1. Who we are
Glocal Opportunities (operating the website www.glocalopportunities.com along with its associated brands GloEdge Visas, Immigrow Visas and Pearlwise Consulting — collectively "Glocal Opportunities", "we", "us", "our") is the Data Fiduciary (under the Digital Personal Data Protection Act, 2023, India) and the Data Controller (under the EU General Data Protection Regulation, where it applies) for the personal data described in this Policy.
2. Scope of this policy
This Policy applies to personal data we collect when you visit the Website, complete an enquiry or eligibility form, attend a webinar, sign an Engagement Letter, communicate with us by phone / email / WhatsApp / chat, follow us on social media or otherwise interact with our brand.
3. Information we collect
3.1 Information you provide directly
- Identification: full name, date of birth, gender, nationality, passport number, photograph.
- Contact: phone number, email, residence state, postal address.
- Profile: highest qualification, work experience band, marital and dependent status, languages spoken.
- Service intent: country of interest, visa category, programme of study, occupation, intended budget.
- Documentary: academic transcripts, IELTS / PTE / TOEFL / Duolingo scores, employment letters, payslips, ITRs, bank statements, police-clearance, medicals.
- Sensitive personal data, where strictly required for the visa or admission process: health declarations, biometric details, criminal record disclosures, financial information.
- Payment data: billing name, address, transaction reference, GSTIN where applicable. We do NOT store full card numbers; payments are processed by PCI-DSS compliant third-party gateways.
3.2 Information we collect automatically
- Device and browser data: IP address, browser type, OS, device model, screen resolution.
- Usage data: pages viewed, time on page, referral source, search terms, click stream.
- Location: approximate city / region inferred from IP. We do not collect precise GPS location.
- Cookies and similar technologies — see our separate Cookie Policy.
3.3 Information from third parties
- University and college partners (offer letters, admission status).
- Visa partner agencies, language testing bodies, evaluators (e.g., WES, ECA).
- Payment gateways and KYC providers.
- Social media platforms when you engage with our pages or run-of-network advertisements.
- Lead-generation partners and referrers, where you have given consent.
4. Sources of personal data
We collect personal data primarily from you. Where we receive data from a third party, we ensure the third party has obtained your consent or has another lawful basis to share, and we inform you within a reasonable time.
5. How and why we use your data — purposes
We use your personal data for the following purposes:
Purpose Examples
Service delivery Eligibility evaluation, application drafting, document verification, university and visa filing, status updates.
Account & engagement Onboarding, contract execution, KYC, billing, payment
Purpose Examples
administration reconciliation, refunds.
Customer communication Replying to your enquiries, scheduling counselling, deadline reminders, post-departure check-ins.
Marketing & promotions Sending webinars, country bulletins, offers via SMS / RCS / Call / Email / WhatsApp — only where you have authorised this.
Analytics & improvement Understanding which content / programmes / countries are useful so we can improve our Services.
Legal & regulatory Compliance with tax, accounting, AML / KYC, court orders, consumer-protection and IT Rules obligations.
Security & fraud prevention Detecting forged documents, account abuse, payment fraud, unauthorized access.
6. Lawful basis for processing
- We process your personal data on one or more of the following bases:
- Consent — for marketing communications, optional analytics cookies, and processing of sensitive personal data.
- Contract — to perform the Engagement Letter you have entered into with us.
- Legal obligation — to comply with tax, accounting, IT Rules, AML and other regulatory requirements.
- Legitimate interests (GDPR users only) — running and improving our business in a way that does not override your rights, including fraud prevention and securing our systems.
- Vital interests / public interest — only in rare emergencies (e.g., a medical event during a pre-departure programme).
7. Sharing and disclosure
- We share personal data only on a need-to-know basis with:
- Foreign universities, colleges and language schools, when you instruct us to apply on your behalf.
- Visa filing partners, including OISC / RCIC / MARA-registered immigration advisers in destination countries.
- Service providers: cloud hosting, CRM, email and SMS gateways, WhatsApp Business API providers, courier services, KYC and payment platforms — bound by confidentiality and data-processing agreements.
