Privacy Policy — Start Shining Limited
Privacy Policy — Start Shining Limited
Last updated: 11.09.10126
Note before publishing: This is a draft prepared to give you a solid, structured starting point. Please have it reviewed by a solicitor or a qualified data protection advisor before publishing — especially the sections on data sharing with partner universities and international transfers, since the exact wording needs to match what you actually do in practice.
1. Who we are
Start Shining Limited is a UK-based higher education recruitment agency, registered in England and Wales under Company No. 12298513. We help prospective students find and apply to university courses in the UK.
Contact details:
- Email: info@startshining.eu
- Phone: 07538 377368
- WhatsApp: 07459 030348
If you have any questions about this Privacy Policy or how we handle your personal data, please contact us using the details above.
2. What personal data we collect
Depending on how you interact with us, we may collect:
- Contact details: full name, email address, phone number
- Application information: educational qualifications, ID/passport details, Share Code (for right-to-study checks), CV, and other documents you submit as part of a course application
- Communication data: records of calls, emails, and WhatsApp messages between you and us
- Marketing engagement data: which emails you open or click, and which pages of our website you visit
- Technical data: IP address, browser type, and device information collected automatically when you visit our website
3. How we collect your data
We collect personal data when you:
- Submit an enquiry form through Facebook or Instagram (Meta Lead Ads)
- Fill in a form on our website (edu.startshining.eu)
- Contact us directly by phone, email, or WhatsApp
- Upload documents as part of a course application
- Book a call with us
4. How we use your data and our legal basis
| Purpose | Legal basis |
|---|---|
| Contacting you about course options you enquired about | Legitimate interest / steps taken at your request prior to entering into a service |
| Processing and submitting your university application | Performance of a contract / necessary to provide our service |
| Sending you marketing emails and WhatsApp messages about courses and opportunities | Consent (you can withdraw this at any time) |
| Verifying your right to study in the UK | Legal obligation / legitimate interest |
| Improving our services and understanding how our website is used | Legitimate interest |
5. Who we share your data with
We may share your personal data with:
- Partner universities (e.g. Solent University, London Metropolitan University) — only where necessary to process your course application
- Zoho Corporation — we use Zoho CRM, Zoho Marketing Automation, and Zoho Bookings to manage our customer relationships, communications, and scheduling. Zoho processes data on our behalf as a data processor.
- Meta Platforms (Facebook/Instagram) — where you submit an enquiry through a Meta Lead Ads form, Meta is involved in the initial collection of your data before it reaches us.
- WhatsApp / Meta Business — if we communicate with you via WhatsApp.
We do not sell your personal data to third parties.
6. International data transfers
Some of the service providers we use (such as Zoho and Meta) may process data outside the UK/EEA. Where this happens, we rely on appropriate safeguards such as Standard Contractual Clauses, or the provider's own adequacy arrangements, to ensure your data remains protected.
[Confirm with your Zoho account settings which data centre region your CRM/ZMA data is hosted in, and update this section accordingly.]
7. How long we keep your data
We keep your personal data only for as long as necessary to fulfil the purposes described in this policy — for example, for the duration of your application process and a reasonable period afterwards in case you re-engage with us, or as required by law. If you ask us to delete your data and we have no legal obligation to keep it, we will do so.
8. Cookies and tracking
Our website may use cookies and similar technologies to understand how visitors use the site and to support our marketing (for example, Meta Pixel or Google Analytics, if enabled).
You can control cookies through your browser settings.
9. Your rights
Under UK GDPR, you have the right to:
- Access the personal data we hold about you
- Ask us to correct inaccurate data
- Ask us to delete your data ("right to be forgotten")
- Restrict or object to how we process your data
- Request a copy of your data in a portable format
- Withdraw consent at any time (for marketing communications)
To exercise any of these rights, contact us at info@startshining.eu.
If you're not satisfied with how we've handled your data, you have the right to complain to the UK Information Commissioner's Office (ICO): https://ico.org.uk
10. Changes to this policy
We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated "Last updated" date.
