Last Updated: 19 April 2024
Liu Cheng International Group Limited (“LCI Group”, “we”, “us” and “our”) is committed to protecting your privacy as a user of our LCI Partnership SaaS System (the “Platform”), or as a visitor to our website, www.lcig.io (“Website”). We respect the privacy and confidentiality of the personal information provided by you.
This Privacy Policy covers LCI Group and its related companies and explains how we manage the personal information that is collected, used, disclosed and stored about you.
By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us.
1. Who is LCI Group?
LCI Group is a Hong Kong-based company that provides the Platform which enables students to access and apply to study at thousands of universities and educational institutions around the world. We connect students with educational institutions (“Partner Institutions”) and with recruiters across the world who connect with students and process applications through our Platform (“Recruitment Partners”) (collectively the “Services”).
2. What is personal information?
When we refer to “personal information”, we mean information or an opinion about you, from which you are, or may reasonably be, identified. This information may include (but is not limited to) your name, date of birth, phone number, email address and address.
Personal information may also include information which is “sensitive information” under the Privacy Act. Sensitive information includes, for example, information or an opinion about an individual’s racial or ethnic origin, criminal record or membership of a professional association, trade association or trade union. Sensitive information also includes health information.
3. What information do we collect?
The personal information we collect depends on the nature of our relationship with you. For example:
•If you are a student wishing to apply to study with a Partner Institution (“Student”), we will collect your name, date of birth, passport number and academic details.
•If you are a representative of a Recruitment Partner, we will collect your name, contact details, company details, business licence details and bank account number when you onboard.
•If you are a representative of a Partner Institution, we will collect your name, contact details, institution details and product details when you contract with us.
•If you apply for a job with LCI Group (or a related company) or are an employee, we may collect, for example, your full name, contact details (including address, phone number and email address), job title, passport details, employment history and education details, names and contact details of referees, next of kin details (in the event of an emergency) and superannuation or pension fund and tax registration details, if required by law.
If you do not provide the information requested by us, we may not be able to provide you with our Services.
4. How do we collect your personal information?
We will collect personal information about you if you choose to provide it to us. Personal information may be collected from you in a variety of ways, including at different places and times on our Platform and Website. We may collect your personal information when you do any of the following, for example:
• submit an application to create a profile on the Platform;
• apply for a LCI Global Scholarship;
• apply for your business to be a Recruitment Partner;
• apply for your educational facility to be a Partner Institution;
• change your profile on the Platform or your email preferences;
• submit an application for employment with us;
• subscribe to receive our newsletter or promotional materials or sign up to a mailing list;
• enter competitions or other promotional activities we conduct;
• respond to surveys;
• communicate with our customer service team;
• interact with us via any of our social media pages, for example, Facebook, Instagram, Twitter and LinkedIn; or
• engage with us by phone, email, mail, or via the Platform or Website, whether you are a Student or a representative of a Partner Institution or a Recruitment Partner or are interested in using our Platform.
We may also collect personal information about you from third parties. These third parties may include (but are not limited to):
• visa service providers, document verification service providers and finance service providers;
• someone duly authorised to act on your behalf;
• where you have provided consent, for example, from third parties, such as referees.
Our server automatically collects information about your use of the Services (Navigational Data). Navigational Data includes the type of browser you are using, your IP address, the URL you have come from and the time spent at that URL, cookies and your domain type and server. This kind of information is collected by many mobile applications. We use this information to monitor your use of our Services. See “Cookies” below for further information about our use of cookies.
If you provide personal information to us about someone else, you must ensure that you are entitled to disclose that information to us. For example, you should take reasonable steps to ensure the individual concerned is aware of the various matters detailed in this Privacy Policy.
