

As far as we are aware, Apple collects and processes the following data: device identifiers, IP addresses, location information, it cannot be excluded that Apple also transmits the information to a server in a third country. We cannot influence which personal data Apple processes with your registration and the provision of downloads in the respective app store and app store software. The responsible party in this respect is solely Apple as the operator of the Apple App Store. 

c) Device information

Google and Apple may collect information from and about the device(s) you use to access our App, including hardware and software information such as IP address, device ID and type, device-specific and App settings and properties, App crashes, advertising IDs (AAID), information about your wireless and mobile network connection such as your service provider and signal strength; information about device sensors such as accelerometer, gyroscope, and compass and Payment Data and Billing confirmations.

d) Authorizations and Access

We may request permission to store your App data including your Internet Connection and Network, Location, Push Notifications. The legal basis for data processing is our legitimate interest, the provision of contractual or pre-contractual measures and your consent. You can deny access on your device via the Settings/Notifications/ options of your device; however, this means that our App may not function as intended.

e) Location Information 

When you use one of our location-enabled services, we may collect and process information about your mobile device’s coarse GPS location and the time the coarse location information is recorded to provide the Services with location-based information and features. Some of these services require your Personal Data for the feature to work and we may associate location data with your device ID and other information we hold about you. We keep this data for no longer than is reasonably necessary for providing services to you. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.

f) Push messages

When you use our App, you will receive so-called push messages from us, even if you are not currently using our App. These are messages that we send you as part of the performance of the contract using OneSignal.com for Push Notifications. You can adjust or stop receiving push messages at any time via a) the device settings of your device or b) or by enabling or disabling specific types of notifications within the App. Insofar as you consent to the use of push messages, consent is the legal basis for the processing.

g) Firebase

We use the Google Firebase developer App and related features and services provided by Google. We use the following Google Firebase services in our App: a) Firebase Analytics, b) Firebase Cloud Messaging for Push Notifications; and c) Firebase Crashlytics. By integrating Google services, Google may collect and process information (including personal data). It cannot be excluded that Google also transfers the information to a server in a third country. We cannot influence which data Google collects and processes. Firebase's key security and privacy information can be found here: https://firebase.google.com/support/privacy The legal basis is the implementation of the user contract for the use of the App.

h) Crashlytics

The app uses the tool Crashlytics to log crashes of our App. No personal data is transmitted. Only real-time crash reports with precise details of code locations and device information are sent, which is intended to simplify maintenance and improve the resulting stability of our App. The legal basis for data processing is our legitimate interest. In the settings under data services, you can select whether you want to send crash reports or not. 

i) Google Analytics for Firebase

Our App uses the web analytics service Google Analytics for Firebase, which uses tracking technologies to track your use of our App. In this respect, information is generated about, among other things, the number of users and their sessions, the session duration, the operating system used by the users, their device model, the region from which our App is accessed, the first start of our App, our App execution and any updates.

In order to provide the relevant data for analysis, Firebase Analytics uses your a) device's advertising ID, b) an App instance ID (a randomly generated number that identifies a single app installation), c) and the IP address, which is shortened (IP masking) before being processed on Google's servers (which may be located outside the EEA) to generate the usage analysis. You can object to the use of Firebase Analytics at any time by disabling the sending of usage statistics in your device settings (Reset Advertising ID). We have no influence on these data processing operations. The basis for processing is our legitimate interest and your consent.

j) MapBox

We use MapBox API, a service of MapBox Inc. We use MapBox to visually display geographical information. When using MapBox, MapBox also collects, processes and uses data about visitors' use of the map functions. MapBox stores a cookie on your end device. This transfers information about your use of our website and app, including your IP address, to a MapBox server in the USA and stores it there. This data is processed for the purpose of displaying the website or ensuring the functionality of the MapBox service. MapBox may pass this information on to third parties if this is required by law or if the information is processed by third parties on behalf of MapBox. The basis for processing is our legitimate interest and your consent.

k) Uploadcare

We use the service uploadcare, offered by Uploadcare, LLC for uploading, processing, storing and delivering files (e.g. photos) for our web applications. In order to provide the service, some information about users is collected. This concerns IP address, request headers, uploaded data and data that is mediated to the API of uploadcare. The basis for processing is our legitimate interest and your consent.

DATA PROCESSING BY US

a) Contacting us

Personal data is processed depending on the contact method. In addition to your name and email address, IP address or phone number, we usually collect the context of your message, which may also include certain Personal Data. The personal data collected when you contact us is used to process your request and the legal basis is your consent. 

b) Contracting with us 

The protection of your data is particularly important to us in the performance of the contract with you or your relevant University. We therefore only want to process as much Personal Data) as is absolutely necessary. Nevertheless, we rely on the processing of certain Personal Data, to fulfil our contractual obligations to you or to carry out pre-contractual measures. 

c) Service Data 

The Personal Data processed by us depends on how you are using your services and the requests you are submitting for the following purposes:

  • creating and maintaining Public Profile comprising the Personal Data and other content about you which you choose to make available on CampusConnect, so that users are able to identify you and interact with you;

  • publishing, writing, creating, uploading, sharing, changing, editing, saving and browsing content

  • changing, editing and reviewing your CampusConnect Profile (including Public Profile) and Content which you have created and uploaded to CampusConnect;

  • interacting with other users and your University on CampusConnect, including by exchanging private messages and other content with other users or using CampusConnect;

  • sending feedback in relation to CampusConnect to us;

  • posting content in comments on CampusConnect;

  • participating in surveys, web polls and other content creation on CampusConnect as well as in any other activity that results in the ranking, rating, classification, categorisation and evaluation of content made available on CampusConnect, including your Content.

