Privacy Policy bic_2021_admn 2021.08.09.

Privacy Agreement

This Privacy Notice explains how BIC International College Kft. processes personal data in connection with its website, admissions services, adult education activities, foundation programmes, student administration, marketing communication, and related services.

1. Data Controller

The data controller is:

Company name: BIC International College Kft.
Registered seat: 1063 Budapest, Szinyei Merse Utca 10. as 2
Mailing address: 1106 Budapest, Kerepesi út 87., CEU Conference and Residence Center
Office address and place of tuition: 1106 Budapest, Kerepesi út 87., CEU Conference and Residence Center
Website: https://budapestcollege.hu
Public application platform: https://apply.budapestcollege.hu
Email: info@budapestcollege.hu
Phone: +36702433669
Company registration number: 01-09-387699
Registering authority: Fővárosi Törvényszék Cégbírósága
VAT number: 27188103-2-42
Adult education registration number: B/2021/001820
Adult education permit/licence number: E/2022/000126

Questions concerning data protection may be sent to: info@budapestcollege.hu.

2. Scope of this Privacy Notice

This Privacy Notice applies to the processing of personal data in relation to:

* visits to the website budapestcollege.hu;
* the use of the public application platform apply.budapestcollege.hu;
* enquiries and communication with prospective students, applicants, students, alumni, partners and other contacts;
* admissions and student selection processes;
* adult education activities, including foundation programmes and FAR reporting;
* contracts with students and participants;
* tuition, application fee and service fee administration;
* newsletters and marketing communication;
* online advertising, analytics, cookies, tags and embedded third-party content;
* communication through email, WhatsApp, Messenger, Instagram direct messages and similar communication channels when initiated by the data subject.

This Privacy Notice does not replace the privacy notices of third-party platforms used by BIC International College Kft., such as DreamApply, Mailchimp, Keystone Academic Solutions, Meta, Google, Flywire, or other independent service providers. Where these providers act as independent data controllers, their own privacy policies also apply.

3. General Principles of Data Processing

BIC International College Kft. processes personal data lawfully, fairly and transparently. Personal data is collected for specified, explicit and legitimate purposes and is not processed in a way incompatible with those purposes.

BIC International College Kft. processes only data that is adequate, relevant and necessary for the given purpose. The company takes reasonable steps to keep personal data accurate and up to date and stores personal data only for as long as necessary or legally required.

BIC International College Kft. applies appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, loss, destruction or other unlawful processing.

4. Categories of Data Subjects

BIC International College Kft. may process personal data relating to the following categories of persons:

* website visitors;
* prospective students and enquirers;
* applicants;
* admitted students;
* participants in adult education programmes;
* alumni;
* newsletter subscribers;
* representatives of partner agencies and partner institutions;
* persons contacting BIC International College Kft. through email, phone, WhatsApp, Messenger, Instagram or other communication channels;
* persons appearing in professional, administrative or payment-related communication.

5. Main Processing Activities

 5.1 Website visits and technical operation of the website

Purpose of processing:
To operate, secure, maintain and improve the website, prevent abuse, troubleshoot technical issues, and ensure the proper display and functioning of the website.

Categories of personal data:
IP address, browser type and version, device information, operating system, access time, visited pages, referral source, approximate location derived from technical data, technical identifiers, server log data, and cookie consent settings.

Legal basis:
Legitimate interest of BIC International College Kft. in operating and securing its website. Where cookies or similar technologies are not strictly necessary, the legal basis is the data subject’s consent.

Retention period:
Server logs are retained for [0 days, unless longer retention is necessary for investigating abuse, security incidents, legal claims or technical errors. Cookie consent records are retained for 24 months, or until the consent is renewed or withdrawn.

5.2 Cookies, analytics, marketing tags and embedded content

BIC International College Kft. uses cookies and similar technologies on its website. Cookies may be placed by BIC International College Kft. or by third-party providers.

The website may use the following categories of cookies and similar technologies:

Strictly necessary cookies:
These are required for the technical operation of the website, security, consent management and basic website functions. These cookies do not require prior consent.

Analytics/statistics cookies:
These help BIC International College Kft. understand how visitors use the website, which pages are visited, and how the website performs. The website uses Google Analytics 4 and may use other analytics tools.

Marketing/advertising cookies and tags:
These are used for advertising measurement, conversion tracking, remarketing and campaign optimisation. The website uses Google Ads, Google Tag Manager, Google Ads Conversion Linker and Meta Pixel.

Embedded third-party content:
The website may contain embedded YouTube videos and similar third-party content. Such embedded content may place cookies or use similar technologies for video playback, analytics, personalisation, security, feature testing and advertising-related measurement.

Consent:
Non-essential cookies, analytics cookies, marketing cookies, remarketing tags and embedded third-party tracking technologies are used only with the visitor’s consent, managed through the CookieYes consent management platform.

