Privacy Policy

Studendly is operated by Shirah Technologies Inc. ("Shirah", "we", "our", and "us"), a company incorporated in Canada. Shirah recognizes the importance of protecting the privacy and the rights of individuals in relation to their personal information. The purpose of this privacy policy ("Privacy Policy") is to inform you about our privacy practices on Studendly, including how we collect, use and disclose your Personal Information.

This Privacy Policy applies to the Studendly website at https://studendly.shirah.co/ and the Studendly platform, including all accounts, tools and features offered through it (collectively, the "Platform"). It applies to all of our operations in Canada or operations in connection with Canada.

Studendly is a platform for students applying to study abroad. Students search programs, build one profile, apply to multiple institutions, and work with an assigned advisor or a recruitment partner. Shirah operates the Platform. Shirah is not an educational institution, does not make admission decisions, and does not decide any visa or study permit application.

This Privacy Policy governs the Platform only. Shirah operates other products, each with its own privacy policy, and its corporate website at https://shirah.co/ has its own. Nothing in this Privacy Policy applies to those.

This section comes first because it changes who we are dealing with, and when.

Anyone may create an account and search for programs. To do that we collect only a name, an email address and a password. We ask for nothing else, and no application is made and no document is required at that stage.

Before an application is submitted to an institution, before academic, identity or financial documents are uploaded to a profile, and before any payment is made, we ask for the student's date of birth. Where the student has not reached the age of majority in their jurisdiction of residence, we require the student's parent or legal guardian to be identified, to be given this Privacy Policy and our Terms and Conditions of Use, and to consent to the collection, use and disclosure of the student's personal information before any of those things can happen.

We ask at that point rather than at registration because that is the point at which sensitive information starts to be collected and shared. Searching for a program does not require it.

A parent or legal guardian who has given consent may exercise every right in this Privacy Policy on the student's behalf, including access, correction, withdrawal of consent and deletion. They may withdraw consent at any time by contacting us using the information in the 'Contact Information' section below.

The age of majority is not the same everywhere. It is eighteen in most Canadian provinces and nineteen in others, and it varies again in the countries our students apply from. We apply the age of majority in the student's jurisdiction of residence.

Where the student has reached the age of majority, the student holds the account and gives consent themselves, and a parent has no access to the account or to the student's information unless the student chooses to give it.

Studendly is not directed to children under the age of thirteen, and we do not knowingly allow a child under thirteen to create an account or knowingly collect personal information from one. If you have reason to believe that a child under thirteen has provided personal information to us, please contact us and we will endeavour to delete it from our systems.

This Privacy Policy is current as of the "last modified" date which appears at the top of this page. We may make changes to this Privacy Policy from time to time, which will become immediately effective when published in a revised Privacy Policy posted on the Platform unless otherwise noted. You are responsible for checking if any amendments have been made. Your continued use of the Platform will constitute your consent to collection, use, and disclosure of personal information as described in the amended Privacy Policy.

Please review this Privacy Policy carefully. By submitting personal information ("Personal Information") to us, by registering for or using the Platform, or by voluntarily interacting with us, you consent to our collecting, using and disclosing that Personal Information as set out in this Privacy Policy, as revised from time to time.

Personal Information means information about an identifiable individual as described under Canadian privacy laws, which may include, but is not limited to, name, e-mail address and telephone number. Personal Information does not include any business contact information that is solely used to communicate with an individual in relation to their employment, business or profession.

Personal Information also does not include information that has been anonymized or aggregated in such a way that there is no serious possibility it can be used to identify an individual, whether on its own or in combination with other information.

We collect, use and disclose Personal Information with consent or as permitted or required by Canadian privacy laws. How we obtain consent may be express or implied and will depend on the circumstances, as well as the sensitivity of the information collected. Because a study application contains sensitive information about a young person, we rely on express consent, given at registration and again when an application is submitted to an institution.

Where the student is under the age of majority, that consent is given by the parent or legal guardian, as set out above.

Consent may be withdrawn at any time by contacting us. In some cases, withdrawal will mean we can no longer provide the Platform, and it may mean an application in progress cannot continue.

What we collect depends on who you are and what you use the Platform for.

