Privacy Policy

This Privacy Policy addresses the following:

1. What Types of Personal Information We Collect

2. The Purposes and Legal Bases for our Collection of Personal Information

3. How We Collect Personal Information

4. With Whom We Share Personal Information

5. How We Protect Personal Information

6. How We Retain Personal Information

7. Storage and Processing of Information in Canada

8. Personal Information of Minors

9. Your Legal Rights

10. Changes to this Privacy Policy

11. Contacting Us, Challenging Compliance

What Types of Personal Information We Collect

We may collect the following types of Personal Information about a student through our Services:

• Identity Data, including the student’s first and last name, date of birth, gender, school or university student number, and other similar identifiers.

• Contact Data, including the student’s mailing address, email address, and telephone number(s), and similar information about the student’s emergency contact person(s).

• Homestay Matching Data, including information about whether the student smokes, is comfortable living in a home with pets, or has any food allergies, and other similar information.

We may collect the following types of Personal Information about a host family and its members through our Services:

• Identity Data, including host family members’ first and last names, dates of birth, and similar identifiers.

• Contact Data, including the host family’s mailing address and family members’ email addresses and telephone numbers.

• Homestay Matching Data, including information about whether host family members smoke, whether the family has pets, family members’ hobbies, family rules and expectations, whether the family is able to accommodate any food allergies a student who lives with them may have, and other similar information about the family’s household and lifestyle.

We also ask families to provide a picture of themselves. In addition, we require family members to provide us with background criminal check reports.

The Purposes and Legal Bases for our Collection of Personal Information

We collect students’ and host family members’ Personal Information for the following purposes, and we rely on the legal basis for processing identified below:

• Identity Data: We collect and process Identity Data for the purpose of registering and maintaining students’ and host families’ accounts with our Services. The legal bases for processing Identity Data are consent, and to perform our contracts with students/their parents or legal guardians and host families.

• Contact Data: We collect and process Contact Data for the purpose of verifying students’ and host families’ account details and contacting and communicating with them as we provide our Services. The legal bases for processing Contact Data are consent, and to perform our contracts with students/their parents or legal guardians and host families.

• Homestay Matching Data: We collect and process Homestay Matching Data for the purposes of generating appropriate homestay matching options for our students and host families and facilitating the homestay relationship between students and families. The legal bases for processing Homestay Matching Data are consent, and to perform our contracts with students/their parents or legal guardians and host families.

We may also use Personal Information to maintain and improve the quality and effectiveness of our Services and to develop new services. The legal basis for our doing so is our legitimate interest in monitoring and enhancing the quality of our Services and in product development.

We will never use Personal Information for fundraising or marketing purposes.

How We Collect Personal Information

NHISS collects students’ and host family members’ Personal Information directly from them. They provide their Personal Information to us through the application forms that they complete and provide to us, and through our discussions and electronic communications with them over the course of the homestay relationship.

With Whom We Share Personal Information

We may share a student’s Identity Data with their school or university to verify their school or university enrollment and eligibility for our Services.

We may also share the student’s Personal Information with their school or university if weneed the school or university’s assistance in resolving any disagreements or conflicts between the student and their host family.

We will share a student’s Personal Information as required with host families. For example, we may indicate to a potential host family whether a student has any food allergies, so that the family may evaluate whether they would be able to accommodate those food allergies if the student were to live in their home.

We may share host family members’ Personal Information as required with students who may potentially live with them. For example, we may indicate to a student what a host family’s rules and expectations are for household members, so that the student may evaluate whether the family would be suitable for them.

We may also provide a student with family members’ first and last names, dates of birth, and contact information.

Students’ and host family members’ Personal Information may be disclosed, transferred, or otherwise made available to third parties who provide services on our behalf.

Our service providers receive or have access to the information they need to provide their services to us. They are not authorized to use or disclose your Personal Information for their own purposes, including marketing purposes.

They are contractually obligated to use your Personal Information only as we instruct them to. They are required to have in place data security mechanismsthat are as stringent as the ones we have at NHISS.

We and our service providers may disclose Personal Information where required or permitted by law or legal process.

For example, Personal information may be disclosed:

• In response to a search warrant or other legally valid order or inquiry;

• To another organization for the purpose of investigating a breach of an agreement or contravention of law or preventing, suppressing, or detecting fraud;

• where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property;

or

• as otherwise required or permitted by law.

We may disclose Personal Information to third parties in connection with a business transaction, including a merger or sale (including transfers made as part of bankruptcy or insolvency proceedings) involving all or part of NHISS or as part of a corporate reorganization, stock or asset sale, or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.

How We Protect Personal Information

We implement reasonable administrative, technical and physical measures in an effort to safeguard the Personal Information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure.

We restrict access to students’ and host family members’ Personal Information to those employees and authorized service providers who need to have access to theinformation to fulfill their job duties.