Visitors can change or withdraw cookie consent at any time through the cookie settings available on the website.

More detailed information about cookies, cookie categories, providers, purposes and retention periods is available in the Cookie Policy / cookie settings panel.

5.3 Enquiries and communication

Purpose of processing:
To respond to enquiries, provide information about programmes, admissions, tuition, services, student life, events and related matters, and maintain communication with prospective students, applicants, students, partners and other contacts.

Categories of personal data:
Name, email address, phone number, country, nationality, programme of interest, message content, communication history, source of enquiry, and any other personal data voluntarily provided by the person contacting BIC International College Kft.

Communication may take place through email, phone, WhatsApp, Messenger, Instagram direct messages or other channels, depending on how the person contacts BIC International College Kft.

Legal basis:
Taking steps at the request of the data subject prior to entering into a contract, where the enquiry concerns application, admission or training services.
Legitimate interest of BIC International College Kft. in responding to enquiries and maintaining professional communication.
Consent, where the communication concerns newsletter subscription or optional marketing communication.

Retention period:
General enquiries are retained for 5 years after the last meaningful interaction, unless the person becomes an applicant, student, contractual partner or participant in adult education, in which case the relevant retention period applies.

5.4 Leads received from education portals and partner platforms

BIC International College Kft. may receive prospective student leads from third-party education portals, including Keystone Academic Solutions platforms such as educations.com, bachelorstudies.com and related websites.

Purpose of processing:
To contact prospective students who expressed interest in BIC International College Kft., its programmes, partner universities or related study opportunities.

Categories of personal data:
Name, email address, phone number, country, nationality, programme interest, study level, message or enquiry content, source platform, consent status where provided by the source platform, and communication history.

Legal basis:
Consent, where the prospective student consented to being contacted for study-related information through the source platform.
Legitimate interest, where BIC International College Kft. receives a relevant enquiry and responds in a limited, expected and proportionate manner.

Source of data:
The data is received from the education portal or platform where the prospective student submitted the enquiry. The privacy notice and consent mechanism of the source platform may also apply.

Retention period:
Lead data is retained for 2 years after the last meaningful interaction, unless the person becomes an applicant or student, or unless a longer retention period is required for legal, contractual or administrative reasons.

 5.5 Newsletter and direct marketing communication

BIC International College Kft. may send newsletters and study-related marketing communication to subscribers, prospective students, applicants and other contacts where legally permitted.

Purpose of processing:
To send newsletters, programme updates, admissions information, study opportunities, events, deadlines, reminders, and other marketing or informational messages related to BIC International College Kft. and its services.

Categories of personal data:
Name, email address, subscription source, consent status, signup date, communication preferences, email engagement data, opens, clicks, bounces, unsubscribes, and related technical data.

Service provider:
BIC International College Kft. uses Mailchimp for newsletter and email marketing management. Data may be transferred to or accessed by Mailchimp according to Mailchimp’s applicable data processing and privacy terms.

Legal basis:
Consent for newsletter subscription and marketing communication where required.
Legitimate interest for limited follow-up communication to persons who have made a relevant enquiry or application, provided that the communication is related to the original enquiry and the person has an easy possibility to object or unsubscribe.

Automated list management:
BIC International College Kft. uses automation tools, including Zapier, to transfer certain lead and applicant data between systems, including DreamApply and Mailchimp.

Unsubscribing:
Each newsletter or marketing email contains an unsubscribe option. Data subjects may also request deletion or withdrawal of consent by contacting info@budapestcollege.hu.

Retention period:
Newsletter subscription data is retained until the data subject unsubscribes or withdraws consent. After unsubscribe, limited suppression data may be retained to ensure that the person is not contacted again by mistake. Inactive contacts may be periodically deleted or archived according to internal list hygiene rules.

 5.6 Application and admissions process

Applications are submitted through the public application platform available at apply.budapestcollege.hu. The application platform is operated using DreamApply.

Purpose of processing:
To manage applications, assess eligibility, organise interviews and admission steps, communicate with applicants, prepare application packages, forward application materials to the selected university or faculty where appropriate, and support the admissions process.

Categories of personal data:
Name, email address, phone number, date of birth, place of birth, mother’s name where required, gender, nationality, citizenship, country of residence, address, passport or ID data, previous education data, diplomas, transcripts, CV, motivation letter, language certificate where required, optional photo, recommendation letter for master-level applicants, documents proving professional competence where relevant, design portfolio where required by the selected programme, selected programme, selected university or faculty, interview notes, admission decision-related information, payment status and communication history.

BIC International College Kft. does not intentionally collect special categories of personal data, such as health data, ethnic origin, religion or political opinions, as part of the general application process. Applicants are requested not to submit such data unless specifically required by law or by the relevant university process.

