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Data Processing Policy

Last Updated: August 2026

Version: 1.0

1. Introduction

Pathway Academic Resource Private Limited ("PARPL", "we", "our", or "us"), a Pathway Group company, is committed to processing personal information responsibly, transparently, securely, and in accordance with applicable laws.

This Data Processing Policy explains how PARPL collects, records, organizes, stores, uses, shares, updates, secures, retains, and disposes of personal information obtained through www.parpl.org, counselling services, admission support services, educational platforms, student portals, communication channels, and future digital services operated within the Pathway Group ecosystem.

This Policy should be read together with our Privacy Policy, Consent Management Policy, Cookie Policy, Data Sharing Policy, Data Retention Policy, Terms & Conditions, and other applicable legal policies published on our Website.

Pathway Academic Resource Private Limited is incorporated under the Companies Act, 2013 bearing Corporate Identification Number (CIN): U80300GJ2013PTC076270, with its Registered Office at:

404, Atlantis Heights,

Opp. Vadiwadi Fire Station,

Sarabhai Main Road,

Vadodara – 390023,

Gujarat, India.

2. Purpose

The purpose of this Policy is to establish a consistent framework governing the processing of personal information throughout its lifecycle.

PARPL aims to ensure that personal information is:

  • Processed lawfully, fairly, and transparently.
  • Collected only for legitimate educational and business purposes.
  • Limited to information necessary for those purposes.
  • Maintained accurately and updated where appropriate.
  • Protected against unauthorized access or misuse.
  • Retained only for as long as necessary.
  • Securely deleted or anonymized when no longer required.
  • Processed in compliance with applicable legal and regulatory obligations.

3. Scope

This Policy applies to all personal information processed by PARPL through:

  • www.parpl.org
  • Student registration forms
  • Admission enquiry forms
  • Counselling registration forms
  • Application forms
  • Scholarship applications
  • Visa assistance services
  • MBBS Admission Predictor
  • Student Portal
  • Future Medico Campus platforms
  • Future OSMAT platforms
  • Customer Relationship Management (CRM) systems
  • Email communications
  • WhatsApp communications
  • Telephone enquiries
  • Social media enquiries
  • Meta Lead Ads
  • Google Lead Forms
  • Events and webinars
  • Offline documentation
  • Internal administrative systems
  • Any future digital or physical platform operated by PARPL.

This Policy applies to all directors, employees, consultants, interns, counsellors, admission advisors, contractors, service providers, and authorized third parties who process personal information on behalf of PARPL.

4. Definitions

For the purposes of this Policy:

Personal Information means any information relating to an identified or identifiable individual.

Processing includes any operation performed on personal information, including collection, recording, organization, storage, use, consultation, analysis, sharing, updating, retrieval, transmission, restriction, deletion, destruction, or anonymization.

Data Subject refers to the individual whose personal information is processed, including students, parents, guardians, applicants, employees, partners, website users, and other individuals interacting with PARPL.

Processing System means any digital or physical system used by PARPL to process information, including websites, databases, cloud platforms, CRM systems, student portals, document management systems, and communication platforms.

5. Principles of Data Processing

PARPL processes personal information according to the following principles:

Lawfulness

Personal information shall be processed only where permitted by applicable law or where appropriate consent or another valid legal basis exists.

Fairness

Processing activities shall be conducted honestly and without misleading individuals regarding the use of their information.

Transparency

Individuals shall be informed regarding how their information is processed through clear and accessible privacy notices and policies.

Purpose Limitation

Personal information shall only be collected for specified, legitimate, and clearly communicated purposes.

Data Minimization

Only personal information necessary to provide requested services or fulfil legal obligations shall be collected.

Accuracy

Reasonable steps shall be taken to ensure that personal information remains accurate, complete, and up to date.

Storage Limitation

Information shall not be retained longer than necessary for legitimate operational, contractual, regulatory, or legal purposes.

Security

Appropriate administrative, technical, and organizational safeguards shall be implemented to protect personal information.

Accountability

PARPL shall maintain appropriate governance measures demonstrating responsible data processing practices.

6. Categories of Personal Information Processed

Depending upon the services requested, PARPL may process the following categories of personal information.

Identity Information

  • Full name
  • Date of birth
  • Gender
  • Nationality
  • Passport information
  • Government-issued identification details
  • Photograph

Contact Information

  • Mobile number
  • Email address
  • Residential address
  • Permanent address
  • Parent or guardian contact details
  • Emergency contact information

Academic Information

  • Educational qualifications
  • Marksheets
  • Entrance examination details
  • Scores and rankings
  • Preferred courses
  • Preferred universities
  • Preferred countries
  • Academic achievements
  • Certificates

Admission Information

  • University applications
  • Counselling records
  • Admission status
  • Offer letters
  • Acceptance documents
  • Enrollment information

Financial Information

Where required for educational services:

  • Scholarship information
  • Education loan information
  • Payment records
  • Transaction references

PARPL does not intentionally collect or store payment card details. Payments processed through authorized payment gateway providers remain subject to their respective security standards and privacy practices.

