Users can research the procedures for enrolling in particular universities throughout the world through Pave Inc. (“Pave,” “IES”, “we,” “us,” or “our”), including details on visa applications and program details. Additionally, we offer access to supplemental services and products related to the journey of the international student through our recruitment partners, counselors, and website (collectively the “Services”). These services and products are also referred to as the ability to apply for admission to specific programs of such institutions.
To do so, Pave gathers your personal information. The way in which Pave gathers, utilizes, discloses, and otherwise manages personal data is described in this privacy policy.

The modifications to this privacy statement take effect on the date indicated above, and if you continue to use Pave’s services or website after that time, you will be subject to the revised privacy statement.

General

This privacy and cookies policy (the “Policy”) explains:
the data that we gather and use regarding you (which you give to us directly or which is given to us by third parties, such as our partners in recruiting and our counselors);
the objectives for which we gather and use data about you; and
the foundation upon which we gather and use the data we learn about you from your use of our website (hereinafter referred to as “Website”) and the services made available to registered users through it (collectively, “Services”) at https://www.atheneeducation.com.
The terms “personal data” and “personal information” refer to information about a recognized or identifiable individual.
You should carefully read this Policy to understand how Pave Inc. and any subsidiaries and/or affiliates use your personal information. This Policy and any relevant Terms and Conditions for use of our Services, including any applicable restrictions on damages and dispute resolution procedures, govern your use of our website and services as well as any privacy issue. By visiting our Website, you agree to the procedures outlined in this Policy, which is incorporated by reference into our Terms and Conditions for our Services.

Important Reminders
PLEASE NOTE THAT THE WHOLE OF THIS POLICY APPLIES TO YOU, AS WELL AS Extra PROVISIONS WHICH ARE SPECIFIC TO EEA AND UK CUSTOMERS AND ARE FOUND AT APPENDIX 1. These additional provisions are only applicable to EEA and UK customers.
Please take note that the entirety of this Policy, as well as additional rules that are particular to residents of California and can be found in Appendix 2, applies to you. SPECIFIC TERMS FOR CUSTOMERS FROM THE STATE OF CALIFORNIA ONLY.

What Data We Gather and How
How is my personal information gathered by Athene?
In order to provide you with the Pave Services or as part of a customer referral program, we collect personal data about you directly from you, automatically as you use our Website and the Services, and from third parties such as our marketing affiliates and service providers used to verify your identity and prevent fraud. Currently, only users who register for our services are able to utilize them.
From third parties, including affiliates, other Pave users, event providers, and other third parties, we obtain personal information about you (e.g., entities that assist us in validating your identity, for risk assessment purposes, for fraud prevention, etc.). This data may be combined with other information we have about you.
Your domain name, your browser type and operating system, the web pages you view, the links you click, your IP address, the amount of time you spend on our website or use our services, your activities on our website, and other information about how you use our website and our online services are all automatically collected by us and our third-party service providers (with your consent where required by applicable law). For additional information, please see the part below titled “Our Use of Cookies and Other Tracking Mechanisms.”

What private information does Athene gather?
The kinds of personal information we gather from you depend on how you use our website and services specifically, but in general, when allowed by relevant legislation, they include:

Types of Personal Information Gathered
Unique Personal Information
Personal Data Source
Identifiers
Name, email address, phone number, billing or mailing address, IP address, birthdate, national identity numbers, and documents that might include your picture or a government identifier directly from you, other parties acting on your behalf and following your instructions, other customers and users of Pave, our service suppliers, and affiliates.

Use of the Internet or a Comparable Network Activity
Other data stated above and described in the section below labeled “Our Use of Cookies and Other Tracking Mechanisms” that is gathered through Cookies and other tracking technologies
directly from you, as well as via the use of our cookies and third-party analytical tools (see the section below titled “Our Use of Cookies and Other Tracking Mechanisms”).

Information about businesses
Information regarding your company
directly from you, from third parties acting on your behalf and following your instructions, from other Pave users and clients, from our service providers, and from our affiliates.
Location Information
Geolocation
directly from you, by your use of the mobile application, or via our use of third-party analytical tools and cookies (see the section below headed “Our Use of Cookies and Other Tracking Mechanisms”).

Employment or Professional Information
Name and contact details, educational and employment history, professional qualifications and experience, remuneration, assessments, references, interviews, certifications, disciplinary actions, and other data of the kind found on a resume, curriculum vitae, or cover letter.
directly from you or when it is given to us by another person, like a recruiter, counselor, or external website.

Several Categories
Any additional details you decide to share with us (for instance, when you email us or get in touch with us in another way).
directly from you, third parties acting on your behalf, and in accordance with your requests or permission.

When We Gather Information About You and How We Use It
When you perform any of the following actions, Pave records your personal information and utilizes it as stated below:
Create an account:  You must create an account with an email address and password, or sign in using Facebook or Google, in order to access certain features on the website. Your login details are used to establish your account and carry out any administrative tasks related to the service you requested.

Find Out What Programs You Qualify For: You don’t need to register in order to visit and browse specific elements of our website, such as to look through other schools and programs, read other content sections, or check your qualification for specific programs. We gather personal information such your nationality, country of education, highest education, grading scheme, grade average, English exam score(s), and the disciplines or programs you are interested in pursuing if you decide to utilize our website to find programs you are eligible to apply for. These details are used by Pave to compile a list of courses and institutions to which you are qualified to apply.

