Legal

PRIVACY
POLICY.

Globridge Pathways Ltd.Effective: 01 May 2025Version: 1.0

This document is the official and legally binding Privacy Policy of Globridge Pathways Ltd. All staff, partners, and associates are required to read, understand, and adhere to its provisions.

01

Introduction & Commitment

Globridge Pathways Ltd. (hereinafter referred to as "Globridge," "we," "us," or "our") is a premier educational consultancy firm committed to guiding students toward the best global academic opportunities. We operate under a strict Zero-False-Promise Policy, and that same ethos extends fully to how we collect, manage, protect, and respect personal data.

This Privacy Policy governs the collection and use of personal information provided by students, parents, guardians, institutional partners, and website visitors (collectively referred to as "Data Subjects") in connection with our services. By engaging with Globridge Pathways — whether in person, through our website, via social media, or through any digital platform — you unconditionally agree to the terms outlined in this Policy.

We treat your privacy not as a legal obligation alone, but as a fundamental right and a cornerstone of the trust-based relationship we build with every student and family we serve.

02

Scope of This Policy

This Policy applies to all data collected through the following channels and operations:

  • Walk-in and in-person consultations at our offices
  • Online inquiry forms, landing pages, and our official website
  • Email, WhatsApp, phone calls, and social media communications
  • University application submissions and documentation handling
  • Visa processing and embassy documentation support
  • Scholarship application assistance
  • Agent, affiliate, and institutional partner interactions
  • Internal HR and recruitment processes for staff

This Policy does not apply to third-party websites, platforms, or services linked from our website. We encourage users to review the privacy policies of such external parties independently.

03

Categories of Personal Data Collected

Student & Applicant Data

  • Full legal name, date of birth, and national identification details
  • Contact information: phone, email, residential address
  • Academic records: transcripts, certificates, test scores (IELTS, TOEFL, SAT, GRE, GMAT, etc.)
  • Passport and visa documentation
  • Financial documents: bank statements, sponsorship letters, income proof
  • Statement of Purpose (SOP), recommendation letters, and personal essays
  • Health and medical records (only when required by the destination institution or embassy)
  • Immigration history and travel records
  • Counselling session notes and preferred study destinations

Parent / Guardian Data

  • Name, contact information, and relationship to student
  • Financial capacity and sponsorship documentation
  • Communication preferences

Website & Digital Data

  • IP address, browser type, device information
  • Pages visited, session duration, and referral source
  • Cookies and tracking data (subject to cookie consent)
  • Form submissions and inquiry details

Partner & Institutional Data

  • Authorized representative names and contact details
  • University or institution affiliation details
  • MOU, commission, and contractual documentation
04

Lawful Purpose of Data Collection & Processing

Globridge Pathways collects and processes personal data solely for the following lawful, specific, and legitimate purposes:

  • Providing personalized educational counselling and destination guidance
  • Assessing student eligibility for institutions, programs, and scholarships
  • Preparing, submitting, and tracking university and college applications
  • Coordinating visa applications, document authentication, and embassy submission
  • Communicating application status, deadlines, and required action items
  • Facilitating financial documentation and scholarship processing
  • Maintaining a verifiable student journey record for quality assurance
  • Marketing and outreach — only with explicit prior consent
  • Internal analytics and process improvement
  • Legal compliance, audit, and regulatory obligations

We strictly adhere to the principle of data minimization — we collect only what is necessary for the stated purpose. We do not collect sensitive personal data (e.g., religion, political affiliation, biometric data) unless specifically required by an institution or embassy and with your explicit written consent.

05

Data Storage, Protection & Security Protocols

Globridge Pathways implements rigorous, multi-layered data security standards to ensure that your personal information is protected at all times.

