Privacy Policy

1. In short

• You can browse and search every course on the Site without telling us anything about yourself.
• The consultation form asks for a lot — your name, phone, email, country, city, address, academic history and grades, English-test score, course and country preferences, your total budget and your visa history. Clause 3.1 lists every field.
• The English-test practice tools take the essays you type and send them to a third-party AI provider to be marked. They accept typed answers only today — nothing on our site records your microphone. If we add voice practice later, we will ask for your consent on the page before any recording starts. Clause 3.2 explains both.
• If you engage us for paid application and visa support, we then handle much more — passport, transcripts, financial evidence, sponsor details, visa history. Clause 3.6 lists it, and clause 5.1 says exactly who it goes to.
• We use what you give us to reply to you and to help you with your study plans.
• We never sell your information, and we never rent or trade it.
• We only pass your details to a university or an agency when you ask us to.
• You can ask us to show you, correct, or delete what we hold. Email hello@globalgrads.org.
• We never see or store your card details. Our paid online services are charged by our parent company Omnia through Stripe, or by a local wallet provider; we only ever receive your name, email, what you bought and the amount.

The rest of this policy explains all of this properly.

2. Who is responsible for your information

2.1 Global Grads is responsible for the personal information described in this policy. “We”, “us” and “our” mean Global Grads (M/S Global Grads), a partnership firm registered under the Partnership Act, 1932 with the Registrar of Firms, Lahore (Registration No. 0744, year 2023-24), registered office Office #298-Q, 2nd Floor, Commercial Area, DHA Phase 2, Lahore, Pakistan.

2.2 Our registered office and head office are the same premises: Office #298-Q, 2nd Floor, Commercial Area, DHA Phase 2, Lahore, Pakistan. Branch offices: 23/C Zigatola Main Road, Dhanmondi, Dhaka; and House B, 72/A, Road 21, Banani, Dhaka 1213.

2.3 For anything to do with your information, contact hello@globalgrads.org or +92 311 599 9398.

3. What we collect

3.1 What you give us

The consultation form. The form has several steps. When you ask for a Complimentary Consultation you give us:

About you and how to reach you

• your full name (required);
• your phone number (required) — we may use it for WhatsApp;
• your email address (required);
• the country you are in (required);
• your city (required); and
• your address.

About your studies

• the level of study you are aiming for (required);
• your school-level qualifications, with the marks or grades you achieved and the years you completed them;
• your bachelor’s degree, CGPA and year, if you have one;
• your master’s degree, CGPA and year, if you have one; and
• your English-language test (IELTS, TOEFL, PTE or the Duolingo English Test) and the score you achieved.

About what you want

• the countries you would prefer to study in;
• your first and second choice of course;
• your total budget for tuition and living costs;
• your visa history — whether you have applied for or been refused a visa before;
• how you would like to be counselled; and
• how you heard about us.

You do not have to fill in the fields that are not marked required. The more you leave out, the less useful our suggestions will be.

Other forms. The careers and internship form, the Japan Student Exchange form and the contact form collect the details shown on each form — typically your name, contact details and what you are applying for, together with anything you attach or write.

What you tell us afterwards. If we start helping you, you may tell us more — updated grades, documents, your intake year, and similar.

Messages. Emails, WhatsApp messages and calls between you and us, including what is said in them.

3.2 What the practice tools collect

The English-test practice tools on our main website (Duolingo English Test, IELTS and PTE practice material) collect more than a normal page.

Today these tools accept typed answers only. No page on our site records your microphone. When you use them:

• Your written work is taken — the essays, summaries, descriptions and answers you type.
• Your written work is sent to be marked. It goes to our backend and from there to Groq, a third-party artificial-intelligence provider, which produces the score and the feedback. Clause 5.2 lists Groq as one of our processors.
• The score and the feedback are stored, together with which test you attempted and when.

Please do not write anything in a practice task that you would not want stored and sent for marking, and do not include personal details about other people.

If we add voice practice. We may add speaking practice later. If and when we do, your microphone will be used only after you have given consent on the page itself (clause 3.2A), and this is what will happen: the tool records your answer while you speak; the recording, and any transcript made from it, go to our backend and on to Groq in the United States to be marked, on the same terms as written work in clause 5.2; we keep recordings for 90 days, and you can ask us to delete them sooner. If you are under 18, you should not use voice practice unless a parent or guardian agrees (clause 10). None of this happens today, and we will update this policy before it does.