Create a Student Profile and/or Apply to an Educational Program: You must create a student profile on our website before you may apply to an educational program (or have a recruitment partner or counsellor act as your legal representative). We can better match you with schools and programs that match your tastes and credentials thanks to the personal information we collect in your student profile. The school might also need these information in order to process your application. Your first and last name, email address, gender, date of birth, home and mailing addresses, passport information, marital status, emergency contact information, English or French test score(s), educational preferences (like preferred study destination and academic fields of interest), education history, volunteer experience, and other educational information may be included in this list.
You have the choice to submit more details, like proof of honors or schoolwork, at any point during the application process. Although it is not necessary in order to process your application, providing these information can help it be successful.
We may make customized school suggestions through the website based on your profile information and other data about how you use the site (such as search terms or other links you click on).

Use an ApplyStudent Email Account: To help you communicate with specific schools of interest, we may create and give you access to a “ApplyStudent” email account. Email addresses for ApplyStudent are exclusively used while registering for academic programs on Pave. In order to ensure that you don’t miss any crucial information pertaining to your application, Pave monitors the incoming and outgoing emails from ApplyStudent email accounts and may gather information from those emails. You can stop this email account from working by getting in touch with us as indicated below.

Utilization of Our Services for Visa Procedure: We give students the choice of having Pave handle their student visa processing. If you decide to use this service, we may gather personal information about you, such as information from your passport and data from a visa application form, in order to process your visa application (if necessary).

Use ApplyProof to verify your documents: ApplyProof may be an alternative for you. An online tool called ApplyProof makes document verification quick and secure. The document validation platform is made to assist partners and institutions in conducting centralized reviews of papers for a range of purposes, such as expediting study permit and VISA applications and determining whether a student is a viable candidate for academic programs. In addition to this Privacy Policy, any applicable ApplyProof terms and conditions will also apply to your use of the service.
Another example of Pave supporting our objective to “Educate the World” is ApplyProof, which is powered by Athene’s superior SaaS services team.
Post Through Pave’s Services or On Social Media Platforms, Like Facebook, LinkedIn, or Instagram, Or Direct Message Us Through These Platforms: You Have The Ability To Post Information (Example: Questions, Comments, and Opinions) Through Pave’s Services Or On Social Media Platforms, Like Facebook, LinkedIn, or Instagram, Or Direct Message Us Through These Platforms. Please be aware that any personal information you freely disclose in a public forum will be accessible to others, therefore you should use caution while disclosing any personal information. The privacy rules of the third parties whose websites you upload content on (such as social media platforms) are applicable.

Register to Take Any Courses: You can access our course materials and voluntarily give personal information so we can register you as a student taking the course. We shall keep a record of your registration for and/or completion of the course offering, and a certificate of completion may be offered.
Contact Us: When you get in touch with us with a comment, question, or complaint, we might ask you for information that helps us quickly react to your comment, answer your question, or resolve your complaint, such as your name, address, and phone number. We might also save this data in order to help you in the future and to enhance our events, marketing, and customer service.
We may get personal information about you from your legal representation, a recruitment partner (or partners), or a counselor (or counselors) that you are working with and who are utilizing our services to handle your school application. On rare occasions, third parties like mailing list providers and third-party service providers may provide Pave with information about you. The consent to provide us with personal information must be obtained by third-party suppliers.
Payment processing and transaction tracking are done by third-party PCI certified payment service providers, such as Western Union, Flywire, or Stripe, with your permission from Pave. You are subject to their privacy rules when you use these payment service providers directly to make a payment. They are not affiliated with Pave, and Pave is not liable for their privacy policies.
Our applications are built to safely, transparently, and cryptographically connect our users to PCI certified payment processors. By doing this, you may be confident that your financial transactions will remain private. The transaction number and status are provided to Pave by the payment processor. This data is frequently needed for visa applications as evidence of program payment and as a sign of the student’s dedication to the chosen program. In order to process payments to independent service providers and/or third-party contractors in connection with the Services, Pave has a list of payment processors that we may utilize.

Registration for Marketing Email and Other Materials: We may provide you with the option to register to receive Pave marketing and promotional communications on the Website, on external websites (including social media sites), or at training events and informational sessions. In certain situations, we gather specific personal information (such your first and last name, email address, or mobile phone number), which we use to send you emails and other messages with updates, advice, and other content from Pave that may be of interest to you. By following the “opt-out” or “unsubscribe” procedures provided in your email or text message, or by contacting us as detailed below, you can choose not to receive promotional emails from us. Please be aware that you can still get emails from us about your application or other transactional and account-related notifications.

Join Our Surveys and Customer Research: Occasionally, we may provide you the chance to join one of our surveys or other types of customer research. Our surveys and customer research yield information that is used in an aggregated, non-personally identifiable manner. We utilize this information to better our product and service offerings, promotions, and events while also better understanding our customers.

Join Contests and Promotions: If you sign up for a contest or promotion, we may gather your name, address, contact information (such as a phone number and email address), and other details you submit. To manage your participation in the competition or campaign, we utilize this information. The limitation of liability and indemnity clauses, if any, included in the Terms and Conditions are waived with regard to any injuries suffered or liabilities incurred as a result of any research activities if non-identifiable data is utilized for such purposes.