Technical Information

  • IP address
  • Browser information
  • Device identifiers
  • Operating system
  • Website usage information
  • Cookie preferences
  • Session information
  • Security logs

Communication Records

  • Emails
  • WhatsApp conversations
  • SMS records
  • Telephone call records where legally permissible
  • Support requests
  • Counselling notes
  • Appointment records

Uploaded Documents

  • Academic certificates
  • Identity documents
  • Passport
  • Visa documents
  • Recommendation letters
  • Statement of Purpose
  • Resume or Curriculum Vitae
  • Other documents voluntarily submitted during the admission process

7. Sources of Personal Information

PARPL may collect personal information directly or indirectly from various sources, including:

  • Individuals submitting information through the Website.
  • Students seeking counselling or admission assistance.
  • Parents or legal guardians.
  • Educational institutions.
  • Universities.
  • Admission partners.
  • Scholarship providers.
  • Government authorities where required.
  • Publicly available information where legally permissible.
  • Customer support interactions.
  • Events, seminars, and webinars.
  • Social media lead generation campaigns.
  • Marketing campaigns.
  • Referral programmes.
  • Future Pathway Group platforms and digital services.

8. Purposes of Processing

PARPL processes personal information only for legitimate educational, contractual, operational, regulatory, or legal purposes.

These purposes include:

  • Providing educational counselling.
  • Assisting with admissions.
  • University shortlisting.
  • Processing applications.
  • Document verification.
  • Scholarship guidance.
  • Visa assistance.
  • Education loan support.
  • Student communication.
  • Appointment scheduling.
  • Managing enquiries.
  • Delivering educational resources.
  • Operating the MBBS Admission Predictor.
  • Improving website functionality.
  • Managing student relationships.
  • Internal administration.
  • Compliance with legal obligations.
  • Fraud prevention.
  • Information security.
  • Business continuity.
  • Service improvement.
  • Statistical analysis using aggregated or anonymized information where appropriate.

9. Processing Activities

PARPL processes personal information only to the extent necessary for providing educational counselling, admission support, student services, operational management, legal compliance, and the delivery of services requested by individuals.

Processing activities may include:

  • Collection of personal information.
  • Recording and organization of information.
  • Classification and indexing of records.
  • Verification of information and supporting documents.
  • Storage in secure digital or physical systems.
  • Retrieval of information for service delivery.
  • Updating and correction of records.
  • Communication with students, parents, institutions, and authorized partners.
  • Sharing information with authorized recipients where necessary.
  • Analysis of aggregated information for service improvement.
  • Generation of reports and operational insights.
  • Archiving information where legally required.
  • Deletion, anonymization, or secure destruction of information at the end of its retention period.

PARPL processes only the information necessary for the specific purpose for which it was collected.

10. Lawful Basis for Processing

PARPL processes personal information based on one or more lawful grounds permitted under applicable laws.

These lawful grounds may include:

  • Consent provided by the individual.
  • Performance of a contract or requested educational services.
  • Compliance with legal and regulatory obligations.
  • Protection of legitimate interests relating to educational counselling, admission assistance, fraud prevention, information security, and business operations.
  • Protection of vital interests where necessary.
  • Other lawful grounds recognized under applicable legislation.

Where consent is relied upon, individuals may withdraw their consent in accordance with the Consent Management Policy, subject to legal or contractual obligations.

11. Internal Access to Personal Information

Access to personal information is restricted strictly on a need-to-know basis.

Only authorized personnel whose responsibilities require access may process personal information.

Depending upon operational requirements, authorized personnel may include:

  • Directors.
  • Senior management.
  • Admission counsellors.
  • Student relationship executives.
  • Documentation specialists.
  • Visa support personnel.
  • Finance personnel.
  • Customer support executives.
  • Information technology personnel.
  • Compliance personnel.
  • Legal advisors.
  • Internal auditors.

Each authorized individual is expected to maintain confidentiality and comply with PARPL's internal information security requirements.

Access permissions are reviewed periodically and updated whenever organizational responsibilities change.

12. Responsibilities of Employees and Authorized Personnel

All employees, consultants, contractors, interns, and authorized representatives processing personal information on behalf of PARPL shall:

  • Process information only for authorized purposes.
  • Maintain confidentiality of all personal information.
  • Protect login credentials and system access.
  • Follow approved security procedures.
  • Report suspected security incidents immediately.
  • Prevent unauthorized disclosure of information.
  • Use only approved systems for processing personal information.
  • Complete privacy and security awareness training where applicable.
  • Comply with applicable laws and internal policies.

