- SMILE - SCHOLARSHIP FOR MOBILITY AND INTERNATIONAL LEARNING EXPERIENCE

At ASEANGEMS, we deeply believe in the protection of your data and privacy and we care how it applies to you, as a user of our website(s). In this Privacy Policy (‘Policy’), you can find information about how, whether, and why we collect and use your personal information on our website. This Policy applies to any personal information that is gathered when you use our services, visit our Website, or otherwise interact with us. We have divided this Policy into different sections. Please go to the relevant section below for further information. The processing of your personal data complies with the General Data Protection Regulation (‘GDPR’), the Dutch GDPR Execution Act and the Dutch Telecommunications Act.

Types of personal data we process

General

We may collect and process, whether or not on our own behalf or on behalf of one or more educational institutions, the following categories of personal information:

Name, email address and other identifying information

For example, we may record your name, email address, gender, date of birth, nationality, country of residence, education history,or achievements. If you opt to use our Scholarship Match tool, we may also record your financial situation to provide better scholarship recommendations.
Your contact details and personal account/registration details

Your contact details may include: your address, telephone number, and email address. When you create a personal account, we may also record your sign-in details and other information you provide when you create your personal account or fill in a registration form.
Our communication with you

When you send us an email, or chat with us online or via social media, we save your correspondence with us.
Information we collect when you use our Website
- When you visit our Website or use our services, we may register your IP address, browser type, operating system, referring website, web-browsing behaviour and (AI) – chat history.
- We may receive an automatic notification when you open (or open a link from) a newsletter.
Information in relation to social media

Depending on your social network settings, we may receive information from your social network provider. For example, when you sign in for our services using a social network account, we may gather publicly available information you give us access to from your social network profile, including your contact details, interests, and social network. For more information on the personal data that we receive from your social network provider, and how to change your privacy settings, please refer to the website and the privacy policy given by your social network provider.

Cookies and similar technologies

When you use our Website for the first time, a cookie notice is shown. ASEANGEMS uses the information collected through cookies strictly for the purposes stated in the Cookie Statement, found below.

The use of Artificial Intelligence

ASEANGEMS uses AI-methodology within the chat-services. Currently, only your location and nationality are used to provide personalized results. Your input during the chat is utilized solely to improve your specific session. Your input is not used to train the general AI-model. None of your personal data or user behavior data is submitted into the AI tool. ASEANGEMS can decide to add additional profile information to further personalize the conversation.

How we collect your data

ASEANGEMS collects personal information in a number of ways. Information is obtained, for example, when you visit our Website, register on our Website, communicate with us via social media, or subscribe to our newsletter.

Additionally, ASEANGEMS may receive personal information from partner educational institutions, affiliated organizations, and service providers to improve scholarship matching and service delivery.

We may also access publicly available data from users’ social media profiles, such as Google account profile information, when users log in via Gmail.

Purposes of processing your data

We process personal information for the following purposes:

Providing services to you

ASEANGEMS processes personal data to provide our services. For example, personal data is processed so, for example:

Based on the country or field of study that you choose, we can send you programme recommendations that we believe best match your profile;
To make your user experience easier and more effective, we may assess how you use our services, and combine this data with information collected via your personal account, registration details, cookies, and similar technologies. This combination enables us to, for example, optimize our search algorithms, assess your admission chance or match with particular education opportunities;
Collected data are also used to pre-fill scholarship application forms, allow document uploads, and manage submission processes efficiently. Personal data may also be shared with scholarship providers or educational institutions solely for application processing purposes.

For these purposes, ASEANGEMS processes the following personal data: name, digital contact details, demographic information, shortlisted programmes, disciplines and countries of interest, funding situation, preferred start period, previous education information.

ASEANGEMS is allowed to process personal data for these purposes for pursuing its own legitimate interest or those of the educational institutions; with the legitimate interest being to allow ASEANGEMS to provide the best service it is able to, in order to align you with the educational institutions of your choice.

To communicate with you

ASEANGEMS processes contact details to communicate with you, answer your questions, or handle your complaints. This applies to both students and (potential) clients/customers/partners.

For this purpose, ASEANGEMS processes the following personal data: communication history, name, digital contact details, message. For (potential) clients, the following data is also processed: phone number, employer, country.

ASEANGEMS is allowed to process personal data for this purpose to pursue its own legitimate interests or those of the educational institutions; with the legitimate interest being ASEANGEMS to be able to communicate with you for providing the best service it can to align you with the educational institutions, scholarship providers, test providers and other service providers of your choice. Especially, the legitimate interest services is that ASEANGEMS, an educational institution or other service provider concerned, can respond in an effective and timely manner to any questions or complaints you might have.

For processing scholarship applications for specific universities

ASEANGEMS processes personal information to enable students to apply for specific scholarships through our website rather than through the university website. For this processing of your personal data information, ASEANGEMS will act as a mere processor processing your information on behalf of the educational institution concerned.