Apply for a Program at Athene: You may provide us certain personal information about yourself in conjunction with a position application or other question about a potential job with Pave (such as that contained in a resume, cover letter, or similar employment and education-related materials). We use your information to process and address your application for open positions in the present and in the future.
In order to apply to be a potential recruitment partner with Pave, you may give us certain personal information, such as your first and last names, address, email address, information about your academic and professional history, and financial information. With the help of third-party payment processors, we process and address your application to become a Pave Recruitment Partner using the information you provide. We also use it to pay you as necessary.

Apply to Become a Potential Counselor with Athene: In connection with your application to join Pave as a potential counsellor, you may give us certain personal information, including your first and last names, address, email address, information about your educational and professional history, and banking information. In order to process and react to your application to become a Pave Counselor, as well as to pay you as necessary utilizing third-party payment processors, we use this information.
You are in charge of offering truthful and current information.

What Information Do We Share With Others?

As shown in the table below, we share your personal information with third parties such service providers, regulated institutions (like financial institutions), related entities, and business partners.
We also list the justifications for sharing information in the section that follows.

What Information We Share with Whom and How
who we divulge your personal information to
Reason
Schools
We give the schools you’re applying to access to the data in your application (either directly or through a third party on your behalf, within Canada or abroad). When Pave gives your information to these schools for your application for admission, Pave has no control over how those schools will use it. If you have any concerns about how your personal information is handled by these institutions, Pave advises that you get in touch with them directly.

Partners
We might occasionally collaborate with outside companies to offer benefits to the Website’s registered users. We might give some of your personal information to third parties so they can get in touch with you about the benefits, or we might share anonymous, aggregated data about your profile and usage with business partners for marketing and analytics. We might employ Facebook’s Custom Audiences to send our subscribers Facebook ads. Your email address is changed into a unique number that is linked with another unique number to uniquely identify you on Facebook; Facebook does not receive any of your personal information in this process. Ads from Facebook Audience can be turned off.

Service Companies
Your personal information may be transferred (or otherwise made available) to third parties who perform services for us. To send emails, host the website and its data (including cloud providers), and run certain of its services, for instance, we may use service providers like cloud providers. Other service providers might help us with a variety of tasks, including the supply of the services, identity verification, fraud prevention, abuse detection, internal research, analytical evaluations, processing of transactions, account maintenance, and customer service. Your personal information may be maintained and processed by third party service providers, such as internet service providers, data and cyber security services, banks, financial institutions, payment processors, financial services providers, remote access services, service providers that help us verify your identity and help us comply with our legal and regulatory obligations, and our business, legal, tax, financial, and other advisors, on a confidential basis. We only offer the data necessary for our service providers to carry out their assigned tasks; we do not permit them to use or disclose personal information for their own marketing or other reasons.

parties to and participants in a commercial deal with Athene
Any information we have on you may be transferred as an asset in connection with a merger, sale, or other corporate reorganization that involves all or part of Athene, whether contemplated or actualized (including transfers made in connection with insolvency or bankruptcy proceedings).

Researchers
With your permission, Athene may internally utilize your data for research and development to enhance our current goods and services and/or develop new features to better serve you. For the same goal, Athene also uses non-personal data (sometimes known as “Metadata”). In order to enhance our current products and services and/or develop new features to better serve you, we may share your personal information with third parties engaged in research and development, with your approval. These third parties could include scholars, educational institutions, or others working in related fields.

Law Enforcement, Courts, and Attorneys
In response to a search warrant or other legally valid inquiry or order, or to an organization in the event of a breach of an agreement or a violation of the law, or as otherwise required or permitted by applicable Canadian, US, or other law, Pave and our Canadian, US, and other service providers may provide your personal data. The formation, exercise, or defense of legal claims, the detection, suppression, or prevention of fraud, the investigation of real or suspected loss or harm to persons or property, or other situations requiring disclosure of personal data may also be included. For legal, regulatory, and/or compliance reasons, we might need to get in touch with you personally to check certain information provided in connection with your application process if you have hired a recruitment partner or counselor to submit your application to Athene.

Please get in touch with us via the different methods provided under the Section labeled “Contact Us, Questions, Updating Your Info, Opting Out” below if you do not want us to use your personal information to market to you or to share with third parties for marketing purposes. We do not sell your personal information. You can opt out of receiving any marketing emails from Pave by clicking the link given in those emails.

Locations of Our Data Storage
We store all the data you give us on our secure servers. Using SSL technology, all payment transactions will be encrypted. You are in charge of maintaining the confidentiality of any password we have provided you (or that you have chosen) in order to access particular areas of our website. We kindly ask you not to divulge your password to anyone.
Except for the ApplyProof application, which is housed wholly in Canada, our servers are mostly in the USA. Also based outside of Canada are many of our service providers. Although we utilize reasonable security measures to protect your information, laws outside of Canada may not be the same as those in Canada, and authorities in those other countries may be able to access your information in compliance with their local laws.

Safeguards
The protection of your information is a top priority for Athene. In an effort to prevent unauthorized access, use, modification, and disclosure of personal data in our custody and control, we have put in place reasonable administrative, technical, and physical safeguards. These measures include limiting access to our database to authorized users, using device encryption, and using version tracking.
Unfortunately, internet-based information transfer is not entirely secure. Despite our best efforts, we cannot ensure the security of your personal information transferred to our website; any transmission is done at your own risk. Once we obtain your information, we will endeavor to prevent unauthorized access by following tight protocols and utilizing security features.