5. How is personal information used?
We may use your personal information for the following purposes:
• to provide you with the Services you have requested, for example, to create an account on the Platform;
• to respond to your inquiry;
• to manage our relationship with the Partner Institution or Recruitment Partner you represent;
• to verify your identity, visa eligibility and academic credentials;
• for complaints handling;
• data analytics;
• to improve our Services;
• send you direct marketing messages (by email, SMS and post) which we consider may be of interest to you;
• the prevention of fraud and/or identifying and investigating any suspicious use of our Platform, Website or Services;
• for our internal business and management processes, for example, accounting or auditing purposes;
• for any other purpose to allow us to comply with our obligations under law; and
• for any other purposes that would reasonably be expected by you.
If you are a job applicant, employee or contractor with the LCI Group (or a related company), we will use your personal information for purposes relating to your engagement, training, performance management, payroll, superannuation/pension, health and safety, for administration and staff management purposes. Where we consider it appropriate, we may also conduct reference checks (or engage a third party to do so on our behalf).
We may use personal information which has been deidentified to create marketing statistics, identify user demands and to assist in meeting customer needs generally. We may also use this information to improve the Platform and our Services.
6. Will personal information be disclosed to third parties?
Personal information may be disclosed to third parties in the circumstances below:
•If you are a Student, your personal information will be shared with your Recruitment Partner, the university, document verification service providers and the visa office for processing of your study application, document verification and student visa application.
•If you are a Partner Institution representative, your personal information will be shared with students and the Recruitment Partner for student application processing, marketing promotion and marketing fee purposes.
•If you are a Recruitment Partner representative, your personal information will be shared with universities, document verification service providers and visa offices for Student recruitment and compliance purposes.
•Third party contractors and service providers
Personal information collected by us may be disclosed to third parties whom assist us with the operation of our business. These third parties include payment processors, website development and IT service providers, visa service providers, document verification service providers and marketing service providers.
Your personal information may be disclosed to our professional advisors including lawyers, accountants, tax advisors and auditors.
LCI Group is based in Hong Kong, China. The third parties may be located overseas. For example, our Partner Institutions may be located in the UK, Ireland, the USA, Canada, Australia and New Zealand. Our IT team is based in Chinese mainland. Our document verification service providers are based in the countries in which students using our Services are located. Please be aware that the privacy laws in other countries might not be the same as in your country. Before we disclose personal information to overseas recipients, we take reasonable steps to ensure that the overseas recipients will handle personal information in accordance with privacy law requirements.
The data on the Platform is stored in the Microsoft Cloud with the server being in Singapore.
• Disclosures required by law
For legal reasons, other disclosures may need to be made to law enforcement agencies, government agencies, courts or external advisors or as otherwise required or authorised by law.
Sale of Business
We reserve the right to transfer information (including your personal information) to a third party in the event of a sale, merger or other transfer of all or substantially all of the assets of the LCI Group (or a related company, if applicable) provided that the third party agrees to adhere to the terms of this Privacy Policy and handle personal information in accordance with applicable privacy laws.
7. Direct marketing
From time to time, we may use your personal information to provide you with information about our Services, special offers you may find of interest or new services being offered by us or any business we are associated with. Direct marketing messages may be sent by email, SMS or post.
If you do not wish to receive marketing information, you can at any time opt out by contacting our Privacy Officer using the contact details below or by using the opt-out facilities provided in our marketing message (such as an unsubscribe link in an email). Please note that if you opt-out, we may still send you non-promotional messages, such as transactional messages regarding your account.
8. Cookies
We may collect personal information about you when you use and access our Platform and Website. While we do not use browsing information to identify you personally, we may record certain information about use of the Platform and Website, such as the pages or screens visited, the time and date of the visit and the internal protocol or IP address assigned to the computer or device.
Our Platform and Website also use cookies or similar tracking technologies to help us track Platform and Website use and remember user preferences. Cookies are small files that store information on your computer, mobile phone or other device. A cookie enables the entity that put the cookie on your device to recognise you when you use different websites, devices and/or browsing sessions.
We may also use cookies to collect data that may include personal information, for example, where a cookie is linked to your user account. Where we collect personal information via cookies, the personal information will be handled in accordance with this Privacy Policy.
You can disable cookies through your internet browser. However, our Platform and Website may not work as intended if you do so.
9. Accessing and correcting your personal information
We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.