For this purpose, ASEANGEMS processes the following personal data on behalf of the educational institution: name, digital contact details, analog contact details, passport, educational transcripts, CV, various credentials (e.g. CGPA, English language proficiency), demographic information, shortlisted programmes, disciplines and countries of interest, funding situation, preferred start period, previous education information.

ASEANGEMS is allowed to process personal data for this purpose because it is necessary for pursuing the legitimate interests of the educational institutions; with the legitimate interest being ASEANGEMS to be able to communicate with you for providing the best service it can to align you with the scholarships of your choice.

Allowing you to post threads and questions

ASEANGEMS processes personal data when a user submits a thread or question on the platform, particularly within the community forum or discussion spaces.

For these purposes, ASEANGEMS may process the following personal data (whether or not through direct input or associated profile information): the content of the thread or question, any stated experiences or opinions related to scholarships, educational institutions, or study programs, and any other identifiers or references included in the post.

All submitted threads and questions are subject to review by the ASEANGEMS moderation team—either manually or automatically—to ensure quality, authenticity, and alignment with our community guidelines.

ASEANGEMS will make posts publicly visible only after this review process. Posts may be removed or not published if they fall under the following circumstances:

The user is proven not to have engaged with the topic in a genuine or verifiable way (e.g., did not participate in the program, institution, or scholarship they are referring to).
The content includes offensive language, swearing, discriminatory remarks, or threats.
The post expresses political, sexual, religious, or ethical viewpoints in a way deemed inappropriate for the platform.
The post promotes illegal activity, advertising, spam, or unrelated commercial services.
The submission is not based on personal experience or clearly lacks relevance.
Posts repeatedly target other users or groups in a hostile manner.
The submission includes personally identifiable contact details (e.g., phone numbers, email addresses, physical addresses), external URLs, or links to competing platforms.
The user is impersonating another individual or organization.
ASEANGEMS suspects that the submission is not authentic (e.g., was generated to manipulate perception or ratings).
The content infringes on the rights of another individual or organization, including but not limited to privacy rights and intellectual property rights.
The submission was coerced under threat or undue influence.
The thread or question lacks substance or fails to offer informative value relevant to the community.

These guidelines are in place to ensure that ASEANGEMS remains a secure, respectful, and reliable space for scholarship seekers across the ASEAN region.

For direct marketing purposes

ASEANGEMS processes personal information for (direct) marketing purposes. This means we may use your personal information to send you newsletters, promotions, or other marketing communications. We use the results of our analysis to tailor our marketing communications to your specific interests and preferences. For example, if our analysis shows that you may be interested in certain types of programmes or a specific country, we may customize our newsletter and Website with content that are relevant to you. We may use different channels for our marketing communications, such as email, social media, and your personal account.

For this purpose, ASEANGEMS processes the following personal data: name, digital contact details, demographic information, shortlisted programmes, disciplines and countries of interest, funding situation, preferred start period, previous education information, IP address, cookies and comparable services, browser, device specifications, referring website, browsing behaviour and website interactions, social media likes.

We may also combine such aggregated data with information we receive from our subsidiaries, educational institutions, or from public sources.

ASEANGEMS is allowed to process personal data for this purpose because you gave consent or because ASEANGEMS has a legitimate interest. The consent can be withdrawn at any moment, and you can object at any moment to the processing of your personal data for direct marketing purposes when such processing is based on ASEANGEMS or the educational institutions’ legitimate interest. The withdrawal of consent or exercise of your right to object does not affect the lawfulness of the processing prior to the moment of withdrawal or exercise of the right to object.

You may object or revoke your consent for receiving marketing communications at any time, by following the instructions in the relevant marketing communication or by sending an email to us.

Disclosing or sharing data with third parties

General

We reserve the right to release personal information without your consent or without consulting you, when we deem it necessary to comply with our legal obligations, to enforce our terms and conditions, to protect the security of this Website, or to prevent fraud.

Other institutions or businesses

You can contact education institutes through our Website, by means of an electronic form. The details in your inquiry will then be shared with the institute you are trying to contact.

We may share personally identifiable information (such as name, nationality, and email address) with carefully selected education institutions, to verify the status of your application or enrollment, evaluate and manage the performance of our business agreements or initiate new agreements. Some of these institutions may also have access to your information so that they may consider further marketing campaigns or recruitment measures. We will inform the education institutions that they are not allowed to use your personal information for any reason other than mentioned above. Users should note however that, how these educational institutions use this data is not governed by our privacy policy. Therefore, we cannot be held responsible for how the data is utilized once it is shared with them. Educational institutions have separate policy practices for which ASEANGEMS has no responsibility or liability. For further information on how such institutions use your information, please visit the applicable privacy policy of that institution.

Third party websites

Our Website may contain links to third-party websites. If you follow these links, you will exit our Website. This Policy does not apply to third-party websites. ASEANGEMS cannot accept liability for the ways in which these third-party websites use of your personal data. You use these websites at your own risk.