You Rights
The following rights are yours:
Access
Correction (Right to rectification) (Right to rectification)
The right to revoke your agreement or to disappear
the right to criticize or report
Subject to certain limited limitations set down by law, you may access, update, and correct inaccuracies in your personal data that we hold or manage at any time. Just sign in to your account, navigate to your profile, and make the necessary adjustments.
By contacting us as indicated below, you can also ask for access to, updates to, or corrections to additional personal information in our files. To confirm the identity of the person requesting access to their personal data records, we could ask for certain personal information.
If Athene is in a legal position to comply with your request, you have the right to request that your data be erased (withdrawn). If you submit an application to a third-party provider, you cannot have an active study application where billing or financial records are being processed or may be in progress. If Athene can accommodate your request, just the personal information you supplied will be deleted. Metadata, or non-personal data, will always be kept.
If you have any complaints or concerns for Athene, please get in touch with us using the information provided below. Within a reasonable amount of time, usually within 10 business days, we will address your issues.
Use of Tracking Mechanisms, including Cookies
Cookies and other tracking tools (such as tracking technologies created for mobile applications) are used by us and our third-party service providers to keep track of information about how you use our website and services. We may combine this data with other personal information we have about you (and our third-party service providers may do so on our behalf).
Cookies. Cookies are alphanumeric identifiers that we download to the hard disk of your computer through your web browser in order to keep track of certain information. While some cookies facilitate a quicker sign-in process or let us track your actions on our Website and Services, others assist us to make it easier for you to navigate our Website and Services.
Cookies may result in the communication of information to or from us, to you directly, to a third party working on our behalf, or to a third party in line with that third party’s privacy policy. We might combine the data we get about you through cookies. You have the option of turning off all cookies or having your device alert you each time one is transmitted. You accomplish this by using the browser’s options. Some of our services won’t work properly if you disable cookies since you won’t have access to various features that improve the efficiency of your visit. For details on how to control or disable browser cookies, please refer to the last part of this Cookies Policy.
We use a variety of cookie categories, and each serves a particular purpose. A resource website like allaboutcookies.org can teach you more about cookies and how they work in general.

Four different varieties of cookies exist:

Definitely required cookies.
These are cookies that are necessary for our website to function. For instance, they contain cookies that let visitors sign into our website’s secure parts.
cookies for performance analytics.
These cookie types enable us to recognize, count, and track the number of visitors to our website as well as their online behavior. By ensuring that you can quickly find what you’re looking for, for instance, this helps us improve how our website functions.

Cookie functionality
When you return to our website, these cookies help us recognize you. They make it possible to customize material, identify users, and keep track of user preferences (for example, your choice of language or region).

cookie targeting
These cookies keep track of the times you visit our website, the specific pages you view, and the links you click. This type of cookie may be used to track your travels between multiple websites and to compile profiles of your typical online activity if it is placed by a third party (for instance, an advertising network that also tracks traffic on other websites). Online advertising frequently uses the data gathered by tracking cookies to target specific consumers.

The four sorts of cookies mentioned above can either be temporary or persistent.
Temporary cookies. Only while an online session is active do session cookies exist. When you shut down your computer or close your browser, they vanish from it. While you are logged into the Website or Services or during a session, we utilize session cookies to enable our systems to uniquely identify you. As you go via our website or services, this enables us to execute your online requests and transactions and to confirm your identity after you have logged in.
enduring cookies After you have closed your browser or powered off your computer, persistent cookies continue to exist on your system. In order to be able to provide you with our services when you next visit our website or use our services, we utilize persistent cookies to remember your user information, preferences, and activity. Additionally, we track user activity using persistent cookies to compile statistical data that may be aggregated with other user data.
CSS3 Storage. We may also utilize HTML5 to locally save your user data and website preferences in your web browser.
Pixel tags, clear GIFs, and other technologies. Cookies-like in function, clear GIFs are tiny visuals with a distinctive identifier. Cookies are placed on your computer’s hard disk, whereas clear GIFs are hidden within online pages. Clear GIFs, sometimes known as web beacons, web bugs, or pixel tags, may be used in connection with our website or services for a variety of purposes, including monitoring visitor behavior, assisting with content management, and gathering usage data. To track email response rates, determine when our emails are viewed and whether they are forwarded, we and our third-party service providers employ clear GIFs in HTML emails to our clients.
Your cookie settings can be modified or disabled. Most web browsers accept cookies by default, but if you’d like, you can change your browser’s settings to do so going forward. You can prevent your computer from accepting new cookies, have the browser alert you when a new cookie is received, or completely disable cookies by following the instructions in the Help section of the toolbar on the majority of browsers. The majority of site features will not work if cookies are disabled, and you won’t be able to log in to use our services. You can withdraw consent to the placement of cookies at any time by accessing the Privacy Preference Centre on our website under “Cookies Settings.” Visitors to our website who disable their web browsers’ ability to accept cookies will still be able to browse the site. Please be aware that you must individually change your cookie settings for each device if you want to erase all cookies from all of your devices.

Managing Cookies Through Your Browser
You can control cookies and other tracking technology in a variety of ways. You may choose whether to accept cookies from websites you visit by modifying the settings in your browser, or you can instruct your browser to ask you before accepting a cookie. If you set your browser to completely block cookies, you should be aware that you might not be able to access all of our interactive features.
You must make sure that each browser is customized to your preferences if you use various computers in various locations.
Any cookies that have been set up can be removed or disabled from your browser’s cookie folder. Different methods are offered by different browsers to manage your settings. For instructions, click on any of the browser links below.
The Windows Explorer program
Using Chrome
Google Chrome
iOS Safari
If you do not use any of the browsers mentioned above, you should choose “cookies” from the “Help” menu to learn where to locate your cookie folder.
Additionally, you should be aware that deactivating cookies will not affect any other analytics tools we may use to gather statistics about how you and other visitors use our website.