Legal basis:
Taking steps at the request of the applicant prior to entering into a contract.
Performance of a contract, where the applicant becomes a student or participant.
Legitimate interest of BIC International College Kft. in assessing applications, preventing fraud, documenting admissions decisions and maintaining quality control.
Legal obligation, where processing is required by applicable education, adult education, accounting, tax or other legal rules.

Recipients:
Applicant data may be shared with the university, faculty or institutional partner selected by the applicant, where this is necessary for the admissions process. Applicant data may also be processed by DreamApply as the application platform provider.

BIC International College Kft. generally does not handle visa applications on behalf of students. If an embassy or competent authority lawfully requests confirmation or a list of applicants, BIC International College Kft. may provide limited necessary information, such as applicant names, where legally justified.

Retention period:
Applicant data for persons who do not enrol is retained for 5 years after the end of the admissions cycle or last meaningful interaction, unless a longer period is necessary for legal claims, fraud prevention, complaint handling, audit, or legal obligations.
Applicant data for persons who enrol is retained according to the retention periods applicable to student administration, adult education documentation, accounting and legal obligations.

5.7 Adult education administration and FAR reporting

BIC International College Kft. conducts adult education activities, including foundation programmes, under its adult education registration and permit/licence.

Purpose of processing:
To organise and deliver adult education programmes, conclude adult education contracts, maintain participant records, document attendance and performance, issue certificates or confirmations where applicable, comply with adult education documentation obligations, and complete required FAR reporting.

Categories of personal data:
Participant name, natural personal identification data, contact details, education data, programme details, adult education contract data, training start and end dates, training hours, attendance data, completion data, fee-related data, cost bearer where applicable, and any other data required by adult education legislation or FAR reporting.

Legal basis:
Legal obligation of BIC International College Kft. under adult education legislation.
Performance of contract with the participant.
Legitimate interest in documenting training delivery, quality assurance, audit readiness and legal claims.

Recipients:
Personal data may be reported to the adult education data reporting system, FAR, and may be made available to competent authorities during inspections or audits where required by law.

Retention period:
Adult education documentation is retained for the legally required retention period. Unless a different mandatory period applies, BIC International College Kft. retains adult education records for 8 years. This retention period must be confirmed against the currently applicable adult education legislation and internal compliance rules before publication.

5.8 Student administration and training delivery

Purpose of processing:
To provide training and related services, manage student records, organise classes, monitor attendance, communicate academic and administrative information, issue documents, manage payments and maintain records related to the student relationship.

Categories of personal data:
Name, contact details, personal identification data, nationality, citizenship, residence data, programme, class/group, attendance, academic progress, documents submitted during admission, contract data, payment-related data, communication history, and data necessary for the delivery and documentation of training.

Legal basis:
Performance of contract.
Legal obligation.
Legitimate interest in the proper organisation, quality assurance and documentation of education services.

Retention period:
Student administration data is retained for the period required by adult education, accounting, tax and other applicable legal obligations. Where no specific legal retention period applies, data is retained for 8 years for the establishment, exercise or defence of legal claims.

5.9 Payments and financial administration

Purpose of processing:
To process application fees, visa assistance fees, foundation programme tuition fees where payable to BIC International College Kft., issue invoices, reconcile payments, manage refunds, and comply with tax and accounting obligations.

Categories of personal data:
Name, contact details, invoice data, payer data, payment amount, payment status, transaction references, programme/service purchased, and related communication.

Payment service provider:
BIC International College Kft. may use Flywire for payment processing. Where payment is made through Flywire, Flywire’s own terms and privacy policy may also apply.

Legal basis:
Performance of contract.
Legal obligation for accounting and tax compliance.
Legitimate interest in payment administration, fraud prevention and legal claim handling.

Retention period:
Accounting and invoicing data is retained for the period required by Hungarian accounting and tax laws.

5.10 Advertising, remarketing and conversion measurement

BIC International College Kft. uses online advertising services to promote its programmes and services.

Purpose of processing:
To measure advertising performance, optimise campaigns, measure conversions, create and manage remarketing audiences, and contact prospective students who have started but not completed certain steps in the application or payment process.

Tools and providers:
Google Ads, Google Tag Manager, Google Ads Conversion Linker, Meta Pixel, Meta advertising tools, Mailchimp and Zapier-based automations.

Categories of personal data:
Cookie identifiers, device identifiers, IP address, browsing behaviour on the website, ad interaction data, conversion events, application/payment funnel status, email address or other contact identifiers where used for audience creation or automation, and related technical data.

Legal basis:
Consent for marketing cookies, remarketing pixels and similar tracking technologies.
Consent or legitimate interest for limited follow-up communication in relation to an application or service request, depending on the specific communication and source of contact.