Other countries

ASEANGEMS may share your personal data with partners, educational institutions, and scholarship providers located outside of your country of residence. This may be necessary as part of our services to match you with international scholarship opportunities or to support your application to educational institutions abroad. Where such transfers occur, they are carried out under strict conditions. In most cases, the organizations we share data with are bound by written and signed Data Processing Agreements that clearly define how they may use, protect, and store your data. These agreements ensure that your personal information is handled securely and only for the specific purposes permitted by ASEANGEMS. Some of the countries where your data may be transferred might not offer the same level of data protection as your home country. In such cases, ASEANGEMS ensures that adequate safeguards are in place, such as standard contractual clauses or explicit consent from you, to allow the secure transfer of personal data in compliance with applicable privacy regulations. ASEANGEMS does not systematically store your data outside of the region unless it is necessary for delivering services. If your data must be transferred internationally, we ensure that appropriate measures are taken to protect your privacy at all times.

If you contact, apply to, or enroll with a scholarship provider or educational institution through ASEANGEMS that is located outside your country of residence, your personal data will necessarily be transferred to that country.

Security and retention

ASEANGEMS takes the safeguarding of your information very seriously. ASEANGEMS will take appropriate technical and organizational measures to protect your personal data against loss or unlawful use. These measures include but are not limited to: facilities protected by appropriate security measures, encryption of devices, version tracking and access to our databases is limited to key personnel and IP addresses and use of it is logged. Personally identifiable information and account activity are also protected through the use of user names and passwords. In order to help maintain the security of your information, you should protect the confidentiality of your user name and password.

Your personal data will be retained for as long as required for the purposes described in this Policy, or insofar as is necessary to comply with our contractual or statuary obligations, and to solve any disputes. In most cases, your personal data will be retained for forty-eight (48) months after your last activity, or until you request deletion. ASEANGEMS retains your data for that period to optimize their services to you throughout your educational period, which statistical research has shown to usually span a period of more than thirty-six (36) months.

Modifications to this Policy

This Policy is effective as of 19 June 2025 . We reserve the right to alter or otherwise make changes to this Policy. We will notify you of any changes by posting the revised policy on our Website and notifying you through a banner or in case of very material changes to the Policy, via email. Changes take effect as soon as the Policy is posted.

By registering and using the ASEANGEMS platform, the user (“Data Subject”) expressly consents to the collection, processing, and cross-border transfer of their personal data and scholarship-related information by ASEANGEMS and its authorized partners within the ASEAN region. This consent is given voluntarily, knowingly, and explicitly in accordance with applicable data protection laws and regulations, including but not limited to the ASEAN Framework on Personal Data Protection, the Personal Data Protection Act (PDPA) of individual ASEAN member states, and relevant international data privacy standards.

Purpose of Data Collection and Sharing

The personal data collected through ASEANGEMS will be used solely for purposes directly related to the operation and facilitation of scholarship programs across ASEAN member countries. These purposes include:

Facilitating the matching of scholarship opportunities to eligible students based on their profiles and preferences
Enabling scholarship providers, educational institutions, and governmental bodies within ASEAN member states to access necessary applicant information for assessment, selection, and award processing
Supporting intra-ASEAN student mobility initiatives to promote regional educational cooperation and integration
Communicating relevant updates, notifications, and decisions concerning scholarship applications
Conducting administrative, monitoring, evaluation, and audit functions to enhance program effectiveness and compliance

Types of Data Shared

The data shared may include personal identifiers (name, date of birth, contact details), academic records, scholarship preferences, application materials (such as essays, transcripts, and supporting documents), and any other data voluntarily provided by the user in connection with scholarship applications.

Cross-Border Data Transfers

Personal data collected on the ASEANGEMS platform will be transferred and processed across various ASEAN member countries where scholarship providers and partners are located. These transfers are conducted with adequate safeguards in place, including binding agreements with recipients, adherence to ASEAN data protection principles, and implementation of technical and organizational measures to ensure data confidentiality and security.

Data Security and Confidentiality

ASEANGEMS employs industry-standard security measures to protect users’ data against unauthorized access, alteration, disclosure, or destruction. Access to personal data is restricted to authorized personnel and entities involved in scholarship administration and is governed by strict confidentiality agreements.

User Rights and Control

Users retain full control over their personal data and have the following rights under applicable data protection laws:

The right to access, review, and obtain a copy of their personal data held by ASEANGEMS
The right to rectify or update inaccurate or incomplete data
The right to withdraw consent at any time, understanding that such withdrawal may limit access to certain services or scholarship opportunities provided by the platform
The right to request erasure of personal data, subject to legal and contractual obligations
The right to lodge complaints with relevant data protection authorities if they believe their rights have been violated

Contact and Support

For any questions, requests, or concerns related to data privacy or this consent, users may contact ASEANGEMS’ Data Protection Officer.

By continuing to use ASEANGEMS and submitting personal information, the user confirms that they have read, understood, and agreed to the terms of this consent regarding cross-border data sharing and processing.

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