If you are under 18, please read clause 10 before you use the practice tools.

3.2A We ask before we record

No recording takes place on our site today. If we enable voice practice, then the first time you open a speaking task — and before any recording starts — we will show you a box telling you that the tool records your voice and sends the recording and a transcript to Groq, an AI marking service in the United States, to produce a practice score; that a practice score is not an official test result; that we keep recordings for 90 days and you can ask us to delete them sooner at hello@globalgrads.org; and that if you are under 18 you should not continue unless a parent or guardian agrees. You will have to agree before anything is recorded. Your browser will also ask its own permission for the microphone; that is your device asking, and it is not a substitute for this step.

For written practice, which is what the tools offer today, clause 3.2 explains what is taken and where it goes.

3.3 What the Site collects automatically

Analytics. We use Google Analytics on our main website at globalgrads.org to understand how it is used — pages visited, how long a visit lasts, roughly which city or country a visit came from, and whether it came from a phone or a computer. This is about usage patterns, not about identifying you by name. At the date of this policy the study portal at globalgrads.org/courses does not run Google Analytics.

Cookies and similar technologies. Small files that let the Site work and let analytics count visits. See clause 9.

Device and connection data. Your IP address, browser type and version, operating system, screen size, language and referring page.

Server logs. Our hosting provider records requests to the Site — the page requested, the time, the IP address, and the response — so the Site can run and so we can spot faults and attacks.

Google Search Console — not collected from you. We also use Google Search Console. It is worth being clear about what it is: it collects nothing from your visit. It reports Google’s own search data back to us — which search terms showed our pages in Google results, and how often people clicked them — in totals, never as individuals. We list it here for completeness, not because it takes anything from you.

3.4 Choices that are not tracking

The nationality field. Where the Site offers a nationality field it is optional and it gates nothing. Leaving it blank does not restrict what you can see or search. If you do fill it in, your answer is stored in your own browser so the portal can remember it and tailor the guidance it shows you. It stays on your device, it is not sent to our database as part of your browsing, and you can clear it by clearing your browser’s site data.

The currency selector. Your currency choice is a display setting. It may be stored in your browser so the Site remembers it. It tells us nothing about your finances.

3.5 Some things we specifically do not collect

This is not a complete list of everything we do not hold. It answers the three questions we are asked most. What we do collect is set out in clauses 3.1 to 3.4, and that is the part to read.

• No card numbers, ever. There is no card form, no checkout and no payment page on globalgrads.org or globalgrads.org/courses. Where you buy one of our paid online services, the payment is taken by our parent company Omnia Luxoros Asset Management Ltd through Stripe, or by a local wallet provider — and we never see or store your card, bank or wallet details. All we receive is your name, your email address, what you bought and how much you paid. See clause 5.2A.
• No public sign-in yet. Google sign-in is planned but is not live on the public Site at the date of this policy, and the Site does not ask you to create an account. If we switch it on, we will update this policy first and say exactly what Google passes to us.
• We do not ask you for sensitive information. We do not ask about your religion, your health, your politics or your ethnicity, and we ask you not to send such details to us. Note that two fields we do ask for — your total budget and your visa history — are personal and sensitive in the ordinary sense of those words, even if the law does not classify them as a special category. We ask for them only to judge what is realistic for you, we keep them under clause 7, and you may leave them blank.

3.6 If you engage us for application and visa support

Clauses 3.1 to 3.5 are about using the website. If you go further and sign our Consent Form for paid application and visa support, we then handle much more sensitive material about you. It is collected in person, by email or by WhatsApp — not through the website.

Depending on where you are applying, it typically includes:

• Identity documents — your passport, national identity card, photographs, date and place of birth, and your signature.
• Academic records — transcripts, mark sheets, certificates, degrees, references and personal statements.
• English-language and other test results — your official IELTS, TOEFL, PTE, Duolingo, GRE or GMAT scores and certificates.
• Financial evidence — bank statements, sponsorship letters, affidavits of support, loan documents and proof of funds.
• Family and sponsor details — the names, identity details, occupations and financial information of a parent, guardian or sponsor who supports your application.
• Immigration history — previous visas, refusals, travel history and any related correspondence.
• Anything a particular university or visa authority additionally requires, such as medical or police-clearance documents.

We ask for these only because a university or a visa authority requires them. Please send us only what is asked for. Where you give us information about another person — a parent or a sponsor — please make sure they know, and show them this policy.