- Auditors, professional advisers and government authorities where required by law.
- Group companies and our associated brands (GloEdge Visas, Immigrow Visas, Pearlwise Consulting) for the purposes set out in this Policy.
- Acquirers, in the event of a merger, acquisition, reorganisation or insolvency.
We do not sell personal data.
8. International transfers of personal data
- Visa, study and migration services by their nature involve transferring data to destination countries (e.g., Canada, Australia, the UK, USA, Germany, Japan, South Korea, Ireland, New Zealand, Switzerland, UAE, Portugal, Greece). When we transfer data outside India:
- Where the destination has been notified by the Indian Central Government as a permitted country under the DPDP Act 2023, transfers proceed under that framework.
- For EU / UK personal data, transfers to non-adequate countries are made under Standard Contractual Clauses (SCCs) or another lawful transfer mechanism.
- Where the foreign authority requires us to share data as part of an application (e.g., embassy submission), this is necessary for the performance of your contract and is the express purpose for which you engaged us.
9. Retention periods
We retain personal data only for as long as necessary for the purposes for which it was collected or as required by law:
Data category Retention
Active engagement records (case files, Duration of engagement + 7 years (for tax / regulatory / applications) dispute defence)
Counselling-only records (no engagement Up to 24 months from last interaction signed)
Marketing contact list (consented) Until consent is withdrawn, or 24 months of inactivity, whichever is earlier
Payment & invoicing records 8 years (Income Tax Act, 1961 read with GST law)
KYC records 5 years from end of engagement (PMLA, where applicable)
Webinar / event sign-ups 12 months from event
Server access logs and security logs 180 days (CERT-In / IT Rules)
10. Security measures
We implement technical and organisational measures appropriate to the nature of the data, including: HTTPS / TLS in transit, encrypted storage at rest for sensitive documents, role-based access control on our CRM and document repositories, multi-factor authentication for staff,
periodic security awareness training, vendor due diligence, and secure backup. Despite these measures, no system is impenetrable; in the event of a personal-data breach affecting you, we will notify you and the Data Protection Board of India in accordance with the DPDP Act and applicable law.
11. Your rights
- Subject to applicable law, you have the right to:
- Access — obtain confirmation of whether we hold personal data about you and a copy of it.
- Correction — ask us to correct inaccurate or incomplete data.
- Erasure — request deletion of personal data that is no longer needed.
- Withdraw consent — at any time, without affecting the lawfulness of prior processing.
- Grievance — nominate a person to exercise these rights in the event of your death or incapacity (DPDP Act, India).
- Restriction / objection (GDPR users only).
- Data portability (GDPR users only).
- Lodge a complaint with the Data Protection Board of India, or with a relevant supervisory authority in your country. To exercise your rights, write to privacy@glocalopportunities.com. We will respond within 30 days. We may need to verify your identity before processing the request.
12. Cookies and analytics
We use cookies and similar tracking technologies on the Website. Detailed categories, providers and how to opt out are described in our separate Cookie Policy, available at glocalopportunities.com/cookie-policy.
13. Children's data
Our Services are aimed at adults aged 18 and above. Where applications are made on behalf of a minor (e.g., dependent visas, school applications), we collect minimum necessary data with verifiable parental / guardian consent and do not use such data for marketing or behavioural profiling.
14. Automated decision-making
We may use automated tools (e.g., points calculators) to estimate eligibility. These outputs are indicative only — every case is reviewed and finalised by a human counsellor before any application is filed. No legally significant decision is taken about you solely by automated means.
15. Changes to this policy
We may update this Policy from time to time. The "Effective date" at the top reflects the latest revision. For material changes, we will give reasonable advance notice via email or a banner on the Website.
16. Grievance officer & data-protection contact
Particular Detail
Data Protection Officer / Grievance [Name to be inserted] Officer
Address Glocal Opportunities, 809, 8th Floor, Le Meridien Commercial Towers, Raisina Road, New Delhi 110001