Last Updated: 07/01/19
When we say “we”, “us”, “our” and “Smaller Earth” we are referring to Smaller Earth Group Limited which owns and operates all of the Smaller Earth brands, trademarks and websites.
When we say “you”, “your” and “customer” we are referring to either someone who has signed up for a Smaller Earth service or is visiting our websites or is using one of our applications.
Smaller Earth does not sell its customer data or mailing lists and will not share your Personal Data with any third party companies for the purposes of direct marketing unless you have explicitly given consent.
Our websites and brands:
When dealing with our website and apps there are three types of information we collect.
This is data that you voluntarily provide to us and is often information that we need in order for you to take part in a work and travel program, or that may be given to us when you request more information and/or contact us.
This helps us improve our websites and experiences and is often tracked automatically in the background such as your browser type, operating system or device type.
Cookies are small packets of data which are stored on your computer or mobile device. Cookies are used to make certain features work on our websites as well providing reporting data.
Personal Data is any piece of data that identifies or can be reasonably used to identify you as an individual. We collect Personal Data in a few different ways with the most common being:
When registering for any of our programs we will ask you for information such as your full name, email address, password, date of birth, address, postal code and country. During the application we will then ask you to voluntarily provide further information including, for example: home address, emergency contact details, profile photo, work history and references as well as personal details for an emergency contact (you are responsible to gain consent from this individual to share their personal details with us).
When requesting more information about a program, registering your interest or contacting us online we may ask you for information such as your full name, email address and contact no.
Sensitive Personal Data
Information such as criminal background may be considered “Sensitive Personal Data” under the Data Protection Act 1998. We collect this data in order to comply with the visa requirements set by different international governments.
Other Sensitive Personal Data such as religious background and medical history may be voluntarily given to us in order to help match you with an employer or placement.
If data has been aggregated or anonymised so it is no longer reasonably associated with an identifiable individual it is no longer classified as Personal Data. Smaller Earth may use this for any business purpose.
Lawful Basis for Processing Personal Data under GDPR
When registering for a Smaller Earth program we will rely on Contract as the lawful basis for processing your personal information. As a potential customer registering for a Smaller Earth program we will need to process your data in order to provide you with our program services.
When signing up to marketing communication or providing us with feedback related to a Smaller Earth program we will rely on Consent as the lawful basis for processing. You will be asked explicitly to provide us with consent for marketing communication at the point of registering for a Smaller Earth program.
When referring you to a 3rd party program provider that you may visit through a Smaller Earth website or app, Smaller Earth will rely on Legitimate Interest as our lawful basis for processing.
For more information about lawful basis of processing please visit the ICO website.
Lawful Basis for Processing - Criminal Data
Smaller Earth has a lawful basis under Article 6 of GDPR (i.e., contract, legitimate interest) to process data about criminal convictions or offences; the company also has legal authority to do so under Article 10 of GDPR based on data subject consent (Schedule 1, Part 3 under UK law). A comprehensive register of participant criminal convictions is not kept and any data related to criminal convictions or offences is anonymized when service is complete.
When visiting a Smaller Earth website or application we collect usage data, which is done automatically in the background. This includes:
Smaller Earth collect information about the devices accessing our websites and applications including: the type of device, device operating system, device settings, application IDs, unique device identifiers and crash reports. The exact information we collect varies depending on device and system settings.
When visiting our websites or apps our servers automatically record information in server logs. These logs may include information such as your Internet Protocol address, browser type and settings, referring and exit pages, landing pages, pages viewed, language preferences and date and time stamps.
When visiting our websites or apps we will receive data that will help us approximate your location - this helps us deliver the correct language and website to you. We may use the IP address from your browser or device to determine approximate location.
We use the information we collect in the following ways:
In all cases relating to Smaller Earth programs or services, Smaller Earth is the data Controller. In most cases your data Processor will be a Smaller Earth Affiliate based in your local country. Smaller Earth does not sell or rent Personal Data to unaffiliated third parties or companies for marketing purposes. We will only share your data with trusted third parties or affiliates including:
In order to provide our services to customers we use third party providers for areas such as infrastructure, email communication, payment gateways and flight bookings.
Smaller Earth Affiliates
Our Host Businesses & Program Providers
In order to provide our services of placement with Host Businesses or Program Providers around the world, such summer camps, resorts or volunteer programs, we will share required Personal Data with them. This is only for the purpose of placement at Host Businesses or Program Providers and will only be done with your consent when signing our Program Agreements. All Host Businesses and Program Providers have signed a Data Protection Agreement with Smaller Earth which ensures your Personal Data will be managed in accordance with GDPR.
In order to provide our services of cultural exchange programs around the world, we work with a range of Partners such as, Visa Sponsors and Insurance Providers. When necessary we will share required Personal Data with them. This is only for the purpose of delivering our cultural excahnge programs and will only be done with your consent when signing our Program Agreements. All Partners have signed a Data Protection Agreement with Smaller Earth which ensures your Personal Data will be managed in accordance with GDPR.
Safety, Legal and Law Enforcement
Smaller Earth may share your Personal Data in order to comply with safety, legal and law enforcement purposes.
Your Personal Data is only ever used for the purposes for which it was collected and will only be retained for as long as it is needed to fulfill contractual, financial and legal obligations.
Our programs are not directed to anyone younger than the age of 16. If you learn that anyone under 16 has submitted personal information to us, without consent, please contact us and we will delete the information accordingly.
We often display advertisements from third parties and other content that links to external 3rd party websites. We cannot control or be held responsible for 3rd party privacy policies or practise and the content they display. Please read their privacy policies when leaving our website to find out how they collect and process your information.
We take protecting our users information very seriously. Your account details, such as your password, protect your account so you should use a unique and strong password. Please keep your password to yourself and limit access to your computer and browser.
You have the right to:
Please make any request through your online Smaller Earth account, by hitting “unsubscribe” in marketing emails or by writing to:
Data Protection Officer, Smaller Earth, 4th Floor Atlantic Pavilion, Albert Dock, Liverpool L3 4AE OR firstname.lastname@example.org