Your Consent Form records your agreement to us collecting and using this material for your admissions process and for dealing with universities and supervisors on your behalf. This policy explains the detail behind that consent, and you can withdraw it at any time under clause 8 — though, as the form says, withdrawing it may mean we cannot continue the service.

4. Why we use it, and on what basis

We explain the legal basis in plain words. The formal wording is a matter for the law that applies — see clause 12.

“Legitimate interest” means we have a genuine business reason for using the information, and we have checked that the reason does not override your privacy.

We never sell your personal information, and we never rent, trade or share it for anyone else’s advertising.

5. Who we share it with

5.1 Universities and partner agencies

We pass your details to a university, or to an agency that represents universities, only when you ask us to — for example when you want us to submit an enquiry or an application for you. We tell you where we are sending your details — for application-service clients, by agreeing the list of universities and authorities with you before we send anything, and by telling you on request at any time who currently holds your file. Once they have it, they use it under their own privacy policy, which we do not control.

If you have not asked us to, we do not send your details to anyone.

If you have engaged us for application and visa support, that instruction is what the Consent Form records, and it is how the service works. On your instruction we send the material in clause 3.6 to: the universities and colleges you are applying to, and their admissions offices, supervisors and appointed agents; the visa or immigration authority of the country you are applying to, and any office it uses to receive applications; and, where you ask us to, an education loan provider or a sponsor. We also record your file in the customer-records system named in clause 5.2. We do not send your documents anywhere you have not asked us to send them.

5.2 Service providers who run our systems

These companies process information on our instructions so that the Site can work:

We ask our providers to keep your information secure and to use it only for what we have asked them to do.

About Groq in particular. Your practice essays leave our systems when they are marked — as would a recording and its transcript, if we ever enable voice practice. We send Groq the text, or the recording, and nothing else — not your name, not your contact details and not your student file. Groq processes it on Google Cloud infrastructure in the United States. Under our agreement with Groq, Groq is not permitted to use what we send it to train or fine-tune its models. Groq may still process data briefly for system reliability and abuse monitoring under its own terms.

5.2A When you pay for something. If you buy one of our paid online services, the payment is handled outside our systems. For a card payment, Stripe takes your card details directly and Omnia Luxoros Asset Management Ltd — our parent company, registered in England and Wales, company no. 14929050, registered office 128 City Road, London EC1V 2NX — is the seller and the merchant of record; Omnia’s name is what appears on your statement. For a wallet payment, JazzCash, Easypaisa or bKash takes it and Global Grads receives it. In every case your card or wallet number goes to the payment provider, not to us. What we and Omnia keep is your name, your email address, the service you bought, the amount, the currency and the date — so we can give you access, answer a question about your purchase, handle a refund, and keep the tax records we are required to keep. Stripe uses payment data for its own purposes as its own controller, under its own privacy notice.

5.2B A word about WhatsApp. Many students prefer WhatsApp and we use it. Please be aware that messages you send us there sit on your device, on our counsellor’s device and on Meta’s systems under Meta’s own terms, and we cannot delete a copy from your phone or from Meta. Please do not send identity documents, financial evidence or passport scans over WhatsApp — email them to hello@globalgrads.org instead, where we can hold them properly and delete them when you ask. Where a WhatsApp conversation becomes part of your file, we copy what matters into your file and treat that copy under clause 7.

5.3 Embedded content

Some pages embed YouTube videos or Instagram posts. When such an embed loads, YouTube or Instagram may receive your IP address and may set their own cookies, whether or not you click anything. That processing is theirs, under their own policies, and we do not control it.

5.4 Others

We may also share information:

• with our professional advisers — accountants and lawyers — where they need it;
• if the law, a court or a regulator requires it;
• to prevent or investigate fraud, a crime, or an attack on the Site, or to protect someone’s safety; or
• if our business is transferred to another company, in which case your information passes with it and this policy continues to apply until you are told otherwise.

5.5 Careers and internship applications

If you apply to work with us, or for an internship, what you send goes into our internal recruitment records in the customer-records system named in clause 5.2. It is seen by the people at Global Grads who are handling hiring. We do not share it outside the company, and we do not add you to any student mailing list because you applied for a job.

5.6 Using offers and admissions in our marketing

We are proud of our students’ results, and we like to share them. Here is exactly how that works.

