Privacy Policy

Effective Date: 2 January 2023

Company Name: INTERNATIONAL STUDENT PLACEMENTS EDUCATION LIMITED

Contact Email: in**@**********on.com

1. Introduction

INTERNATIONAL STUDENT PLACEMENTS EDUCATION LIMITED (“we”, “us”, “our”) operates the website https://ispeducation.com (the “Website”) and provides education advisory, overseas admission placement, visa advisory, and related student support services (the “Services”).

This Privacy Policy explains how we collect, use, store, disclose, and protect your personal data in accordance with the Nigeria Data Protection Regulation (NDPR) and the EU General Data Protection Regulation (GDPR), where applicable.

By using our Website or Services, you acknowledge that you have read and understood this Privacy Policy.

2. Data We Collect

A. Information You Provide Directly

We may collect the following information when you fill out forms, submit inquiries, book appointments, or otherwise interact with us:

Full name
Email address
Phone number
Home or mailing address
Date of birth and age information
Education history and academic records
Preferred study destination, course, or intake period
Copies of identification or travel documents (e.g., passport) if required for admission or visa guidance
Supporting documents required by partner institutions or visa authorities
Payment-related information (processed via secure third-party payment providers)

B. Information We Collect Automatically

When you visit our Website, we may automatically collect:

IP address
Browser type and version
Device information and operating system
Pages visited, time spent, and navigation paths
Referring website or source
Cookie identifiers and other tracking technologies

C. Sensitive Personal Data

In limited cases, and only when necessary, we may process sensitive personal data, such as:

Nationality and country of residence
Gender
Health-related information (only where required for visa, travel, or institutional compliance purposes)

We will only process such sensitive data where permitted by NDPR, GDPR, or other applicable law, and where strictly necessary for the purposes described in this policy.

D. Information from Third Parties

We may receive information about you from:

Partner schools, colleges, universities, or pathway providers
Scholarship bodies or recruitment partners
Payment service providers
Social media platforms (if you choose to interact with us via those platforms)

3. Legal Basis for Processing

Under NDPR and GDPR, we rely on one or more of the following lawful bases to process your personal data:

Consent: When you voluntarily provide information or explicitly agree to specific processing (e.g., marketing communications).
Contractual Necessity: When processing is required to take steps at your request before entering into a contract or to perform a contract with you (e.g., processing your application or admission documents).
Legal Obligation: When processing is necessary for compliance with legal or regulatory obligations (e.g., immigration, anti-fraud, financial reporting).
Legitimate Interests: When necessary for our legitimate business interests (e.g., service improvement, security, analytics), provided these do not override your fundamental rights and freedoms.

4. How We Use Your Data

We use your personal data for the following purposes:

To provide and manage our education advisory, placement, visa guidance, and student support services
To respond to your inquiries, requests, and messages
To assess your eligibility for specific programs, institutions, or destinations
To prepare, review, and submit applications to partner institutions on your behalf (where instructed by you)
To communicate with you via email, phone calls, SMS, WhatsApp, or other channels you have provided
To process and confirm payments via secure third-party payment providers
To comply with legal and regulatory requirements in Nigeria and other applicable jurisdictions
To maintain internal records, reporting, and quality assurance
To improve our Website, Services, and user experience using analytics and feedback
To send you updates, newsletters, and promotional information about study opportunities, scholarships, events, and services (only where you have given consent or where permitted by law)

We do not sell your personal data to third parties.

5. Cookies and Tracking Technologies

We use cookies and similar technologies on our Website to:

Enhance website performance and security
Remember your preferences and settings
Understand how visitors use our Website
Support marketing and advertising efforts where applicable

You can manage or disable cookies through your browser settings. Please note that disabling cookies may affect the functionality or performance of certain parts of our Website.

6. Data Sharing and Disclosure

A. Trusted Third Parties

We may share your personal data with trusted third parties who assist us in delivering our Services, including:

Partner schools, colleges, universities, and education providers
Scholarship providers and recruitment partners
Payment processors and financial institutions
IT and cloud hosting service providers
Customer relationship management (CRM) and communication tools
Professional advisers (e.g., legal, accounting, compliance consultants) where necessary

These parties are required to process your personal data in accordance with appropriate confidentiality and data protection obligations.

B. Legal and Regulatory Authorities

We may disclose your personal data when required to do so by law or in response to valid requests by public authorities, including:

Court orders and law enforcement agencies
Immigration and visa authorities
Regulatory or governmental bodies

C. International Data Transfers

Because we work with partners and institutions in multiple countries, your data may be transferred and processed outside Nigeria or the European Economic Area (EEA). Where we transfer your data internationally, we will ensure that appropriate safeguards are in place, such as:

Standard Contractual Clauses (SCCs) approved under GDPR
Compliance with NDPR requirements for cross-border data transfer
Transfers to countries deemed to provide an adequate level of data protection

7. Data Retention

We retain your personal data only for as long as necessary for the purposes set out in this Privacy Policy, including:

Providing the Services you request
Maintaining business and financial records
Complying with legal and regulatory obligations
Handling potential disputes or complaints

When personal data is no longer required, we will securely delete, anonymise, or otherwise dispose of it in a safe manner.

8. Your Rights Under NDPR and GDPR

Depending on your location and applicable law, you may have the following rights regarding your personal data:

Right of Access: Request a copy of the personal data we hold about you.
Right to Rectification: Request correction of inaccurate or incomplete data.
Right to Erasure (“Right to be Forgotten”): Request deletion of your data where there is no lawful reason for us to continue processing it.
Right to Restrict Processing: Request that we limit how we use your data in certain circumstances.
Right to Data Portability: Request that we provide your data in a structured, commonly used, and machine-readable format, or transfer it to another controller where technically feasible.
Right to Object: Object to processing based on our legitimate interests or for direct marketing purposes.
Right to Withdraw Consent: Where processing is based on consent, you may withdraw your consent at any time, without affecting the lawfulness of processing before withdrawal.
Right to Lodge a Complaint: You may lodge a complaint with the relevant data protection authority.

To exercise any of these rights, please contact us at in**@**********on.com. We may ask you to verify your identity before responding to your request.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorised access, accidental loss, destruction, or damage, including:

Use of secure (HTTPS) connections on our Website
Access controls and authentication for staff and systems
Regular updates and maintenance of our IT infrastructure
Data backup and recovery procedures
Staff training on confidentiality and data protection

While we strive to use commercially acceptable means to protect your personal data, no method of transmission over the internet or electronic storage is 100% secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the appropriate authorities in line with NDPR and GDPR requirements.

10. Children’s Privacy

Our Services are generally directed at individuals who are 16 years or older, or who are applying for tertiary or related education opportunities. Where we process data relating to a child, we will obtain consent from a parent or legal guardian in accordance with applicable laws, including NDPR and GDPR requirements.

11. Third-Party Websites

Our Website may contain links to third-party websites, plug-ins, or services that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. When we do, we will update the “Effective Date” at the top of this page. We encourage you to review this page periodically to stay informed about how we handle your personal data.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us at:

INTERNATIONAL STUDENT PLACEMENTS EDUCATION LIMITED
Suite B002, 1st Floor, MOROM Plaza, Eke A. Yusufu Close, Utako, Abuja, Nigeria
Email: in**@**********on.com

You also have the right to lodge a complaint with:

The National Information Technology Development Agency (NITDA) in Nigeria, for NDPR-related matters.
Your local Data Protection Authority in the European Union, for GDPR-related matters, if applicable.