Privacy Policy

Last Updated: 10/02/2023

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Thank you for using Smaller Earth or visiting one of our websites/mobile apps.

Smaller Earth is subject to UK and EU GDPR (General Data Protection Regulation). This regulation ensures that companies handle your personal data with the utmost confidentiality and care. Our Privacy Policy is here to help you understand the way we use the data that you share with us along with your rights. The policy covers what data we collect and why, how we collect it, how long it is stored and how it is processed. It also explains who we will share your data with and our legal basis for handling your data.

In order to communicate with you and provide services, Smaller Earth will handle your personal data. If you have any questions or would like to exercise your data rights provided by the UK and EU General Data Protection Regulation such as data access, rectification and erasure please contact via the contact information in this policy.

Please pay attention to the fact that:

if you apply to any of the Smaller Earth programs at our partner offices (e.g. Camp Leaders, Camp Canada, Resort Leaders, Adventure China),
if you participate in events organized by Smaller Earth partner offices,
if you contract us to participate in Smaller Earth programs,

the Data Controller is always Smaller Earth Group Ltd.

For this reason, we ask you to contact us for all related data handling questions, regardless where you have signed your contract.

The Data Controller is Smaller Earth Group Limited, Address: Avenue Hq, 17 Mann Island, Liverpool, England, L3 1BP Company number: 06586570

If you apply to a Smaller Earth program we will ask for a range of personal information often including sensitive personal information. To keep this information safe we regularly train our employees and partners on data security and privacy. Our technology systems are protected through strong authentication methods and employees can only access data that is necessary to carry out their job role. All of our partners strictly use data only for the purposes we define and operate under strong contractual obligations regarding privacy and GDPR compatible data handling.

Your personal data is processed when:

you contact us
participate in our presentations
you enter into a contract with us
you complete a reference for a Smaller Earth participant
you are listed as an emergency contact for a Smaller Earth participant
you subscribe to an email newsletter
you visit our website and/or app
you visit an official Smaller Earth social media profile
you provide feedback and/or a customer review
you participate in a competition, giveaway or award
you are a hosting party, representatives of clients, host employer or partner of hosting organizations
you apply for a full time, part time or contract based position at Smaller Earth, including internships and work experience

This policy will explain why we process the data listed above, how we store the data and who it is shared with.

Your rights regarding your personal data

You can contact us to ask if we store or process any of your personal data, if so, you have a right to access, rectification and erasure. You can also object to the processing of your personal data and ask for a copy in electronic form. To read more about your rights please refer to EU and UK GDPR Article 12-21.

If you have any questions, requests or issues regarding data processing please contact our Data Protection Officer:

Andy Callender

Phone number: 1-866-803-7643

E-mail address: data@smallerearth.com

If you are a registered user, you can also initiate the data request and data deletion in your online profile via the settings section.

If you have an issue regarding your personal data we kindly ask you to contact us, and our team will do their utmost to solve your query.

If necessary, you can lodge a complaint at the relevant data protection authorities. Your local authority is:

ICO - Information Commissioner's Office - https://ico.org.uk

You can also initiate a legal process at your local Regional Court or at the Regional Court in the location of the Data Controller.

EU representative for data protection cases

The EU representative of Smaller Earth Group Limited for contact with authorities and other data protection related requests is:

Campleaders Hungary Kft.

1051 Budapest, Vigyázó Ferenc utca 4. 3/1. HUNGARY

Izabella Gyuricza

data@smallerearth.com

When you contact us - via email, live chat, phone, social media, in person, or any other form - we may process the following personal data: your name, e-mail address, gender, date of birth, phone number and Facebook ID (for Facebook based contact only). Furthermore, all the personal information you may share with us during the communication.

We use this data to contact you, answer any questions, requests and provide you further information. This data processing is our legitimate interest regarding contact handling. We delete the data from our CRM systems after 3 years of last interaction. Data in messaging platforms (e.g. email, Facebook, Whatsapp) stored indefinitely.

When you contact us on Facebook, we process your Facebook data jointly with Facebook Inc. In other cases, the data resides in the systems of our technical solution provider (webpage, e-mail, etc), who may have access to your data. Our local partner offices might actively process the data you send, when they handle your request.

We may organize webinars and in-person events to inform potential applicants about Smaller Earth programs or provide additional information to our contracted participants. During these events we will record the list of attending participants and at registration we may ask you to give us your:

name,
email address,
phone number,
date and place of birth,
name of your university or collage
date of event attended
name of event attended

We also may learn your

gender,
and signature.

If you change your mind, you can ask us to erase your data immediately or you can do this request later. If you ask us later, we will delete your data within 1 month of the request. If you complete a paper-based form at an event but do not contact us further we will store your data until the end of the travelling season.

During the season we may organize webinars on topics, such as job fairs, interviews, travel, pre-departure orientation and so on. In the case of online webinars we have access to the attendees email address and username. The providers of the software used for online webinars will store user activity logs. You can find the details of their data handling on the website of the software provider you use to connect to the online event.

Event data resides in the systems of our technical solution provider (website, e-mail, etc), who might have access to this data and also our local partner offices might actively process the information to provide the Smaller Earth services.

Recording of events

We may carry out photography and record videos of our public events, you will be informed if this is taking place and we will provide you with the option to not to be recorded, you can learn about this at the event location.

The purpose of these records is to document the event and to advertise the services we offer. Any photos and videos we captured may be published on our website, social media and other media. This is our legitimate interest regarding the advertisement of the company.

We store any photos and videos indefinitely, but you can always object against the usage or ask for the erasure of the data.

We may record our online webinar sessions. In such cases we will inform you of the recording in advance.