Physical Security

  • All physical documents containing personal data are stored in locked, access-controlled filing systems
  • Only authorized personnel with a verified need are permitted to access physical records
  • All document disposal follows a certified shredding and destruction protocol

Digital Security

  • All digital data is stored on password-protected, encrypted systems
  • Role-based access control (RBAC) ensures employees only access data relevant to their function
  • Regular security audits and vulnerability assessments of all digital infrastructure
  • Two-factor authentication (2FA) required for all staff accessing the CRM and student databases
  • No personal data is stored on personal or unmanaged employee devices

Data Breach Response

  • Immediately isolate and investigate the breach within 24 hours
  • Notify all affected Data Subjects within 72 hours of confirmation
  • Report to relevant regulatory authorities as required by law
  • Document the incident and implement corrective measures
  • Conduct a full post-incident review and staff retraining
06

Data Sharing & Disclosure Policy

Globridge Pathways operates under a strict need-to-share basis. Your personal data is never sold, rented, traded, or commercially exploited. We may share data only in the following controlled circumstances:

Authorized Disclosures

  • Universities and colleges to which a student has formally applied — with student consent
  • Visa processing authorities, embassies, and immigration departments — as legally required
  • Authorized scholarship bodies — only with specific student instruction
  • Certified document attestation and notarization services
  • Partner institutions under active Non-Disclosure Agreements (NDAs)

Legal Disclosures

We may disclose personal data without consent when required by:

  • A valid court order or subpoena
  • Regulatory authority mandate under applicable Bangladeshi or international law
  • Law enforcement request in connection with fraud, crime, or national security

Prohibited Disclosures

  • Data is NEVER sold or disclosed to advertising companies or third-party marketers
  • Data is NEVER shared with unauthorized agents, brokers, or affiliates
  • Data is NEVER transferred outside Globridge's approved partner ecosystem without written consent
07

Data Retention Policy

We retain personal data only for as long as necessary to fulfill the stated purpose, meet legal obligations, or resolve any disputes.

Data TypeRetention Period
Active student filesDuration of engagement + 5 years
Visa & immigration documents7 years post-application
Financial records7 years (regulatory requirement)
Marketing consent recordsUntil consent is withdrawn
Website & analytics data24 months
Staff & HR recordsDuration of employment + 7 years

Upon expiry of the retention period, all data is securely deleted or anonymized. Physical records are shredded; digital records are permanently deleted from all systems including backups.

08

Rights of Data Subjects

Globridge Pathways fully respects and actively upholds the rights of every individual whose data we hold. As a Data Subject, you are entitled to exercise the following rights at any time:

  • Right to Access — Request a copy of all personal data we hold about you
  • Right to Rectification — Request correction of any inaccurate or incomplete data
  • Right to Erasure — Request deletion of your data (subject to legal retention obligations)
  • Right to Restrict Processing — Limit how we use your data in specific circumstances
  • Right to Data Portability — Receive your data in a structured, machine-readable format
  • Right to Object — Object to processing for marketing or profiling purposes
  • Right to Withdraw Consent — Revoke any previously given consent at any time, without affecting prior lawful processing

To exercise any of these rights, submit a written request to: privacy@globridgepathways.com. We will acknowledge your request within 3 business days and respond in full within 15 business days. No fees will be charged for exercising these rights.

09

Cookie & Tracking Technology Policy

Our website uses cookies and similar technologies to enhance user experience, analyze traffic, and measure campaign performance. By continuing to use our website, you consent to our use of cookies as described below.

Types of Cookies We Use

  • Strictly Necessary Cookies — Essential for website functionality; cannot be disabled
  • Performance & Analytics Cookies — Help us understand how visitors interact with our site (e.g., Google Analytics)
  • Preference Cookies — Remember your settings and choices
  • Marketing Cookies — Used only with explicit consent; track engagement with our campaigns

You may manage, disable, or delete cookies at any time through your browser settings. Disabling certain cookies may affect website functionality.