Important information about audience creation:
BIC International College Kft. may use automated segmentation or audience creation for persons who have applied but have not completed payment or another admissions-related step. Where contact lists or audience data are transferred to advertising platforms, this is done only where there is an appropriate legal basis and in accordance with the settings and data processing terms of the relevant provider.

Retention period:
Marketing cookie and advertising identifier retention depends on the relevant provider and cookie settings. Contact-based marketing audience data is retained only as long as necessary for the specific campaign or audience purpose and is periodically reviewed.

5.11 Communication through WhatsApp, Messenger, Instagram and similar platforms

Data subjects may contact BIC International College Kft. through WhatsApp, Messenger, Instagram direct messages or similar platforms.

Purpose of processing:
To respond to messages, provide information, support admissions-related communication and maintain a record of relevant communication.

Categories of personal data:
Profile name, account identifier, message content, contact details voluntarily provided, attachments voluntarily sent, timestamp and communication history.

Legal basis:
Taking steps at the request of the data subject prior to entering into a contract.
Legitimate interest in responding to communication and documenting relevant admissions or student administration matters.

Third-party platforms:
The providers of these communication platforms may act as independent data controllers. Their own privacy policies also apply.

Retention period:
Communication data is retained for 2 years after the last meaningful interaction, unless it becomes part of an applicant or student record or is required for legal, contractual or administrative reasons.

6. Data Processors and Recipients

BIC International College Kft. may use the following categories of processors and recipients:

* website hosting provider: Magyar Hosting Kft.;
* website development and maintenance providers, where applicable;
* DreamApply as application platform provider;
* Mailchimp as newsletter and email marketing provider;
* Zapier as automation provider;
* Google services, including Google Analytics, Google Tag Manager, Google Ads and Google Drive;
* Meta advertising services;
* CookieYes as cookie consent management provider;
* Flywire as payment service provider, where applicable;
* pCloud and other cloud storage providers used for business administration;
* email service providers and IT service providers;
* accounting, invoicing, tax, legal and audit service providers;
* partner universities, faculties and institutional partners selected by the applicant;
* competent authorities, including adult education authorities and FAR, where required by law;
* embassies or competent authorities, where a lawful request requires limited confirmation of applicant-related information.

BIC International College Kft. shares personal data only where necessary for the relevant purpose, where required by law, or where the data subject has consented.

7. International Data Transfers

Some service providers used by BIC International College Kft. may process personal data outside the European Economic Area. This may include providers such as Mailchimp, Google, Meta, Zapier, DreamApply, Flywire or other technology providers, depending on their infrastructure and service terms.

Where personal data is transferred outside the European Economic Area, BIC International College Kft. relies on appropriate safeguards required by GDPR, such as adequacy decisions, Standard Contractual Clauses, data processing agreements, or other lawful transfer mechanisms provided by the relevant service provider.

8. Data Security

BIC International College Kft. applies appropriate technical and organisational measures to protect personal data, including access control, password protection, role-based access where available, secure storage, data minimisation, staff awareness, and restricted access to applicant and student documents.

Access to personal data is limited to persons who need the data for admissions, student administration, adult education administration, marketing, accounting, IT support or management purposes.

BIC International College Kft. expects its processors and service providers to apply appropriate data security measures under their contractual and legal obligations.

9. Rights of Data Subjects

Data subjects have the following rights under GDPR, subject to the conditions and limitations set out in applicable law:

* right to information about data processing;
* right of access to personal data;
* right to rectification of inaccurate or incomplete data;
* right to erasure;
* right to restriction of processing;
* right to object to processing based on legitimate interest;
* right to data portability, where applicable;
* right to withdraw consent at any time, where processing is based on consent;
* right to lodge a complaint with a supervisory authority;
* right to seek judicial remedy.

Requests may be sent to: info@budapestcollege.hu

BIC International College Kft. responds to requests within one month. This period may be extended by two further months where necessary, taking into account the complexity and number of requests. BIC International College Kft. may request information necessary to identify the data subject before fulfilling a request.

Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

10. Complaint and Legal Remedy

If a data subject believes that their personal data has been processed unlawfully, they may contact BIC International College Kft. first at: info@budapestcollege.hu

Data subjects may also lodge a complaint with the Hungarian supervisory authority:

Nemzeti Adatvédelmi és Információszabadság Hatóság

Address: 1055 Budapest, Falk Miksa utca 9-11.
Postal address: 1363 Budapest, Pf. 9.
Website: https://www.naih.hu
Email: ugyfelszolgalat@naih.hu
Phone: +36 1 391 1400

Data subjects may also seek judicial remedy before the competent court.

11. Changes to this Privacy Notice

BIC International College Kft. may update this Privacy Notice from time to time to reflect changes in legal requirements, services, data processing activities, technology providers or internal procedures.

The current version of the Privacy Notice is published on budapestcollege.hu.