We store your data in our systems, which are operated and maintained by our technical solution provider. They might access the data occasionally (e.g. for troubleshooting). Our partner offices in the country you apply within will have access to the data.

If you enter into a contract with us (e.g. sign a Program Agreement) we will process your personal data in different ways.

The following section will cover how we handle your data in each of the situations below:

participation in a program
flight and travel arrangement
insurance
our 24h helpline number
risks regarding data sharing with countries outside EU/UK
program specific details

If you participate in a Smaller Earth program we are required to share some of your personal data with 3rd party partner organisations (e.g. camps, resorts and other employers). We also use this data for billing purposes.

The following information is either handled because we have legal obligation to do so (e.g. invoicing) or we have to process the data to provide you with contracted services.

Below is a list of common personal data we will process if you participate in a Smaller Earth program;

Contract related data processing:

Scoring and review written by and written about the hosting parties
The fact that you have applied to our program
Country of origin
Data regarding your criminal records
Destination country and address
Proof of student status
Photo
Pocket money details
Method of payment, amount and payment details
Interview report
Address, temporary address
Motivation details
Gender
Name
Shirt size
Preferred contact time
Contract data
References
Date and place of birth
Phone number
IP address in case of digital document signature
Passport data
Emergency contact name, relationship, contact details
Dietary preference
Other personal data you have shared with us during the interview or in writing

We handle the everyday or common data based on the contract between us. But some other data we process is classed as sensitive data, such as your medical history and criminal background. Before providing us with this data we will ask for your consent to process, store and share it with partner host organisations.

Please note that our partner host organisations require this information and in the lack of consent we will not be able to arrange your travel and participation in the program.

We may also ask about your religion and beliefs to provide a better match during our placement process. This is optional. You are not required to answer these questions and you can delete your answers at any time.

Third parties who will receive your data

We store your data in our systems, which are operated and maintained by our technical solution provider. Our technical solution provider may access the data occasionally in certain situations such as troubleshooting. Our partner offices in the country you apply from also have access to the data, to provide you the contracted services.

When you upload all of the required information, documents and we have verified them, your application status may change to “Ready to Hire”. At this stage, we share your data with the verified potential hosting parties, who are the employers and partners in the exchange program you are participating in.

To arrange different logistical aid, support, legal compliance and other service related needs in the country you visit, we may share your data with the regional Smaller Earth office.

When we send you updates, news, we do that with a third party notification provider. They store your name and mail address and the message itself. If you opt-in for SMS notification, we also engage a third party to provide this, who stores your phone number, name and the content of the message.

When you pay for the services, we involve third parties in the payment process, who receive the payment details: your name, bank account number or credit card number, username, the fact of the payment itself, the amount and date of transfer. You can learn about their data processing in their own privacy policy, which is reachable on the payment related pages of the chosen payment method.

We store your data for the following time:

We process and store your data for a period of time based on our legal obligation as following:

If you registered on our website, but did not pay any fees and did not sign the program agreement: we store paper documents until the end of the travelling season; electronic information is stored for 3 years.
Payment related data is stored for 7 years.
Contract related data and documents are stored for 5 years after acceptance to the program.

For flight included programs the bookings are handled by a Smaller Earth partner office (Campleaders Hungary Kft.) using a Global Distribution Booking System (GDS). We record the following information to the flight booking system:

Name
Date and place of birth
Country of origin
Physical address during the program
Destination
Frequent traveler card details
Passport data
Flight itinerary and schedule
Food allergy
Transfer related information

With your consent, data may be shared with countries outside of the EU/UK. Any countries who receive your data will be specifically detailed in the program description further on in this policy.

If you fly to the USA, we register your data in the APIS system (Advance Passenger Information System) of the US Customs and Border Protection. It is a mandatory data handover, involving the following:

first name, middle, last name
gender
phone
email
nationality
passport number
passport issue country
passport expiry date
date of birth
destination country
street, zip, city, state

In case we organize any kind of transfer beside the flight itself or we organize accommodation for temporary stay, we share your contact details with these service providers.

You might need to use the insurance we provide for you as part of your program. In such case, we share the following data with the insurance broker:

Your name
Date and place of birth
The country where you live
Your program destination
Email
Placement and travel dates

If you travel with us, you might call our helpline after office hours. If you do so, the call may be received by a third party company who help us to prioritize support cases. They record and share with us the data that is needed to handle your issue:

Your name
Date and time of the call
Date and place of birth
E-mail address
Phone number
The details of next of kin/emergency contact person
The facts and subject of the call
Health data
Crime related data

We handle this information based on our contract with you. The call is not recorded, the information you share is captured in written form, which we use to resolve any issues and provide support.

We store this information until the case is closed, considering the potential legal consequences and settlement times. We may need to share the details of the incident with the partner office who you entered into contract with or your visa sponsor, but only to resolve an issue or as legal obligations dictate.

We store the helpline call data in our systems, which are operated by our technical solution provider, who might access the data occasionally (e.g. for troubleshooting).

You should be aware that data protection and privacy regulations of countries outside of the EU and UK often operate differently. Our partners handle your data with utmost care and confidentiality, but the hosting country might inspect and survey the visitors based on their own right.

The crime preventing, the anti-immigration or anti-terrorism practices of the hosting countries are different at each destination and the average person might have limited information about the details. These practices often differ from the norms you experience in the EU or UK. For example, hosting countries may check your social media account, they may ask for access to your electronic devices when you enter the country or they may carry out other privacy invasive actions.

If you have any particular concerns regarding the privacy practices of a hosting country please research the relevant information before applying to a Smaller Earth program. This information can usually be found on official government websites.

Programs in the United States of America

If you participate in a US based program we will share your data with third parties in the United States of America: visa sponsors who will verify your data, potential employers, authorities related to the visa process.