Overview of Cookies
Remove the Hubspot cookies by clicking the button below.
Take away cookies
Type and objective
VENDOR
OPT-OUT

Definitely Required Cookies:
These session cookies are required for the site’s essential features, such as login, page access, and content authorization.
Pave
Privacy Athene Policy
Terms of Use for Athene
NO OPT-OUT:
Without certain cookies, the website will not work properly. They are not OPT-OUTABLE.
Analytics:
used to track and record the number of website visitors and to examine how they navigate the site (including number of page views, number of visitors, and time spent on each page). This enables us to monitor the operation of our application in order to enhance it and improve the functionality of our sites, such as ensuring that you can find what you need with ease.
Using Google Analytics
Policy on Privacy for Google Analytics
Their policy contains information on when they expire.
Terms of Service for Google Analytics

Amplitude:
Privacy Amplitude Policy
Conditions of Use for Amplitude

Mixpanel:
Mixpanel’s Privacy Statement
Conditions of Use for Mixpanel

NO TO OPT-OUT:
Make the necessary changes to your browser’s settings as outlined in the section above titled “DISABLING/ENABLING COOKIES VIA YOUR BROWSER.” Many times, providers provide direct opt-out solutions.
Opt-Out of Google Analytics
For your browser, add-ons

Functionality and Cookie Control:
used to manage the site’s Cookie OPT-OUT functionality
Search Engine Tag Manager
Privacy Statement for Google Tag Manager
Terms of Service for Google Tag Manager

NO OPT-OUT:
Other cookies on the system must be managed using this functionality. Without it, the site’s OPT-OUT option is inaccessible.
Functionality:

HelloBar:
Use to keep people logged in – Display advertising and information about new features and website problems to pertinent website visitors as a pop-up window.

HubSpot:
Targeted marketing automation is used to keep the user’s session active and to provide user support.

Plug-in for Elementor:
The marketing team at Pave employed a theme tool to develop the website’s marketing content.
HelloBar:
HelloBar’s Privacy Statement
Terms of Service for HelloBar

HubSpot:
Hubspot Privacy Statement
Terms of Service for Hubspot

Elementor:
Elements Privacy Statement
Terms of Service for Elementor
NO OPT-OUT

HelloBar:
Make the necessary changes to your browser’s settings as outlined in the section above titled “DISABLING/ENABLING COOKIES VIA YOUR BROWSER.” Many times, providers provide direct opt-out solutions.

HubSpot:
Click to decline.

Elementor:
Data purge guidelines
Advertising/Targeting:
These cookies have been created with the express purpose of gathering data from your device’s browser so that you can see advertising related to subjects that are of interest to you.
Amplitude:
Privacy Amplitude Policy
Conditions of Use for Amplitude

Mixpanel:
Mixpanel’s Privacy Statement
Conditions of Use for Mixpanel

Facebook:
Facebook’s Privacy Statement
Terms of Service for Facebook
NO OPT-OUT

Make the necessary changes to your browser’s settings as outlined in the section above titled “DISABLING/ENABLING COOKIES VIA YOUR BROWSER.” Many times, providers provide direct opt-out solutions.
Educating and Developing:

WalkMe:
used to create training materials for counselors, recruiter partners, and institutions.

Vidyard:
There will be video training materials available for the system.
WalkMe:
WalkMe Privacy Statement
Terms of Service for WalkMe

Vidyard:
Vidyard Privacy Statement
Cookie Policy for Vidyard
Terms of Service for Vidyard
NO OPT-OUT

Make the necessary changes to your browser’s settings as outlined in the section above titled “DISABLING/ENABLING COOKIES VIA YOUR BROWSER.” Many times, providers provide direct opt-out solutions.

Don’t Follow. Our systems do not currently respect browser “do-not-track” requests. However, you can stop some tracking as mentioned above (for example, by turning off cookies) and you can stop receiving targeted ads by third parties by following the guidelines in the Third Party Ad Networks section below.
Social media: We may provide you with the option to interact with our content on or through social networking sites, plug-ins, and applications operated by third parties. You may give us permission to access certain information from your social media account (such as your name, username, email address, and profile picture) when you interact with our content on or through third-party social networking websites, plug-ins, and applications. This access is necessary to deliver the content to you or to maintain the functionality of the website, plug-in, or application. Links to Other Websites: Our Website may contain links to other websites that Pave does not own or operate, including the websites of third-party partners. When you provide information from your social media account, we may use this information to personalize your experience on the Website and on the third-party social networking websites, plug-ins, and applications, as well as to provide you with other products or services you may request. Additionally, other websites that we advertise on may contain links to our website. We will not disclose any of your personal information to these third parties without your permission, with the exception of what is stated in this clause. As a service to the user, we offer connections to websites operated by third parties. These links are not meant to be recommendations or endorsements of the connected websites. We advise you to carefully read the privacy statements, notices, and terms of use on the linked websites since they are different and independent from one another. As a result of our lack of control over such websites, we disclaim all responsibility and liability for how your personal information may be gathered, used, disclosed, secured, or otherwise handled by the companies behind such linked websites.

