Privacy Policy

This Privacy Policy explains how GLLS Teleporto Technologies LTD (“Univenter”, “we”, “us”) collects, uses, shares and protects personal data when you visit univenter.me, use the Univenter platform at app.univenter.me, talk to our team, or are a student whose application is handled through Univenter (together, the “Service”).

Univenter is a business-to-business platform. Education agents (“Partners”) use it to find programmes and send students’ applications to universities and schools (“Institutions”). Institutions use it to receive and manage those applications.

1. Who is responsible for your data

GLLS Teleporto Technologies LTD, a company registered in the Republic of Cyprus (registration number HE 448695), is the controller of the personal data described in this Policy, except where Section 3 says otherwise. We process personal data under the EU General Data Protection Regulation (“GDPR”) and the Cyprus law on the protection of natural persons with regard to the processing of personal data (Law 125(I)/2018).

We have not appointed a data protection officer. For any data protection question or request, write to info@univenter.me with the subject “Data protection”.

2. Whose data we process

• Website visitors of univenter.me.
• People who contact us or book a call, for example through the demo booking calendar, the institution form, email, phone or WhatsApp.
• Partners and their team members, including the people who register, verify and manage a Partner account.
• Institution staff who use the platform on behalf of a university or school.
• Students, and where relevant their parents, guardians or sponsors, whose details a Partner uploads to apply for a programme, or who register on the platform themselves.
• Job applicants who apply through our careers page.

3. Our role for student data

A Partner collects a student’s data and decides to upload it. The Partner is an independent controller of the data it collects. We become a controller of student data once it is used to send an application through the platform, because we then use it for our own purposes: passing the application to the chosen Institution, recording its progress, confirming which Partner the student is attributed to, checking identity and documents, preventing fraud, paying Partners and meeting legal duties. Each Institution is an independent controller of the data from the moment it receives an application.

For a few functions we act only on the Partner’s instructions, as its processor: storing a student record before its first application, preparing programme proposals for the Partner, and running AI matching, drafting and messages to a student at the Partner’s request. Our Data Processing Terms govern that processing.

Before a student’s first application, the platform sends the student a short notice (the Student Disclosure). It explains who the student’s adviser is, how Univenter and the adviser are paid, and how the student’s data is used, and asks the student to confirm it.

4. What data we collect

• Contact and account data: name, email address, phone and WhatsApp number, country, organisation, job title, login details (passwords are stored only as a salted hash), two-factor authentication settings and preferences such as language and time zone.
• Verification data of Partners: identity documents, the result of a liveness check or video call, company registry extracts, owners and directors, licences, tax number and payout bank details.
• Student data: name, date of birth, nationality, passport details, contact details, address, education history, language certificates, budget and study preferences, uploaded documents, and application status. Where an Institution or a visa process requires it, this can include health information or a police certificate.
• Application and finance records: applications, stages, decisions, offer letters, visa decisions, payments reported to Institutions, rewards, payouts and clawbacks.
• Communications: messages in platform chats, support tickets, emails and WhatsApp messages with our team. Calls with our team through our business telephony may be recorded and transcribed. If you do not want a call recorded, tell the manager at the start of the call or write to us.
• Booking and enquiry data: what you enter when you book a demo call or send a form, the time you chose and your time zone.
• Technical and usage data: IP address, device and browser type, pages viewed, referring page and timestamps. On univenter.me, analytics run only if you accept analytics cookies; see Section 10.
• Job application data: your CV and what you write in the application form.

If you sign in with Google, we receive your name, email address and profile picture from Google.

5. Why we use data and on what legal basis

• To provide the platform and perform our contracts with Partners, Institutions and students who register themselves (contract).
• To send applications to the Institutions a student chooses and record their progress (our legitimate interest in running the marketplace, and the contract with the Partner and the Institution).
• To verify Partners, check documents, attribute students to the right Partner and prevent fraud (legitimate interest; legal obligation where sanctions or anti-money-laundering law applies).
• To pay Partners, keep accounting records and meet tax rules (contract and legal obligation).
• To answer enquiries, run demo calls and support users (steps at your request before a contract, and legitimate interest).
• To send service messages about your account and applications (contract and legitimate interest), and product news where you agreed or where the law allows it (consent or legitimate interest; you can unsubscribe at any time).
• To measure and improve the website with analytics cookies (consent, which you can withdraw at any time).
• To transcribe and summarise recorded calls and draft replies with AI, so our managers can follow up accurately (legitimate interest). A person reviews AI drafts before they are sent.
• To assess job applications (steps at your request before a contract).
• To establish or defend legal claims (legitimate interest).

Partners are responsible for having a lawful basis to upload student data and for giving the Student Disclosure. We use special category data, such as health information, only where an Institution or visa process requires it, and only to pass it to that Institution.

