91. (“91”, “we”, “us”) values your trust and we want you to feel confident in how we handle your Personal Information.
In order to provide products and services (“Services”) to our users and conduct our day-to-day business operations, including empowering students to explore and enroll in schools around the world, providing them with global educational opportunities, and providing additional services and products to enhance the international student journey, we collect, use, and share Personal Information.
“Personal Information” is any information that directly identifies you, such as your name and email address, or that indirectly identifies you, for example a phone number or device identifier.
The Personal Information we collect and process about you varies depending on our relationship with you. We may have a direct relationship with you because you have set up an account or consented to receive marketing communications from us, or we may have an indirect relationship with you via your relationship with one of our partners or customers, where you may be their employee or their customer.
We take our privacy, data protection, and legal obligations very seriously. We are committed to being transparent with you about how we use your Personal Information. This Privacy Policy aims to describe our privacy practices in a clear, accessible, and easy to understand way and to let you know how you can exercise your rights in relation to your data.
This Privacy Policy takes effect on the date listed above. By using 91’s Services or website after that date, you agree to the updated Policy.
Everything we do with your information serves a purpose, such as making your educational journey easier or recommending programs that match your preferences. Throughout this policy, we will cover:
We encourage you to read this Privacy Policy carefully so you know how we manage and protect your information. If you have any questions or concerns, please reach out to us at the contact details provided below.
We collect Personal Information from you directly, from agents and third parties, and automatically through our Services and websites.
Information you provide:
Information we collect automatically:
Information collected from third parties:
We only collect this information when necessary and always with your consent.
The Personal Information we collect about you depends on your relationship with us and the purposes for which we process that personal data. The following describes the types of purposes for which we collected your Personal Information:
Account management:
Creating and managing accounts, including verification of the identity of our users for Know-Your-Customer (KYC) or identity verification purposes.
Business operations:
Carrying out our core business operations, such as application processing and submission, account administration, accounting, auditing and compliance, business analytics, forecasting, consolidated management and reporting, product strategy and revenue planning. We also provide additional supporting services such as language tests, visa processing assistance, student loan applications, GICs, foreign exchange, housing, and additional banking and financial services, and collect and process Personal Information to enable us to provide these services.
Personalization:
We use the details you share—like your educational background and interests to enhance your experience by creating and managing your personalized account. By understanding your unique profile, we can match you with schools and programs that align with your qualifications and interests. This allows us to provide thoughtful and tailored recommendations as you navigate our website.
We also use your information to enhance your experience by monitoring and improving our online support services. By analyzing how you and others interact with our Services, we can continuously refine and improve the way we help students connect with educational opportunities.
Safety & security:
Your information helps us verify your identity, detect fraudulent activity, and prevent, detect, and investigate security incidents. Such information assists us in maintaining the security of our platform, Services, websites and accounts, and protecting the health and safety of our employees, visitors and our properties.
Measure & enhance:
We analyze data to understand what works, identify improvements, and refine features based on user feedback and behavior. Providing, optimizing and maintaining our Services and platforms, including debugging and troubleshooting.
Facilitating purchases:
We use your information to assist, where applicable, with completing transactions, processing payments, and communicating with you about purchase.
Communicate with you:
We send updates, answer questions, respond to complaints, share promotions or administer contests if you’ve opted in. The information we collect helps us to improve customer service quality and provide customer support, including responding to your requests and communicating with you about your account and use of the Services.
Research & development:
Where allowed by law and supported by consent, we may use your information for surveys, research, and developing new features or Services.
Cookies and tracking:
Understanding how customers are using our platform and Services by deploying cookies and other tracking technologies in accordance with your online settings, and understanding how visitors navigate our websites, and tracking and optimizing the performance of our advertising activities. For more information, please check our cookies policy available at /cookies.
Training and Services improvement:
Developing or improving our Services, including anonymizing, de-identifying, pseudonymizing and aggregating personal data for this purpose. We may use Personal Information to train and improve our AI models in accordance with applicable laws. 91 will take steps to ensure that the data is relevant and accurate.
Compliance:
Complying with legal and regulatory obligations. Protecting the rights and freedoms of individuals, meeting legal or regulatory obligations, including complying with valid court orders, disclosure requests, subpoenas, and other appropriate legal mechanisms and preventing, detecting, or investigating abuse or misuse of our platform or Services.
Employment opportunities:
Identifying potential job candidates, and conducting interviews, background checks, and screening.
Based on your informed consent:
As otherwise authorized by you through your use and configuration of features in the Services.
We disclose Personal Information to third parties in limited circumstances in order to provide the Services and to otherwise run our business. Below are the different scenarios under which we may disclose your data to third parties:
Sharing directly with educational institutions:
Helping you achieve your educational goals requires collaboration with schools and other partners. With your consent, we share application materials, supporting documents, and relevant information with schools you’re interested in—this is how we help facilitate your entry into the program of your choice.
Supporting services:
With your consent, we help you access additional services that support your educational journey. For example, if you opt to have us assist you with obtaining a student loan, we will share your information with our financial partners to ensure they can adequately provide you their services, or if you apply for accommodation, we will share your relevant information with accommodation providers for this purpose.
Third party service providers:
To provide you with a secure and effective platform, we work with a number of partners and service providers to help carry out our Services. This includes companies that process your payment safely, host our data, protect against fraud, and more.
Research and innovation:
We’re committed to advancing education through research and innovation. We may conduct internal research to improve our Services, and with consent, share our findings with external partners for research and development. We generally use aggregated, anonymized and de-identified derived by 91 from your Personal Information for this purpose, and this is generally not considered Personal Information under data protection law as this data does not directly or indirectly reveal your identity. We may use and disclose de-identified, anonymized or aggregated data to third parties.