Independent Analytics
To gather common internet log data, Pave makes use of the web analytics services provided by Google Analytics, Hubspot, Walkme, Hellobar, Amplitude, Mixpanel, and Freshpaint. These tools may make use of cookies to assist us in studying how users interact with the website. For instance, if you use Google Analytics, a Google server will receive and store the data the cookie creates on how you use the Website (including your IP address). This data is used by Google to analyze how you use the website, create reports on website activity for website owners, and perform other services for website owners related to website activity and internet usage. By downloading and installing the browser plug-in accessible at the following URL: https://tools.google.com/dlpage/gaoptout, you can stop Google from storing and processing the data related to your use of the Website and collected via the cookie (including your IP address). hl=en.
The URLs https://policies.google.com/technologies/partner-sites and https://support.google.com/analytics/topic/2919631 provide more information about data collection, processing, privacy, and security in Google Analytics.
In order to save processing times and eliminate processing errors in your chosen software application, Pave also employs Google OCR, or “Optical Character Recognition,” to turn your uploaded photos into text for data import into your preferred Pave applications.

Networks of third-party Ads
In order to display adverts on our website, help us display advertisements on other websites, and assess the effectiveness of our advertising campaigns, we employ third parties like network advertisers and other marketing agents. On the basis on your visits to our Website and unrelated third-party websites, network advertisers are companies that show adverts on third-party websites. By presenting adverts for goods and services you might be interested in, this enables us and these third parties to target advertisements to you. Cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs, and other technologies may be used by third-party ad network providers, advertisers, sponsors, and/or traffic measurement services to measure the performance of their ads and to tailor advertising content for you. The privacy policies of each individual third party, not this one, apply to these third-party cookies and other technologies. In addition to aggregate or non-personally identifiable data on visitors to our website and users of our service, we might give these third-party marketers information about how you use our website and services.
Opting out of Interest-Based Advertising: Please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices for more information about Interest-Based Advertising and to understand your options, including how to opt-out of receiving Behavioral Ads from Third-Party Advertising Companies Participating in the Digital Advertising Alliance of Canada.
You will still see ads from us even if you choose to opt out of interest-based advertising from third parties, but they won’t be targeted based on your behavior and may be less relevant to you and your interests. Please note that even if you choose to opt out of analytics, these tracking technologies may still collect data for other purposes.
You must have cookies enabled in your web browser in order to correctly opt out; for more information on cookies and how to activate them, consult the instructions for your browser. You must opt out of each online browser on each computer you use because your opt-out only applies to the web browser you are currently using. You will have to opt out again if you clear the cookies that your browser has saved after opting out.
Custom Audience: We may also use third-party platform services (such as social networking and other websites) to show you or other people tailored adverts on those platforms. To do so, we may give the platform provider a hashed version of your email address or other information. Please get in touch with us at info@Pave.com if you’d prefer that we not utilize your information for such purposes.

Data Storage
Your personal information will only be kept by Pave for as long as necessary to fulfill the purposes for which it was obtained, or as otherwise permitted or required by law or contract (which may extend beyond the termination of our relationship with you).
Personal data is typically kept for up to a year after we last communicated with you or as long as you are enrolled in the institutional program you applied to. We might keep some information if it’s necessary for:
legitimate commercial objectives, such as account recovery and auditing;
if mandated by relevant national, state, local, or other legislation;
to stop fraud or abuse in the future, or
by agreement with a party and/or organization.
All collected personal information is handled in line with this Privacy Policy.
Due to technological and regulatory limitations, it might not be feasible to entirely delete all of your personal data if you ask for it to be removed from our databases and/or systems. However, we will take reasonable measures to ensure that the information is securely destroyed, deidentified, and/or anonymized as needed.
You will be approving the expansion of the data collection and/or processing purpose if you ask Pave for further services that are covered by this privacy statement.
Documents from ApplyProof will be kept for as long as they are required by law or contract, or as long as they are required for the intended purpose (which may extend beyond the termination of our relationship with you).
The organization, student, or institutional partner that uploaded the file(s) for verification may ask for the early removal of such materials. This is most likely to happen when a content update or correction is necessary.

Modifications to Our Privacy Policy
This policy could alter at any time. Future modifications will be announced on our website and, as necessary, you will be notified by email or through your “My Account” section of our website.
We strongly advise you to return often to see any updates or modifications to our Policy. Your rights under this Policy will not be considerably reduced by us unless we first take efforts to notify you of any changes.

Questions? Contact Us. Updating Your Information. Opting Out
If you are a customer of Athene Services and would like to update your personal information, please log into “My Account” to do so or get in touch with us using the details provided below. If you would like to amend your personal information and you are not a customer of Pave Services but have given us personal information or if third parties have given us your personal information, you can get in touch with us at the phone number or email address provided below. Periodically, we might email you or send you a special offer; you can choose not to receive those emails by clicking the link in the email or contacting us as listed below.

