GlobalGrad Privacy Policy

Your privacy is paramount to GlobalGrad. This Privacy Policy describes how GlobalGrad ("we," "us," or "our") collects, uses, processes, and discloses your information in connection with your access to and use of the GlobalGrad website, mobile applications, and services (collectively, the "Service"). We are committed to protecting your personal data and handling it responsibly, in compliance with applicable data protection laws, including the UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection (PDPL), as it applies to our operations in Dubai and the UAE, and other international standards like GDPR where relevant.

By using the Service, you agree to the collection and use of information in accordance with this policy.

Table of Contents

1. 1. Who We Are
2. 2. Information We Collect
3. 3. How We Use Your Information
4. 4. How We Share Your Information
5. 5. International Data Transfers
6. 6. Data Security
7. 7. Data Retention
8. 8. Your Rights (Data Subject Rights)
9. 9. Cookies and Tracking Technologies
10. 10. Third-Party Websites and Services
11. 11. Children's Privacy
12. 12. Changes to This Privacy Policy
13. 13. Contact Us

1. Who We Are

GlobalGrad is an AI-powered platform designed to simplify the international university application process. We connect aspiring students with their dream universities worldwide, providing expert guidance, innovative tools, and personalized support.

Our registered office is located at:
[Your Company's Physical Address in Dubai/UAE]
[Your Company's Phone Number, e.g., +971 (4) XXX XXXX]
Email: privacy@globalgrad.com

2. Information We Collect

We collect various types of information for various purposes to provide and improve our Service to you.

2.1. Personal Data (Information you provide to us):

• Identity & Contact Data: Name, email address, phone number, date of birth, nationality, country of residence, passport number, visa details.
• Academic Data: Educational qualifications (degrees, institutions, GPA), academic transcripts, test scores (IELTS, TOEFL, SAT, GRE), personal statements, essays, resume/CV.
• Financial Data: Budget for studies, financial statements, scholarship information, payment transaction details (not full payment card numbers, which are handled by third-party processors).
• Correspondence Data: Records of your communication with us, your assigned counselor, universities, and other Users through the Service's messaging features.
• Counselor Application Data: If you apply to be a counselor, we collect professional qualifications, work experience, certifications, references, and background check consent.
• Referral Data: Your unique referral code and information about referred individuals who sign up using your code.
• Profile Photo: Your profile picture uploaded to the Service.

2.2. Usage Data (Information collected automatically):

• Technical Data: IP address, browser type and version, time zone setting, operating system and platform, device type, screen resolution.
• Behavioral Data: Pages you visit, time spent on pages, links clicked, search queries, application progress, feature usage, login frequency, last active timestamp.
• Location Data: Derived from your IP address or device settings (e.g., city, country).

2.3. Information from Third Parties:

• Universities: Updates on your application status, offer details, and admission decisions.
• Payment Processors: Confirmation of payment transactions.
• AI Service Providers: Data processed by AI (e.g., parsed CV content) in accordance with our AI terms.
• Publicly Available Sources: Limited data from publicly accessible sources to verify information (e.g., professional social media profiles).

3. How We Use Your Information

We use your Personal Data for various purposes based on the legal bases permitted by applicable laws (e.g., performance of a contract, legitimate interests, consent).

3.1. To Provide and Maintain the Service:

• Create and manage your account.
• Process your university applications and related documents.
• Match you with suitable universities and programs.
• Facilitate communication between you, your assigned counselor, and universities.
• Process payments for application fees or services.
• Deliver AI-powered guidance and tools (e.g., CV parsing, essay drafting assistance).

3.2. To Improve and Personalize the Service:

• Understand how you use the Service to enhance features and functionality.
• Personalize your experience (e.g., tailored university recommendations).
• Conduct research and analysis to improve our educational guidance.

3.3. For Communication:

• Send you essential Service-related notifications, updates, and reminders (e.g., application status changes, deadlines, new messages).
• Respond to your inquiries and support requests.
• Send you marketing and promotional communications (if you have opted-in).

3.4. For Security and Compliance:

• Maintain the security and integrity of the Service.
• Prevent fraud, abuse, and unauthorized access.
• Comply with legal obligations, enforce our Terms of Service, and resolve disputes.
• Perform necessary verification steps (e.g., identity verification for counselors, document authenticity checks).

