Legal
PRIVACY
POLICY.
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.
Contents
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.
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.
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
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.
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
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
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 Type | Retention Period |
|---|---|
| Active student files | Duration of engagement + 5 years |
| Visa & immigration documents | 7 years post-application |
| Financial records | 7 years (regulatory requirement) |
| Marketing consent records | Until consent is withdrawn |
| Website & analytics data | 24 months |
| Staff & HR records | Duration 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.
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.
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.
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
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
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.
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.
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.
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
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