Contact our Data Privacy Officer if you want to:
You have any queries or remarks regarding this privacy statement.
You are unable to access, amend, or correct inaccurate information about you but would like to, or
You also have a query or a grievance regarding how we or our service providers handle your personal data.
You can email our data privacy officer at info@atheneeducation.com or send a letter to the following address to reach them:
Athene Inc
118, FAAN Staff Quarters, Ikeja Along Bustop, Ikeja, Lagos 

Freephone number: 234 80 87928523
Additional Terms for EEA and UK Customers, Appendix 1
According to EEA privacy and data protection regulations, the following details are necessary. In addition to the terms in the rest of the Policy, the terms below also apply to our customers and website visitors in the EEA and the UK.
In accordance with the General Data Protection Regulation (GDPR), Athene of 101 Frederick Street, Suite 600, Kitchener, Ontario, N2H 6R3, Canada, is the data controller. Please send an email to info@atheneeducation.com to reach our Data Protection Officer (DPO) if you have any issues regarding this policy.
You have the right to complain to your local supervisory authority if you are dissatisfied with how we are handling your data or how we handled a request or complaint.

WHICH PERSONAL DATA DO WE SHARE AND WHEN?
Who we may share your information with is listed in the table titled “How and Why We Share Your Information” in the main section of the Policy under the heading “WHEN DO WE SHARE YOUR INFORMATION,” which includes transfers for reasons of legal compliance and necessity in order to provide you with our Services.
When providing information, you should be aware that it might be sent to and stored in locations outside the EEA or the UK, as appropriate.
Please be aware that non-EEA countries may not provide the same degree of protection for personal data as is offered in the EEA in cases when data is moved outside of the EEA. Pave will take a number of steps to safeguard the security of your data, including but not limited to:
examining the security procedures implemented everywhere your personal data is moved;
having a contract in place with adequate terms requiring a data processor to only process our instructions;
putting in place monitoring, reporting, and resolution processes for continuing security;
Your data will only be transferred if an adequate protection is used, as defined in Article 46 of the GDPR, such as Standard Contractual Clauses issued by the European Commission (Article 46.2)
Email us at info@atheneeducation.com to get in touch. if you want more specific information about how your personal data is transferred internationally and the specific security measures employed.

PERSONAL DATA PROCESSING LEGAL FOUNDATIONS
According to the following legal justifications and in accordance with the relevant data protection regulations, we process your personal data:
The processing is required to fulfill the terms of our agreement with you (i.e., the Terms and Conditions that apply as they relate to Pave Services, for the provision of our Services), or to carry out your pre-contractual requests;
You must give us your personal information in order for us to enter into and carry out our contractual obligations. We won’t be able to carry out our contractual obligation to you if you choose not to give us your personal information for the reasons listed above in the “How and why we use your information” section;
The processing is done in order to further the legitimate interests of Pave or another party, and your rights or interests in maintaining the privacy of your personal information do not conflict with those purposes. This may entail processing your data for internal analytics and research evaluations, fraud protection, communicating with you, alerting you of new products and services we are offering, or promoting new products and services of other parties we believe you may find interesting;
We carefully examine the impact of our processing activities on your fundamental rights and freedoms before processing your personal data to further our legitimate interests for the reasons listed above in the “How and why we use your information” section. Overall, we’ve come to the conclusion that this processing is required for our legitimate purposes and that it doesn’t negatively affect these rights and freedoms.

You have granted permission for the processing of your personal data;
The processing is required to fulfill a legal requirement that pertains to Pave.
We may use one of the following grounds for processing data about you that the law classifies as belonging to a special category (see “What Data Do We Process About You?” for more information).
establishing, exercising, or defending legal claims requires the processing;
You specifically and voluntarily provided your informed consent to the processing; or
According to current law, the processing is required for grounds of great public interest.
Please get in touch with us if you have any questions about the legal justifications for processing your information or the aforementioned legitimate interests.
You have the right to revoke your consent at any moment if we have requested it and you have given it for us to process your personal data. You can reach us at info@pavehq.com to accomplish this.

ARE YOU REQUIRED TO PROVIDE US WITH YOUR PERSONAL DETAILS?
Most of the time, giving us your personal information is voluntary, but if you choose not to, you won’t be able to access our services. For instance, in order to send and receive payments from you, we require information such your name, address, and bank account information. You can decide whether we collect your personal information in other situations. For instance, you can turn off cookies in your browser to prevent us from installing any cookies on your device or computer (although in this case you may not be able to use all parts of our Website).

AUTOMATED DECISION MAKING AND PROFILING
For the Pave Services, automated decision-making is used. In order to assess security and risk related to the provision of the Pave Services and to prevent fraud, we employ the following tools:
Automated technologies that are part of our process for approving your application may let you know whether further information is needed in order to proceed. This depends on the information you submitted.
Automated tools are used in our approval process for particular schools or programs. These tools can determine eligibility or suggest further information that may be needed.

PERIOD OF STORAGE FOR YOUR PERSONAL DATA
Your personal information will only be kept by Pave for as long as necessary to fulfill the purposes for which it was obtained, or as otherwise permitted or required by law or contract (which may extend beyond the termination of our relationship with you).
Personal data is typically kept for up to a year after we last communicated with you or as long as you are enrolled in the institutional program you applied to. We might keep some information if it’s necessary for:
legitimate commercial objectives, such as account recovery and auditing;
if mandated by relevant national, state, local, or other legislation;
to stop fraud or abuse in the future, or
by agreement with a party and/or organization.
All collected personal information is handled in line with this Privacy Policy.
Due to technological and regulatory limitations, it might not be feasible to entirely delete all of your personal data if you ask for it to be removed from our databases and/or systems. However, we will take reasonable measures to ensure that the information is securely destroyed, deidentified, and/or anonymized as needed.
You will be approving the expansion of the data collection and/or processing purpose if you ask Pave for further services that are covered by this privacy statement.
Documents from ApplyProof will be kept for as long as they are required by law or contract, or as long as they are required for the intended purpose (which may extend beyond the termination of our relationship with you).
The organization, student, or institutional partner that uploaded the file(s) for verification may ask for the early removal of such materials. This is most likely to happen when a content update or correction is necessary.