We may choose to verify some of the information that you give us when requesting an invitation to use CampusConnect, when registering as a user of CampusConnect or when using CampusConnect. This may include the following:

d) Personal Data: Personal data we collect are name, username, email address, images, university or college name, as well as country or county of residence or nationality. It does not include data where the identity has been removed (anonymous data).

e) Biographic data (Special Categories of Personal Data): 

  • Prospective students: your Profile picture and fields labelled as About me, Type of student, Area of study, Country, Start date, End date, Campus (where applicable) and Interests will be visible on the profile that may be viewed only by other registered users of CampusConnect (your “CampusConnect Profile”). 

  • Current students (“ambassadors”): your Profile picture and fields labelled as About me, Type of student (indicating that you are an ambassador), Area of study, Start date, End data, Campus (where applicable) and Interests will be visible on the profile that may be viewed only by other registered users of CampusConnect (your “CampusConnect Profile”). You will have the opportunity to publish, review and edit your Profile, which is visible to all registered users of CampusConnect (your “Public Profile”). 

  • Graduates (“alumni”): your Profile picture and fields labelled as About me, Type of student (indicating that you are an Alumni), Area of study, Start date, End date, and Interests will be visible on the profile that may be viewed only by other registered users of CampusConnect (your “ CampusConnect Profile”). You will have the opportunity to publish, review and edit your Profile, which is visible to all registered users of CampusConnect (your “Public Profile”). 

  • Administrators (“Staff”): your Profile picture and fields labelled as About me, Type of user (indicating that you are a member of staff), Area of study (if applicable), and Interests will be visible on the profile that may be viewed only by other registered users of CampusConnect (your “ CampusConnect Profile”). You will have the opportunity to publish, review and edit your Profile, which is visible to all registered users of CampusConnect (your “Public Profile”). 

  • Your content: When you post or upload text, sound, images, comments, private messages, feedback sounds, video footage, graphics, quotes, other material and information (user-generated content), we will process such information in accordance with the legal requirements as set out in the relevant applicable law. Information posted on the open areas of the site will be publicly accessible. Please note that by submitting user-generated content you may also be making personal data available to us. 

  • Information about interests and preferences: We may also collect information about you interests, preferences including for example area of study, exchange host country, exchange host city, exchange host university/college, start date, end date and travel information; 

f) Aggregated Data: We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose including improving our website and services. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

We recognize that you own your Service Data and provide you with complete control of your Service Data by providing you the ability to (i) access your Service Data, (ii) share your Service Data through supported third-party integrations, and (iii) request export or deletion of your Service Data. 

We process Service Data as Data Processor or in other words on behalf of your University, in accordance with your University's instructions and shall use it only for the purposes agreed between you and your University.

We ensure that access by our employees to your data is only available on a need-to-know basis, restricted to specific individuals, and is logged and audited. We communicate our privacy and security guidelines to our employees and enforce privacy and protection safeguards strictly.

For the purpose of providing our Services all Service Data processed by us will be processed using our Business Partners as set out in this policy. We take appropriate legal precautions and corresponding technical and organisational measures to ensure the protection of your Service Data.

g) Administration, financial accounting, office organisation, contact management

We process data in the context of administrative tasks as well as organisation of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.

GENERAL PRINCIPLES

a) What we do not do

  • We do not request Personal Data from minors and children;

  • We do not collect any information about criminal convictions and offences.

  • We do not process special category data without obtaining prior specific consent;

  • We do not use Automated decision-making including profiling; and

  • We do not sell your Personal Data.

b) Sharing

We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of our services, b) you have consented to the disclosure, c) or the disclosure of data is permitted by relevant legal provisions. In addition, we may disclose your Personal Data: in connection with law enforcement, fraud prevention or other legal proceedings; as required by law or regulation; if CampusConnect (or a part of CampusConnect) is sold to or merged with a company; or if we have reason to believe that disclosure is necessary to protect our business.

c) International Transfer

We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer.

d) Storage

All Service Data collected is generally transferred to our DigitalOcean, LLC Server located in Ireland and in a MongoDB database. The legal basis for the data processing is our legitimate interest in providing our App and Services.

e) Retention

Processed Personal Data will be deleted as soon as the purpose of the processing has been achieved and there are no longer any legally required retention obligations.

f) Data Security

Our App uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through our App. 

Nonetheless, databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised, and the notice will be accompanied by a description of the action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after which the breach was discovered.

YOUR RIGHTS AND PRIVILEGES 

a) Privacy rights 

You can exercise the following rights:

  • Right to information

  • Right to rectification

  • Right to object to processing

  • Right to deletion

  • Right to data portability

  • Right to withdraw consent

  • Right to complain to a supervisory authority

  • Right not to be subject to a decision based solely on automated processing.

If you wish to exercise any of your rights, please contact us.

b) Updating your information

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us. 

c) Withdrawing your consent 

You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

d) Access Request 

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the respective legal regulations mentioned above).

e) Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The Data Protection Commission (DPC) in Ireland is the relevant authority in matters of data protection (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us in the first instance.

VALIDITY AND QUESTIONS

This Privacy Policy was last updated on Friday 10th January 2025 and is the current and valid version. However, from time to time changes or a revision to this policy may be necessary.

If you feel that the above is not sufficient or if you have any queries as regards the collection, processing or use of your information we are looking forward to hearing from you. We will make every effort to reply as soon as possible and take into consideration any suggestions from your end.