• Only with your consent. We use your offer or admission in marketing or promotional material only if you have agreed to it. That agreement is given on the Consent Form, and it is a choice — the service does not depend on it.
• By default it is anonymous. Unless you separately agree otherwise, we will show only non-identifying details, such as the course, the university, the country and the intake — for example, “a student placed at a university in the UK for September 2026”.
• Your name, photograph, video or words are used only if you separately agree to that specific use. We will tell you what we want to use and where, and we will not treat a general consent as covering it.
• You can change your mind at any time. Email hello@globalgrads.org and we will stop using your details in anything new, and remove them from material we still control — our website and our own social-media posts. We cannot recall something already printed, or reshared by someone else.
• We never publish your documents. Your passport, transcripts, financial evidence, offer letter, visa or any other document is never published, and no screenshot of one is used in marketing, whether or not your name is on it.
• Under-18s. Where the student is under 18, we use their details in marketing only with a parent’s or guardian’s agreement, and never with a photograph unless the parent or guardian agrees to that specific use.

6. Sending information outside Pakistan and Bangladesh

6.1 The companies listed in clause 5.2 store and process data on servers outside Pakistan and Bangladesh.

6.2 If you ask us to approach a university abroad, your details go to that country.

6.3 If you use the English-test practice tools, your written work is sent outside Pakistan — to the United States — to be marked by Groq, as clause 5.2 explains. If we enable voice practice later, a recording and any transcript would travel the same way. We send nothing that identifies you by name with it.

6.3A Payments. If you buy a paid online service by card, your purchase details go to the United Kingdom, where Omnia Luxoros Asset Management Ltd is registered and sells them, and to Stripe’s infrastructure, which is global. Wallet payments stay with the wallet provider in Pakistan or Bangladesh.

6.4 That means your information may be handled under laws different from your own.

6.5 We choose established providers, we send only what is needed, and we ask providers to protect the data.

7. How long we keep it

These are the periods we propose. They are not yet fixed.

These periods apply wherever the record is held — in our customer-records system, in the study portal database, in our email, and in any working copy — and we delete or anonymise each copy when the period ends.

When a period ends, we delete the information or make it anonymous so it can no longer be linked to you.

8. Your rights, and how to use them

8.1 You can ask us to:

1. show you what personal information we hold about you;
2. correct anything that is wrong or out of date;
3. delete what we hold, where we do not have to keep it;
4. stop using it for a particular purpose — for example, stop emailing you;
5. withdraw your consent where we relied on it; and
6. give us nothing — you can simply choose not to fill in a field or send a form, though that may mean we cannot help you.

8.2 How to ask. Email hello@globalgrads.org with the word Privacy in the subject line, and tell us what you want. You can also phone +92 311 599 9398 and ask us to send you the form. This includes your practice-test recordings and essays: ask us to delete them and we will, without waiting for the periods in clause 7 to run out.

8.3 What happens next. We will confirm we have received your request, we may ask you to prove who you are so we do not hand your details to someone else, and we aim to answer within 30 days. There is no charge.

8.4 Withdrawing consent stops future use. It does not undo what was already done while your consent was in place.

8.5 If we cannot do what you ask — for example because we must keep a record for tax — we will tell you why.

8.6 Complaints. If you are unhappy with how we have handled your information, write to hello@globalgrads.org first and give us a chance to put it right. At the date of this policy Pakistan has no data protection regulator you can escalate a privacy complaint to. If your complaint is about a paid service you bought from us, you may take it to the District Consumer Court at Lahore under the Punjab Consumer Protection Act 2005 or to the Directorate of Consumer Protection Council, Punjab. If your complaint is that someone has attacked our systems or misused data taken from them, that is a matter for the National Cyber Crime Investigation Agency under the Prevention of Electronic Crimes Act 2016.

9. Cookies, analytics, and how to switch them off

9.1 Cookies we need. A few cookies and similar storage are needed for the Site to work — for example remembering your currency choice or keeping a page working as you move through it. Without these the Site does not function properly.

9.2 Analytics cookies. Google Analytics sets cookies that count visits and show how pages are used.

9.3 Third-party cookies. YouTube and Instagram embeds may set their own cookies when they load.

9.4 How to switch them off:

• Your browser can block or delete cookies. Look under Settings → Privacy. Doing so may stop parts of the Site working.
• Google Analytics can be switched off for every site you visit by installing Google’s own browser add-on from tools.google.com/dlpage/gaoptout.
• Private or incognito windows clear cookies when you close them.
• You control what you send us. Our forms and the practice tools are the places where you actively give us your details, your written work or your voice. If you do not send a form and do not use the practice tools, we do not have them.