RIGHTS UNDER THE GDPR
The rights you have in connection to your personal data are broken down in further detail below. Contact us at info@atheneeducation.com at any time to exercise your rights.
getting to your data
You can request that we:
Verify if we are processing your personal information.
Give you a copy of the private information.
Give you more details about your personal data, including what we have, how we use it, who we disclose it to, whether we transfer it outside of the EEA, how we protect it, how long we keep it, your rights, how to complain, where we got your data from, and whether we use automated decision-making or profiling. If anything in this Policy is unclear, please contact our Data Protection Officer at info@atheneeducation.com. We try to provide all of this information to you.
Except in cases where your request is unreasonable, repetitive, or excessive, in which case we may impose a reasonable price under the circumstances, you are not required to pay a fee for a copy of your personal data. Any fees will be disclosed to you before we fulfill your request.

updating your personal information
You have the right to request that we rectify any inaccurate or incomplete personal information (in most cases you will be able to make these changes yourself by logging into your account). It’s free to do this.
Wherever possible, we shall notify anybody with whom we have shared the personal data of the correction.
If we are unable to comply with a request to update your personal information, we will inform you and provide a justification.
deleting personal information
The “right to be forgotten” is another name for this privilege. You have the right to have your data deleted without charge in some situations, but this is not a fundamental right.
Where can you make a request to have your personal data removed?
it is no longer required for the original reason information was gathered or processed;
Despite your withdrawal of consent, we continue to process your personal data;
You object to the processing of your personal information, and there is no compelling legitimate reason for us to continue;
It has undergone improper processing;
it must be deleted to satisfy a legal requirement;
It was prepared to provide a child with services from the information society.
This right is subject to several limitations. We are not required to remove the personal data if one of these situations applies.
We shall notify any third parties with whom we have disclosed your personal information if we have done so unless doing so is impractical or would require an unreasonable amount of work.
Please be aware that in conjunction with such requests, depending on technological and commercial capability, personal data may either be erased or stored in an aggregated form without being linked to any identifiers or personal data.
limiting how your personal data is processed
You can request a free restriction on how we can use your personal data in certain situations. This isn’t a fundamental right. Unless you consent, the processing is required in connection with a legal claim, to protect the rights of another person, or for important public interest, we can store the personal data and retain enough information to ensure the restriction is respected, but we cannot further process your data if processing is restricted.
In the following circumstances, you may limit how your personal data is processed:
If you question the veracity of your personal information, we will halt processing until we have determined that it is true;
if you object to our processing while we determine whether our interests are justified and outweigh yours, your rights, and your freedoms, or in connection with a judicial procedure;
if the processing of your personal data is unlawful but you do not want us to delete it;
if you need the personal information to make, use, or defend a legal claim but we no longer need it.
In the absence of impossibility or unreasonable effort, we will notify any third parties to whom we have supplied the data of the restriction. If we decide to remove a restriction on processing your personal data, we will let you know.
Refusing to have your personal data processed
The processing of your personal data is subject to your right to object at any time. There will be no price for this request. You can object to our processing of your personal data in the following circumstances, albeit it is not an absolute right:
based on the theory of justifiable interest; or
for statistical and historical/scientific research objectives.
If we no longer need to process your personal data for the establishment, exercise, or defense of legal claims, we will stop doing so unless we have compelling legitimate grounds for the processing that outweigh your interests and rights.
You have the right to request that we stop using your personal information for direct marketing. If you ask us to cease, we will do so as quickly as possible, but we might not be able to do so for any ongoing direct marketing efforts. There aren’t any exceptions or justifications for us to say no.

Portability of Data
This makes it possible for you to get and reuse your personal data across many services for your own needs. When the aforementioned requirements are satisfied, it applies:
You yourself gave us the personal information;
We are processing your personal information either with your permission or because it is required to carry out a contract; and
Automated tools are used to carry out the processing.
Your personal information will be given to you without charge in a format that is machine-readable, generally used, and structured.
automated judgments and profiling
You have the right to be free from decisions that are exclusively the result of automated processing and have a major impact on you legally or otherwise.
Any automated decision-making that has an impact on you will be disclosed to you. You are entitled to:
request assistance from people;
express your viewpoint;
enquire about the reasoning behind the choice; and
contest the judgment.
These privileges are not unqualified. If the processing of your personal data is as follows, we might not be able to comply with your request:
necessary for us to make a deal with you or to carry it out;
authorized by law (for example, to prevent fraud), which also specifies appropriate safeguards for your rights, freedoms, and legitimate interests; or
dependent on your express permission.
addressing demands for rights exercise
Unless it is particularly complicated or you have made multiple requests, we will respond to your request without undue delay and, at the latest, within one (1) month of receiving it. In these cases, we may extend this deadline by two (2) months. If processing your request will take longer than one (1) month, we’ll let you know. If we know a lot about you, we might ask you to be more specific about what you want to receive. By doing this, we can handle your request more quickly.
We will carry out the required internal procedures to identify you in order to abide by your requests to exercise the aforementioned rights.