10

International Data Transfers

As an international educational consultancy, Globridge Pathways regularly handles applications and submissions to institutions across the United Kingdom, United States of America, Canada, Australia, Germany, Malaysia, and other destination countries. In the course of these services, personal data may be transferred internationally.

All international transfers are conducted:

  • Only to institutions and embassies with established data protection frameworks
  • Under binding contractual obligations where no formal framework exists
  • With full disclosure to the student and, where applicable, explicit written consent
  • In compliance with applicable cross-border data transfer regulations
11

Protection of Minors (Under 18)

Globridge Pathways serves students of all ages, including minors applying for undergraduate and pre-university programs. We take the protection of minors' data with the utmost seriousness.

  • All data collection from students under 18 requires verified written consent from a parent or legal guardian
  • Minors' data is flagged within our systems and subject to additional access restrictions
  • No minors' data is ever used for marketing or profiling purposes
  • Parents and guardians may request access, correction, or deletion of their child's data at any time
12

Staff & Internal Data Handling Obligations

All Globridge Pathways employees, interns, agents, and contractors are bound by the following obligations:

  • Sign a binding Confidentiality & Non-Disclosure Agreement (NDA) upon onboarding
  • Complete mandatory data privacy and security training within 7 days of joining, and annually thereafter
  • Access only the data necessary for their specific role (minimum-access principle)
  • Immediately report any suspected data breach, unauthorized access, or data misuse to the Compliance Officer
  • Refrain from using student data for any personal, commercial, or unauthorized purpose
  • Ensure all devices used for work are password-protected and approved by IT

Violation of this Policy by any staff member will result in immediate disciplinary action, which may include termination and legal proceedings. Globridge maintains zero tolerance for internal data misuse.

13

Marketing & Communications Consent

Globridge Pathways may use contact information to send newsletters, study abroad updates, scholarship alerts, and event invitations — but only when:

  • You have provided explicit, informed consent to receive such communications
  • You have made an inquiry or engaged with our services and have been given clear opt-out options

Every marketing communication includes a clear and functional unsubscribe mechanism. Upon receiving an opt-out request, we will remove your contact information from marketing lists within 5 business days. Transactional communications related to active cases are not affected by marketing opt-outs.

14

Updates & Amendments to This Policy

Globridge Pathways reserves the right to update, revise, or amend this Privacy Policy at any time to reflect changes in our operations, services, technology, or applicable law. In the event of material changes:

  • We will post the revised Policy on our official website with an updated effective date
  • Active clients will be notified via email or WhatsApp at least 14 days before the changes take effect
  • Continued use of our services after the effective date constitutes acceptance of the updated Policy

We encourage all Data Subjects to review this Policy periodically to remain informed about how we protect your information.

15

Grievance, Dispute Resolution & Regulatory Compliance

Internal Grievance

If you believe your data rights have been violated or have concerns about how your data is being handled, you may:

  • Submit a formal written complaint to: privacy@globridgepathways.com
  • Address correspondence to: Compliance Officer, Globridge Pathways Ltd.

We will investigate all complaints thoroughly and respond within 10 business days.

Regulatory Compliance

Globridge Pathways operates in alignment with:

  • The Digital Security Act, Bangladesh (and any successor legislation)
  • Relevant ICT and data protection guidelines issued by Bangladesh Telecommunication Regulatory Commission (BTRC)
  • GDPR principles (for processing data of EU-origin students or partners)
  • Applicable destination-country data protection laws where our services extend
16

Contact Information

For all privacy-related inquiries, data subject requests, or compliance matters, please reach out to us through any of the following channels:

Privacy Email

privacy@globridgepathways.com

General Email

hello@globridge.com

Phone

+880 1799 008100

Address

201M Suite, N Broad St 651, Middletown, Delaware, USA

Compliance Officer

Globridge Pathways Ltd.

Effective Date

01 May 2025

Approved & Authorized By

Managing Director

Globridge Pathways Ltd.

Effective 01 May 2025 · Supersedes all previous versions

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