You are entitled to access and correct your personal information we hold on request. To request access to and/or correction of your personal information, please contact our Privacy Officer using the contact details set out below. After receiving a request from you, we will take reasonable steps to correct the information. Alternatively, you may be able to update your contact information, for example, by logging into your account.
You will not be charged for making an access and/or correction request but you may be charged for the reasonable time and expense incurred in compiling information in response to your access request.
We may decline your access and/or correction request in certain circumstances where permitted by law. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.
10. Is personal information stored safely?
We take reasonable steps to ensure the security of personal information held by us from such risks as loss or unauthorised access, destruction, use, modification or disclosure. Our IT systems are password protected and comply with our security standards, and if personal information is held on paper files, it is stored in premises that are locked when unattended.
The data on the Platform is stored in the Microsoft Cloud with the server being in Singapore.
11. Third party websites
Sometimes our Services contain links to other websites and mobile applications for your convenience and information. When you access a website through our Services, please understand that we are not responsible for the privacy practices of that site. We recommend that you review the privacy policies of each site you visit.
Any information you provide to third party websites will be governed by the terms of the websites’ privacy policies. We have no responsibility or liability whatsoever for the content, actions or policies of third party websites.
12 Further information and complaints
You may contact us at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.
You may make a complaint about privacy to our Privacy Officer using the contact details set out below.
The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint.
Your complaint will then be investigated. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.
In most cases, we will investigate and respond to a complaint within a reasonable time, usually within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
If you are not satisfied with our response to your complaint, you may make a complaint to the privacy commissioner or relevant data protection authority where you are located.
13. Individuals in the EU and UK
If you are located in the EU or the UK, you have the following additional rights:
• The right to information – you can request confirmation about the following: whether your personal information is being processed by us; the purpose of processing; the categories of personal information which are processed; the recipients (or types of recipients) who may receive the personal information; the anticipated retention period of the personal information; and your rights to rectification, erasure, to restrict (or object) to processing and to lodge a complaint with a data protection authority in the EU or UK.
• The right to object to our processing of your personal information for (i) direct marketing purposes; (ii) for scientific, historical research or statistical purposes; or (iii) where our processing is based on legitimate interest grounds or because it is in the public’s interest. We will respond to your objection request within a month. However, there may be some circumstances where we are not required to stop processing your personal information. If this is the case, we will provide you with a written explanation.
• The right to restrict processing – in some circumstances, you can request us to restrict our use of your personal information in which case we will not use or disclose your personal information while it is restricted. We will respond to your restriction request within a month.
• The right to erasure – you can request us to erase your personal information where it is no longer required for a purpose for which it was collected or where, for example, you have exercised successfully your right to object to processing. We will respond to your erasure request within a month. However, where there are legal or other reasons for us to retain your personal information, we will provide you with a written explanation.
• The right to data portability you can request us to provide you with a copy of the personal information you have provided to us. We are required to provide it to you in an electronic format that can be reused easily. You can also request us to transfer your personal information
in an electronic format to another entity.
You can exercise any of these rights by contacting us using the contact details below. You also have the right to:
• access your personal information and request the correction of your personal information (see “Accessing and correcting your personal information” above); and
• lodge a complaint with a data protection authority if you are unhappy with the outcome of a privacy complaint. The “Further information and complaints” section above explains our complaints handling process. A list of EU data protection authorities is available at https://commission.europa.eu/index_en.
14. Contacting us
You can contact our Privacy Officer by:
• emailing us at support@lcig.io
• writing to: Suite 1708 / 87-89 Liverpool Street, Sydney NSW 2000 Australia
15. Changes to this Privacy Policy
We may change this Privacy Policy from time to time. When we make changes, we will post a notice on our Platform and Website homepage. We will also make a new copy of the updated Privacy Policy available on our Platform and Website. Where changes to the Privacy Policy are material, we will provide you with reasonable notice before the changes take effect. If you continue to use our Platform or Website after the effective date of the changes, you will be taken to have accepted the amended Privacy Policy.