Although we take reasonable precautions against possible security breaches of our websites and our customer databases and records, no website or Internet transmission is completely secure, and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur.

In the event of a privacy breach, we will comply with our legal obligations, including with respect to notifying affected individuals, organizations, and/or regulators as required.

How We Retain Personal Information

We retain Personal Information only for as long as needed to carry out the purposes stated above or to otherwise meet legal requirements. For more information about our retention processes, please contact us at info@niagarastudentservices.com

Storage and Processing of Information in Canada

The Personal Information that we collect is processed and stored in Canada. It is subject to Canadian laws.

Personal Information of Minors

Some of the students to whom we provide the Services are minors. When we collect their Personal Information, we take additional steps to protect their privacy. For example, we notify their parents or legal guardians about ourinformation practices through this Privacy Policy. We also require that theirparents or legal guardians provide consent to NHISS to collect, use, disclose, andhandle their Personal Information in accordance with the terms of this Privacy Policy. Additionally, the information that we collect and use about minor students, and about all students, is limited to only what we need for the purpose of providing our Services. We also give parents various rights in respect of their minor children’s Personal Information, as outlined below.

Legal Rights

You have the right to request access to your (or your minor child’s) Personal Information, meaning that you may ask to receive a copy of the Personal Information we hold about you (or your minor child).

Under certain circumstances, you may also have the rights to:

• Request correction of the Personal Information that we hold about you (or your minor child). You may ask to have corrections made to any incomplete or inaccurate information we hold about you (or your minor child). We may need to verify the accuracy of the new information you provide to us.

• Request erasure of your (or your minor child’s) Personal Information. You may ask us to delete or remove your (or your minor child’s) Personal Information in the following situations: (a) there is no legitimate basis for us continuing to process the information, (b) you have successfully exercised your right to object to processing (see below), (c) we may have processed the information unlawfully, or (d) we are required to erase the information to comply with local law. For legal reasons, we may not always be able to comply with your request of erasure. If that is the case, we will inform you of the reasons why we cannot comply with your request.

• Object to processing of your (or your minor child’s) Personal Information. You may object where we are relying on a legitimate interest (or those of a third party) as the basis for processing the information, and you believe that our processing of the information violates your (or your minor child’s) fundamental rights and freedoms. You may also object where we are processing the information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process the information that override your (or your minor child’s) rights and freedoms.

• Request restriction of processing of your (or your minor child’s) Personal Information. You may ask us to suspend the processing of your (or your minor child’s) Personal Information in the following situations: (a) you want us to establish the accuracy of the information; (b) our use of the information is unlawful but you do not want us to erase it; (c) you need us to hold the information even if we no longer require it, because you need the information to establish, exercise or defend legal claims; or (d) you have objected to our use of the information but we need to verify whether we have overriding legitimate grounds to use it.

• Withdraw consent at any time where we are relying on consent to process your (or your minor child’s) Personal Information. If you withdraw your consent, this will not affect the lawfulness of any processing of the information that was carried out before you withdrew consent. If you withdraw consent, we may not be able to provide certain services to you (or your minor child). We will advise you if this is the case, at the time you withdraw your consent.

If you wish to exercise any of these rights, please contact us at info@niagarastudentservices.com.

You will not have to pay a fee to access your (or your minor child’s) Personal Information (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee, or we may refuse to comply with your request.

If you wish to exercise any of these rights, we may need to request specific information from you to help us confirm your identity and ensure your rights. This is a security measure to ensure that your (or your minor child’s) Personal Information is not disclosed to any person who is not authorized to receive it. We may also contact you to request additional information relating to your request.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes to our privacy practices. If we decide to make material changes to our Privacy Policy, we will notify our users by placing a notice on our website or by sending a notice to the e-mail address we have on file for each user. You should periodically check https://niagarastudentservices.com/ for updates.

Contacting Us, Challenging Compliance

If you have any questions or comments about this Privacy Policy or questions or complaints about how we or our service providers are handling your (or your minor child’s) Personal Information, or if you wish to access, update, and/or correct your (or your minor child’s) Personal Information, please contact us at info@niagarastudentservices.com or Niagara Homestay & International Student Services, 6 Pearl Ann Dr., St Catharines, ON, L2T 3B3.

You also have the option of contacting the appropriate Privacy Commissioner or supervisory authority in your jurisdiction.

• In Canada, you may contact https://www.priv.gc.ca/en/report-a-concern/file-a-formal-privacy complaint/file-a-complaint-about-a-business/ or one of the applicable provincial commissioners.

• In the United Kingdom, you may contact https://ico.org.uk/make-a-complaint/.

• A list of European Data Protection Supervisors is available at

https://edpb.europa.eu/about edpb/aboutedpb/members_en.

If you have any questions about this Privacy Policy or our information handling practices, please do not proceed with your application for our Services. Please contact us at info@niagarastudentservices.com.