• At registration: name, email address and password, and nothing more.
• Once an application is started: date of birth, telephone number, mailing address, country of residence and citizenship.
• Account information: username, password and account preferences.
• Parent or legal guardian details, collected once an application is started and only where the student is under the age of majority: name, relationship to the student, email address and telephone number.
• Academic information: schools attended, transcripts, grades, certificates and diplomas, English or French language test results, and any other academic record an institution requires.
• Application information: the programs and institutions applied to, application status, offers, deferrals and refusals.
• Documents uploaded: passports and travel documents, academic records, proof of funds and financial records, statements of purpose, reference letters, and civil status documents where an institution or a study permit application requires them.
• Study permit and visa information, where an application is being supported, including immigration and travel history and previous refusals.
• Payment information: the last four digits of a credit or debit card, and other payment method details held by our third party payment processors.
• Communications: messages, appointment records and advisor correspondence exchanged through the Platform.

• Identity and contact information, business details, and where applicable the institutions they are authorized to represent.
• Account, commission and payout information.
• Information about the students they manage on the Platform.

• Technical information: IP address, browser type, operating system and device information, collected to ensure the security, performance and functionality of the Platform.
• Usage information: pages visited, length of visits, page interaction such as scrolling and clicks, and how you navigate the Platform.

A study application contains sensitive information. It can reveal a young person's academic record, family finances, nationality, family relationships and legal status. We treat it accordingly.

We collect it only where it is needed for the applications being pursued. We do not sell it. We do not use it for advertising, and we do not disclose it for advertising purposes. We do not disclose it to any party other than as set out in 'How We Share Personal Information' below.

We use different methods to collect information, including through:

• Information provided directly, when registering, completing a profile, uploading a document, messaging an advisor, booking an appointment, making a payment, or contacting us.
• Information a parent or legal guardian provides about the student, where the student is under the age of majority.
• Information a recruitment partner enters about a student they manage, where the student or their parent has authorized that partner to act for them.
• Information returned by an institution about an application, such as a decision or a request for further documents.
• Information collected automatically through cookies and similar technologies. See 'Automatic data collection technologies' below.

We use information that we collect or that is provided to us in the following ways:

• Service delivery: to operate the Platform, match students to programs, build and maintain the student profile, prepare and organize documents, submit applications to institutions, and process payments.
• Application support: to populate application and immigration forms with information already provided, so it does not have to be re-entered.
• Guided assistance: to operate the guidance and matching tools on the Platform. See 'Automated Processing' below.
• Notifications: to communicate deadlines, decisions and requests for further information.
• Platform optimization: to analyze usage data and improve the Platform.
• Customer support: to respond to inquiries and provide assistance.
• Marketing outreach: to send updates and information about programs and services, with the option to opt out at any time. We do not direct marketing to a student we know to be under the age of majority, and marketing about such a student's account is sent to the parent or legal guardian.
• Regulatory compliance: to meet legal, tax and audit requirements.
• Security monitoring: to conduct audits and risk assessments that protect data from unauthorized access or breaches.

The Platform uses automated tools to match students to programs, to check eligibility against published entry requirements, and to help complete forms and organize documents.

These tools produce suggestions and drafts. They are not decisions. No admission decision, scholarship decision or immigration decision is made about a student by automated means on the Platform. Those decisions are made by the institution or the immigration authority. Anything an automated tool produces is reviewed by the student, the parent or guardian, and the assigned advisor before it is used.

We do not use Personal Information, documents or application content to train publicly available artificial intelligence models. Where an automated feature relies on a third party service provider, that provider is bound by contract to process the information only to deliver the feature and not to use it for its own purposes, including model training.

We share information in the following ways, and no others.

• With the educational institutions applied to, so that they can assess the application. This is the purpose of the Platform, and it is what the student or their parent is consenting to when an application is submitted.
• With the assigned advisor, and with a recruitment partner where the student or their parent has authorized that partner to act for them.
• With a licensed immigration professional, where a study permit or visa application is being supported and the student or their parent has engaged one.
• With third party service providers who perform services on our behalf, such as data storage (Google Cloud), email delivery and marketing (Mailchimp), and payment processing. They are required to keep Personal Information secure and to handle it only for the limited purposes for which we disclose it to them. They are not authorized to disclose it to unauthorized parties or to use it for their own direct marketing purposes.

Additionally, we may use and disclose information when we believe such use or disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our rights, operations or property; (f) to allow us to pursue available remedies or limit the damages that we may sustain.

If we otherwise intend to disclose Personal Information to a third party, we will identify that third party and the purpose for the disclosure and obtain consent.

We do not sell Personal Information, and we do not disclose it to other organizations for their own direct marketing purposes.

We may send direct marketing communications and information about programs and services that we consider may be of interest, in accordance with applicable marketing laws, including Canada's Anti-Spam Legislation (CASL). You may opt out at any time by contacting us or by using the unsubscribe mechanism provided in our marketing communications. Opting out of marketing does not stop the operational messages needed about an application, such as deadlines and decisions.