10. Children and students under 18

10.1 Many of the students who use the Site are 17 to 25 years old, and some are under 18.

10.2 If you are under 18, please do not send us the consultation form, or any of your personal information, unless a parent or legal guardian has read this policy and agreed.

10.3 By sending the form you confirm that a parent or guardian has agreed. We may ask for that confirmation before we go further, and we may decline to continue without it.

10.4 A parent or guardian can email hello@globalgrads.org at any time to see, correct or delete the information we hold about a student under 18. We will act on that request.

10.5 The English-test practice tools and students under 18. These tools take a student’s written work and send it to a third-party artificial-intelligence provider to be marked (clause 3.2). They accept typed answers only today and do not record anyone’s voice. If you are under 18, please do not use the written practice unless a parent or legal guardian has read clause 3.2 and agrees — and if we enable voice practice later, a parent’s or guardian’s agreement will be needed before a student under 18 uses it at all. A parent or guardian can email hello@globalgrads.org at any time to ask us to delete a student’s written work, practice scores and any recording we hold, and we will do so.

10.6 If we learn that we hold information about a child sent to us without a parent’s or guardian’s agreement, we will delete it, unless we are required by law to keep a particular record — in which case we will keep only that record, and only for as long as the law requires.

11. Security

11.1 We take reasonable steps to protect your information:

• the Site is served over an encrypted connection (HTTPS);
• the database is access-controlled and is not open to the public;
• administrative access is limited to people who need it; and
• we take regular backups so information is not lost.

11.2 No website or system is perfectly secure. We cannot promise that your information will never be at risk, and you send it to us at your own risk.

11.3 At the date of this policy Pakistani law does not require us to report a data breach to any authority or to any affected person. We have decided to do it anyway. If a breach happens that we believe puts your information at serious risk, we will act quickly to contain it, we will tell affected people without undue delay once we have established what happened and who is affected, we will tell you what we know and what you should do, and we will notify any authority that the law requires us to notify at that time.

12. The law that applies

12.1 This policy is governed by the laws of Pakistan. Any dispute about it is dealt with as set out in our Terms and Conditions.

12.2 The Prevention of Electronic Crimes Act 2016 (PECA). This is Pakistan’s main statute on the misuse of electronic data. Among other things it makes it a criminal offence to access an information system without authorisation, and to copy or transmit data from it without authorisation. It protects our systems and our users against intrusion and against bulk extraction of our data — but it is a cybercrime statute, not a general data-protection law, and it does not by itself give you the rights described in clause 8. We give you those rights as a matter of our own policy.

12.3 A general data protection statute. As at the date of this policy Pakistan has no general personal data protection law in force. A Personal Data Protection Bill has been through several drafts since 2018 and a version was approved by the Federal Cabinet, but it has not been passed by Parliament and has not been brought into force, so there is no data protection regulator in Pakistan you can complain to and no statutory register we are required to join. The rights we give you in clause 8 are given as a matter of our own policy, and we will honour them whether or not a law requires it. If a data protection statute comes into force, we will review this policy against it and update it before it binds us.

12.4 Bangladesh. We have branch offices in Dhaka.

12.5 Students elsewhere. We offer our services to students in Pakistan and Bangladesh. We do not target students living in the United Kingdom or the European Union and we do not track anyone’s behaviour there, so we do not consider that UK or EU data protection law applies to us. When we send your details to a university in those regions at your request, that university handles them as its own controller under its own policy and under the law that applies to it. If we ever begin offering our services to students living in the UK or the EU, we will update this policy before we do.

13. Changes to this policy

13.1 We may update this policy. The current version is always the one published on the Site, with its date at the top.

13.2 If we make a significant change — for example if we switch on Google sign-in, add a cookie banner, add analytics to the study portal, or start using a new provider such as a different AI marking service — we will update this policy before the change goes live, and we will say so clearly on the Site.

13.3 Please check the date at the top from time to time.

14. Contact us

Global Grads (M/S Global Grads)
Registered and head office: Office #298-Q, 2nd Floor, Commercial Area, DHA Phase 2, Lahore, Pakistan
Dhaka — Dhanmondi: 23/C Zigatola Main Road, Dhaka
Dhaka — Banani: House B, 72/A, Road 21, Dhaka 1213
Phone / WhatsApp: +92 311 599 9398
Email: hello@globalgrads.org
Web: globalgrads.org