Legal requirements and business changes:
There are times when we need to share information for legal or operational reasons—like complying with laws, protecting our rights, or ensuring user safety. If 91 undergoes changes like a merger or acquisition, your information may transfer to the new organization, which will continue to protect your information.
Your choice regarding marketing communications:
If you prefer that we don’t use your information to market to you, or share it with third parties for marketing purposes, you have the following options:
We respect your choice and will update your preferences promptly. We do not sell your Personal Information to anyone.
How long we retain your Personal Information:
We keep your Personal Information only for as long as it’s needed to provide our Services to you or for other valid purposes. The duration depends on factors such as the risk of harm from unauthorized use or exposure, and the amount and type of data we have.
Typically, we retain your Personal Information while you’re involved in the program you applied to, or for up to a year following our last contact with you. We may keep certain data longer for the following reasons:
Where we store your Personal Information:
We store your information on our service providers cloud servers, which are predominantly located in the USA, except for the ApplyProof application, which is hosted entirely in Canada. The laws in jurisdictions outside of Canada and authorities in those jurisdictions may access your information in accordance with their local laws.
Your privacy and security are fundamental to everything we do. To protect your Personal Information against loss, unauthorized use, access or disclosure, 91 uses reasonable and appropriate security measures designed to protect the security of your Personal Information both online and offline. These measures vary based on the sensitivity of the personal data we collect, process and store and the current state of technology. While we take all possible steps to protect your information, it’s important to understand that no online service can guarantee absolute security. However, we continuously work to strengthen our protections and respond quickly to new security challenges.
Partner security vetting:
We carefully evaluate all our partners and service providers before sharing any information with them. Each partner or service provider must:
It is important to note however that we are not responsible for third-party privacy practices. We encourage you to review their privacy policies.
Security and incident response:
Our team monitors our systems and responds immediately to any potential issues. If we suspect or confirm unauthorized access, use, modification, or disclosure of your Personal Information, we promptly evaluate and respond to the incident. If a security breach occurs, we will notify you without undue delay and provide timely updates as more information becomes available, in accordance with legal requirements.
Cookies and similar technologies:
We use cookies and similar technologies to track information about your use of our website and Services to enhance your experience. To learn more about how 91 uses cookies and how you can manage your preferences, visit /cookies.
Different privacy legislations around the world (such as the GDPR and the CCPA) provide you with specific rights regarding how organizations handle your information. We’ve consolidated these rights below to help you understand how you can control your information when using our Services:
Accessing your Personal Information:
You can view and update your data anytime by logging into your account and visiting your profile. You can request information about how and why we collect, use, share, and process your Personal Information. For additional requests or corrections (such as requesting a copy of your information or to discuss how we protect your information), contact us as indicated below. We may need to verify your identity for certain requests.
Correcting, rectifying, or updating your Personal Information:
If you have an account, log into “My Account” to update your information. If you’re not a registered customer or your data was provided by a third party, you can still request updates by contacting us via the methods below. If you require assistance to correct or update your Personal Information, please contact us using the details below. If we have shared this data with third parties, we will, where possible, inform them of the correction.
Data deletion (“right to be forgotten”):
You can ask us to delete your Personal Information at no cost in certain circumstances. Such requests depend on our legal position and any ongoing financial or application processes. If we can fulfill your request, only Personal Information is erased; non-Personal Information may be retained. We will inform relevant third parties of your request.
Restricting our processing of Personal Information:
You may request that we limit how we use your data, though doing so might affect the Services we can provide. We will inform relevant third parties unless restriction is impossible or disproportionate.
Human review of automated decisions:
You can request human review of certain automated decisions that significantly affect you, where required by law.
Data portability:
Where processing is based on your consent or contract, and carried out by automated means, you may request a structured, commonly used, and machine-reasonable copy of your Personal Information for reuse somewhere.
Withdrawing your consent:
You have the right to withdraw your consent at any time. When you withdraw consent, we’ll begin a process to stop processing your information, but this may not be immediate. If you have active applications or ongoing services, we’ll need time to connect with educational institutions and partners. Some information may need to be retained for legal requirements and certain services may be unavailable. We’ll keep you informed throughout the process and work to complete your request as soon as possible while meeting our legal and contractual obligations.
Contacting privacy regulator:
If you have a specific complaint, you can file a complaint with a relevant data protection authority (see below):
Important notes on your rights: These rights are not absolute. We may refuse certain requests if complying would prevent us from fulfilling our contractual obligations or providing our Services. We’ll always let you know what we can and can’t do.
Automated decision-making occurs when an electronic system uses data, including potentially your Personal Information to make a decision about you, without human involvement. 91 uses automated decision-making leveraging a variety of information from records we collect or obtain from third party vendors. An example would be scanning the document uploaded as a passport to make sure it is the correct document, that it is the right file format, and that it is legible.
We may update this Privacy Policy from time to time to address legal, technical or business development requirements or make clarifications. When we change this notice, the most current version will be available at /privacy-policy with the date indicating when it was last updated. We won’t materially reduce your rights under this Privacy Policy without alerting you first.
Contact Our data privacy office if:
Email: dpo@91.com
Ѳ:
91.
101 Frederick Street, Suite 600
Kitchener, ON N2H 6R3, Canada T
Toll-Free: 1-844-972-7759
By using our websites and Services, you consent to the policies and practices described herein.