GradForward Privacy Policy

Last updated: [date]

1. Who we are

GradForward Ltd ("GradForward", "we", "us") is a student recruitment and education consultancy registered in England and Wales (company number [company number]). Our registered office is Office 7669, 58 Peregrine Road, Hainault, Ilford, Essex, IG6 3SZ.

We are the data controller for the personal information described in this policy. We are registered with the Information Commissioner's Office (ICO) under registration number [ICO number].

Contact us about your data at [privacy@yourdomain.com] or by post at the address above.

2. What information we collect

When you enquire with us or use our services, we may collect:

• Contact details: name, email, phone/WhatsApp number, country and city of residence.
• Identity and immigration details: date of birth, nationality, passport details and visa history (needed for university applications and CAS).
• Education and work history: qualifications, transcripts, certificates, English test results (IELTS, PTE etc.), CV, references and personal statement.
• Application details: courses and universities you are interested in, application status, offers and enrolment.
• Financial information where a university requires it, such as evidence of funds or sponsor details.
• Communications: messages, emails, call notes and meeting records.
• Website and marketing data: IP address, device and browser information, and how you found us (for example a Meta or Google advert). We only collect this through non-essential cookies if you agree to them.

We do not ask for sensitive information (such as health, religion or ethnicity) unless a university needs it, for example to arrange disability support. If you choose to share it, we use it only for that purpose and with your explicit consent.

3. How we use your information and our legal basis

4. Who we share your information with

We share your information only where needed to provide our service:

• Universities and colleges you choose to apply to, and their admissions teams and authorised application portals.
• Application platforms such as UCAS or university online portals, where used.
• Service providers who support our business, such as our email and website hosting providers, cloud storage, CRM and accounting software. They may only use your data on our instructions.
• Professional advisers such as accountants and lawyers, where needed.
• Authorities such as HMRC or law enforcement, where the law requires it.

We do not sell your personal data.

5. International transfers

Many of our students live outside the UK, and some of our service providers store data outside the UK. When we transfer personal data outside the UK, we make sure it is protected, for example by using countries with UK "adequacy" status, or the ICO's International Data Transfer Agreement or Addendum, or equivalent safeguards. Contact us for details.

6. Marketing

We will only send you marketing messages (email, SMS, WhatsApp) if you have agreed to it. Every message includes a way to unsubscribe, or you can reply "STOP" or email us at any time.

7. Cookies

We use essential cookies to make our website work. With your consent, we also use analytics and advertising cookies (such as Google Analytics and the Meta Pixel) to understand how visitors use our site and to measure our adverts. You can accept or reject these through our cookie banner, and change your choice at any time using the "Cookie settings" link in the footer.

8. How long we keep your information

• Enquiries that do not lead to an application: up to 2 years after our last contact.
• Student application and enrolment records: 6 years after your enrolment or our last contact, to meet tax and commission record-keeping requirements and to deal with any disputes.
• Copies of identity documents and transcripts: deleted within [12 months] of your enrolment decision, unless a university or the law requires us to keep them longer.
• Marketing preferences: until you unsubscribe.

9. Your rights

Under UK GDPR you have the right to:

• ask for a copy of the personal data we hold about you
• ask us to correct inaccurate data
• ask us to delete your data
• ask us to restrict or object to how we use your data
• ask us to transfer your data to another organisation
• withdraw your consent at any time, where we rely on consent.

To use any of these rights, email [privacy@yourdomain.com]. We will respond within one month. There is normally no charge.

10. Students under 18

If you are under 18, we may ask a parent or guardian to be involved in your application and to agree to how we use your information.

11. Keeping your information secure

We use appropriate technical and organisational measures to protect your data, including access controls, two-factor authentication and secure storage. Only GradForward staff who need your information to help you can access it.

12. Complaints

If you are unhappy with how we have used your data, please contact us first at [privacy@yourdomain.com]. You also have the right to complain to the Information Commissioner's Office (ICO) at ico.org.uk or on 0303 123 1113.

13. Changes to this policy

We may update this policy from time to time. The latest version will always be on this page, with the date it was last updated.