Where the student is under the age of majority, marketing is directed to the parent or legal guardian and not to the student.

The security of Personal Information is very important to us. We take reasonable steps to ensure it is protected from misuse and loss and from unauthorized access, modification, or disclosure, including access controls that limit each account to the applications it is entitled to see.

Security also depends on you. You are responsible for keeping your password confidential and for the activity on the account. We ask you not to share a password with anyone, including a recruitment partner.

Unfortunately, no data transmission over the Internet can be guaranteed to be totally secure. Accordingly, any information transmitted to us online is transmitted at your own risk. Once we receive it, we make our best efforts to ensure its security on our systems.

We may transfer personal information that we collect or that is provided to contractors and service providers we use to support our business, who are contractually obligated to keep it confidential, use it only for the purposes for which we disclose it to them, and process it to the same standards set out in this policy.

Applying to study abroad necessarily means sending information to another country. When an application is submitted, the information in it is transferred to the institution applied to, in the country where that institution operates, under the privacy laws of that country. Those laws may or may not be as comprehensive as Canadian law, and the governments, courts, law enforcement or regulatory agencies of that country may be able to obtain access to it. Submitting an application is consent to that transfer.

Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation. You are welcome to contact us for further information about our policies regarding service providers outside of Canada.

We only collect information by lawful means. When we do, we will collect, use or share personal information with consent for the purposes identified or as otherwise permitted or required by law. In some situations, the law allows us to collect, use or disclose personal information without consent.

Consent may be withdrawn at any time. However, withdrawing consent will normally mean that we can no longer provide the Platform, and an application in progress may not be able to continue. Where an application has already been submitted to an institution, we cannot withdraw the information from that institution, and any request to do so must be made to the institution directly.

A parent or legal guardian may withdraw consent to the collection, use or disclosure of their child's personal information at any time by contacting our Privacy Officer (see 'Contact Information' below) and, subject to any legal constraints, we will comply with the request.

You may request access to any personal information we hold at any time by contacting us. Where we hold information you are entitled to access, we will try to provide you with suitable means of accessing it.

If you believe that Personal Information we hold is incorrect, incomplete, or inaccurate, you may request us to amend it. We will consider whether the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note stating that you disagree with it, together with your requested amendment. If we correct Personal Information, we will, so far as is reasonably practicable, inform every other person to whom we have disclosed that information of the correction.

We may request specific information to help us confirm identity and the right to access. In certain situations we may not be able to fulfil a request, and we will explain the reasons when responding. Where the student is under the age of majority these rights are exercised by the parent or legal guardian.

Except as otherwise permitted or required by applicable law or regulation, we will only retain Personal Information for as long as necessary to fulfill the purposes we collected it for, including satisfying any legal, accounting, or reporting requirements. Application records are retained while an application is live and for a period afterwards so that decisions, deferrals and reapplications can be handled. Under some circumstances we may anonymize personal information so that it can no longer be associated with an individual, and we reserve the right to use such anonymous and de-identified data for any legitimate business purpose.

Tracking Technologies and Advertising. You can set your browser settings to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, some parts of the Platform may not be accessible or may not function properly.

Promotional Offers. If you no longer wish to receive marketing email from us, you can opt out by clicking "Unsubscribe" at the bottom of the email or by contacting us.

We do not share personal information with unaffiliated third parties for their promotional purposes, and we do not use academic, financial or immigration information to target advertising.

The information we collect automatically is statistical information and may include personal information. It helps us to improve the Platform and deliver a better and more personalized service, including by enabling us to estimate our audience size and usage patterns, store information about preferences, speed up searches, and recognize you when you return.

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or your smartphone. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of the Platform, including the parts that require you to be signed in.

Web Beacons. Pages of the Platform and our e-mails may contain small electronic files known as web beacons that permit Shirah, for example, to count users who have visited those pages or opened an email and for other related statistics.

Some content or applications on the Platform may be served by third parties. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Platform. We do not control these third parties' tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

The Platform may include links to third-party websites, including the websites of educational institutions, plug-ins, services or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. These third parties have their own privacy policies, we do not assume responsibility for their privacy practices, and we encourage you to review them before using them.

We welcome your questions, comments, complaints and requests regarding this Privacy Policy and our privacy practices. Shirah has designated a Privacy Officer who is accountable for our compliance with this policy and with applicable privacy laws. You may contact our Privacy Officer at:

Shirah Technologies Inc., operator of Studendly

[email protected]

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. Please note that we may need to confirm your identity or request additional details in order to process your request.

A parent or legal guardian contacting us about a student under the age of majority should say so, and we will verify the relationship before acting on the request.