3.5. For Referral Program:

• Track and manage your participation in the referral program, including commission calculations and payouts.

4. How We Share Your Information

We may share your Personal Data with third parties in the following situations:

4.1. With Universities (Based on Consent/Application):

• When you apply to a university through GlobalGrad, we share your application data, profile information, and uploaded documents with that specific university to process your application.
• Your consent to share information for application purposes is implicit when you initiate an application through our platform.

4.2. With Assigned Counselors:

Your assigned GlobalGrad counselor has access to your profile, application data, documents, and communication history to provide personalized guidance.

4.3. With Service Providers:

We may employ third-party companies and individuals to facilitate our Service (e.g., cloud hosting, payment processing, analytics, customer support, email delivery, AI model providers). These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

• For AI-powered features, relevant data (e.g., CV text, essay prompts) is securely transmitted to AI model providers (like Google Gemini API) for processing. We ensure these providers adhere to strict data privacy and security standards.

4.4. Business Transfers:

If GlobalGrad is involved in a merger, acquisition, or asset sale, your Personal Data may be transferred as a business asset.

4.5. Law Enforcement & Legal Compliance:

We may disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency), particularly to comply with UAE laws and regulations.

4.6. With Your Consent:

We may disclose your Personal Data for any other purpose with your explicit consent.

5. International Data Transfers

As an international platform, your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.

Specifically, data may be processed in the UAE, in cloud regions where our Firebase servers reside (e.g., us-central1), and by third-party service providers located globally.

We take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and that adequate data protection safeguards are in place (e.g., Standard Contractual Clauses for transfers outside the UAE/EEA where required). By submitting your Personal Data, you agree to this transfer.

6. Data Security

We implement robust technical and organizational measures designed to protect your Personal Data from unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption: Data encryption in transit (e.g., TLS/SSL) and at rest.
• Access Controls: Strict role-based access controls to our systems.
• Authentication: Multi-factor authentication for administrative access.
• Regular Security Audits: Periodic security assessments and vulnerability testing.
• Data Minimization: Collecting only the data necessary for the stated purposes.
• Secure Storage: Utilizing Firebase's secure and scalable infrastructure (Firestore, Storage).

However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

7. Data Retention

We retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy, typically for the duration of your active account with GlobalGrad and for a reasonable period thereafter to comply with our legal obligations (e.g., tax, accounting, or legal requirements), resolve disputes, and enforce our agreements.

• Account Deletion: If you request account deletion, we will delete or anonymize your Personal Data. However, some data may be retained in anonymized or aggregated form for analytics and reporting, or if legally required.
• Data Anonymization: Data linked to your account may be anonymized or pseudonymized to preserve its value for analytics without identifying you personally.

8. Your Rights (Data Subject Rights)

In accordance with applicable data protection laws (including UAE PDPL where applicable), you may have the following rights regarding your Personal Data:

• Right to Access: You have the right to request access to your Personal Data we hold.
• Right to Rectification: You have the right to request that we correct any inaccurate or incomplete Personal Data.
• Right to Erasure ("Right to be Forgotten"): You have the right to request the deletion of your Personal Data under certain conditions.
• Right to Restriction of Processing: You have the right to request that we restrict the processing of your Personal Data under certain conditions.
• Right to Data Portability: You have the right to obtain your Personal Data in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to our processing of your Personal Data under certain conditions.
• Right to Withdraw Consent: Where we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, please contact us using the details in Section 13. We may require you to verify your identity before responding to such requests.

9. Cookies and Tracking Technologies

We use cookies and similar tracking technologies (e.g., web beacons, pixels) to track activity on our Service and hold certain information.

• Cookies: Small files stored on your device.
• Purpose: To remember your preferences, analyze Service usage, and for security.
• Types: Session cookies (temporary) and persistent cookies (remain on your device).
• Management: You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

10. Third-Party Websites and Services

Our Service may contain links to third-party websites or services. This Privacy Policy applies only to GlobalGrad. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. We encourage you to review the privacy policies of any third-party sites you visit.

11. Children's Privacy

Our Service is not intended for individuals under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

12. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

13. Contact Us

If you have any questions about this Privacy Policy, you can contact us:

• Email: privacy@globalgrad.com
• Phone: [Your Support Phone Number, e.g., +971 (4) XXX XXXX]
• Address: [Your Company's Physical Address in Dubai/UAE]