6. Who we share data with

We do not sell personal data. We share it only as follows:

• Institutions receive the student data and documents needed for the applications the student makes to them.
• Partners see the progress of the applications they submitted. Institutions see the Partner’s partner code; they see a Partner’s email address only where that Institution has been given access to contact details.
• Service providers who process data for us under contracts that protect it (listed in Section 7).
• Document issuers and authorities, where we need to check that a document is genuine, or where the law requires disclosure, including to report forgery or fraud.
• Professional advisers, such as lawyers, accountants and auditors, under a duty of confidentiality.
• A buyer or successor of our business, if the business or part of it is transferred, under the same protections.

7. Our service providers (sub-processors)

We use the following providers to run the Service. We may change this list; Partners whose data we process as a processor receive notice of a new sub-processor as set out in the Data Processing Terms.

Provider	What it does for us	Where data is processed
Supabase	Database, file storage and sign-in for the platform and the website	European Union (Ireland)
Vercel	Hosting of the website and the platform, and cookieless usage statistics on the platform	United States and global edge network
Bitrix24	Our CRM, business telephony and call recordings, demo booking calendar, internal chat and knowledge base	Provider data centres
Wazzup and Meta (WhatsApp Business)	WhatsApp messages between our team and Partners	Provider data centres
Google	Business email and calendar, Google Meet calls, Google sign-in, and Google Analytics on the website if you accept analytics cookies	European Union and United States
Contentsquare	Website experience analytics, if you accept analytics cookies	European Union
Mailtrap	Delivery of platform notification emails	Provider data centres
Anthropic	AI drafting, translation and summaries for our team	United States
OpenAI	Transcription of recorded calls with our team	United States
Atlassian (Jira)	Bug reports that users send from the platform	Provider data centres

We do not allow AI providers to train their general models on student data.

8. International transfers

Our users are in many countries, and some of our providers and Institutions are outside the European Economic Area. Where we transfer personal data outside the EEA to a country without an EU adequacy decision, we use the European Commission’s Standard Contractual Clauses or another safeguard the GDPR allows. A student’s data goes to an Institution outside the EEA only when the student applies to that Institution. You can ask us for a copy of the safeguards that apply to you.

9. How long we keep data

• Platform records, including applications, verification records, acceptance records and finance records: 7 years after the last event on the application or after the end of the Partner’s agreement, or longer while a claim or legal duty requires it.
• Data we hold only as a Partner’s processor: deleted within 90 days after the Partner’s account is closed, unless the law requires us to keep it.
• Enquiries and demo bookings that do not lead to a contract: up to 3 years after our last contact.
• Call recordings and transcripts: up to 2 years, unless needed for a dispute.
• Job applications: up to 12 months after the position is filled, unless you agree that we keep your CV longer.
• Analytics data: as set in the analytics tools, up to 14 months for Google Analytics and 13 months for Contentsquare.

When data is no longer needed, we delete it or make it anonymous.

10. Cookies and analytics

On univenter.me we use only necessary storage unless you accept analytics cookies in the cookie banner. If you accept, we use Google Analytics and Contentsquare to understand how visitors use the website. You can change your choice at any time with the “Cookie settings” link at the bottom of every page. On the platform we use only necessary cookies and local storage, and cookieless usage statistics. Details are in our Cookie Policy.

11. Your rights

Subject to the law, you can ask us to give you access to your personal data, correct it, delete it, restrict its use, give it to you or another organisation in a portable format, and you can object to processing based on our legitimate interests. Where we rely on your consent, you can withdraw it at any time without affecting what was done before.

To use your rights, write to info@univenter.me with the subject “Data protection”. We answer within one month, and may ask you to confirm your identity. If a Partner uploaded your data and your request concerns that Partner’s own use of it, we will pass your request to the Partner and tell you.

You can also complain to the Commissioner for Personal Data Protection in Cyprus (dataprotection.gov.cy) or to the data protection authority where you live or work.

12. Security

We protect personal data with encryption in transit and at rest, role-based access for our staff with multi-factor authentication, access controls that separate each organisation’s data, access logs, backups and an incident response procedure. No system is completely secure. If a breach is likely to put your rights at risk, we will tell you and the authorities as the law requires.

13. Children

The Service is for businesses and adults. Students under 18 can only be represented through a Partner, and the Partner must obtain the consent of a parent or guardian and include them in communication. We do not knowingly allow anyone under 18 to open an account.

14. Automated decisions

We do not make decisions about you based solely on automated processing that have legal or similarly significant effects. The platform may suggest programmes or flag possible duplicates or fraud, but a person makes every decision on verification, attribution, payouts and measures against accounts. Admission decisions are made only by Institutions.

15. Changes to this Policy

We may update this Policy. We change the effective date at the top and, for material changes, tell registered users through the platform or by email before the change takes effect.

16. Contact

GLLS Teleporto Technologies LTD
Peiraios 30, 1st floor, Flat/Office 1, Strovolos 2023, Nicosia, Cyprus
Email: info@univenter.me
Phone / WhatsApp: +44 7458 164888

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GLLS Teleporto Technologies LTD, incorporated under the laws of the Republic of Cyprus · Organization number 623549 · Record number 35690886 · Registration number HE 448695 · Peiraios 30, 1st floor, Flat/Office 1, Strovolos 2023, Nicosia, Cyprus