Unauthorized access, misuse, disclosure, copying, alteration, or removal of personal information may result in disciplinary action, termination of engagement, legal proceedings, or other appropriate action.

13. Accuracy and Quality of Information

PARPL takes reasonable steps to ensure that personal information remains accurate, complete, relevant, and up to date.

Individuals are encouraged to promptly notify PARPL of any changes relating to:

  • Contact information.
  • Educational qualifications.
  • Examination results.
  • Passport details.
  • Visa status.
  • Address.
  • Parent or guardian information.
  • Other relevant personal information.

Where inaccurate or incomplete information is identified, PARPL will make reasonable efforts to correct or update such information in accordance with applicable laws.

14. Data Security During Processing

PARPL implements appropriate technical and organizational safeguards throughout the processing lifecycle to protect personal information from unauthorized access, accidental disclosure, misuse, alteration, destruction, or loss.

Security measures may include:

  • Role-based access control.
  • Multi-factor authentication where applicable.
  • Strong password policies.
  • Encryption during transmission where appropriate.
  • Secure cloud infrastructure.
  • Firewalls and network security controls.
  • Antivirus and endpoint protection.
  • Secure document storage.
  • Activity logging and monitoring.
  • Regular software updates.
  • Security patch management.
  • Backup and disaster recovery procedures.
  • Physical security controls for office premises.
  • Employee confidentiality obligations.

Security controls are periodically reviewed and improved based on operational requirements and evolving cybersecurity risks.

15. Third-Party Data Processors

PARPL may engage trusted third-party service providers to process personal information on its behalf where necessary for delivering requested services.

Examples include:

  • Cloud hosting providers.
  • Customer Relationship Management (CRM) platforms.
  • Email service providers.
  • Payment gateway providers.
  • Communication platforms.
  • Document management systems.
  • Analytics providers.
  • Customer support software.
  • Educational technology platforms.
  • Information technology service providers.

Third-party processors are expected to:

  • Process personal information only in accordance with PARPL's instructions.
  • Maintain appropriate security measures.
  • Protect confidentiality.
  • Comply with applicable privacy laws.
  • Notify PARPL of significant security incidents affecting personal information where required.

PARPL undertakes reasonable due diligence before engaging third-party processors.

16. International Processing

As PARPL provides admission guidance for educational institutions located in multiple countries, certain personal information may be processed, stored, or transferred outside India where necessary for providing requested educational services.

International processing may occur when information is shared with:

  • Universities.
  • Educational institutions.
  • Scholarship providers.
  • Visa authorities.
  • International admission partners.
  • Technology service providers supporting global operations.

Where reasonably practicable, PARPL shall implement appropriate contractual, technical, and organizational safeguards to protect personal information during international processing.

17. Automated Processing and Educational Tools

PARPL may use digital systems and educational tools to improve operational efficiency and enhance student services.

These tools may include:

  • MBBS Admission Predictor.
  • Student portals.
  • Application tracking systems.
  • CRM platforms.
  • Appointment scheduling systems.
  • Communication management systems.
  • Analytics platforms.
  • Future technology-enabled educational services.

The MBBS Admission Predictor provides indicative guidance based on historical admission trends and information submitted by users.

Results generated by the Predictor are intended solely for educational guidance and should not be interpreted as admission decisions, counselling outcomes, or guarantees of admission.

Where future automated decision-support or artificial intelligence technologies materially affect the processing of personal information, PARPL will update its policies and obtain consent where required by applicable law.

18. Data Quality Reviews

PARPL periodically reviews the quality, relevance, and accuracy of information processed within its systems.

Such reviews may include:

  • Duplicate record identification.
  • Verification of outdated information.
  • Removal of unnecessary records.
  • Validation of mandatory fields.
  • Review of inactive accounts.
  • Secure archival of historical records.
  • Compliance checks against applicable retention requirements.

These reviews help maintain the integrity and reliability of information processed by PARPL.

19. Data Breach and Incident Management

PARPL maintains procedures for identifying, investigating, managing, documenting, and responding to actual or suspected incidents involving personal information.

In the event of a security incident, PARPL may:

  • Assess the nature and scope of the incident.
  • Contain and mitigate the impact.
  • Restore affected systems where necessary.
  • Conduct internal investigations.
  • Implement corrective measures.
  • Notify affected individuals or competent authorities where required by applicable law.
  • Review and strengthen security controls to reduce the likelihood of future incidents.

All personnel are expected to report suspected security incidents immediately through established internal reporting channels.

20. Compliance Monitoring and Audits

PARPL periodically reviews its data processing activities to ensure continued compliance with applicable laws, internal policies, contractual obligations, and recognized best practices.

Compliance activities may include:

  • Internal policy reviews.
  • Operational assessments.
  • Access permission reviews.
  • Security evaluations.
  • Vendor assessments.
  • Documentation reviews.
  • Risk assessments.
  • Corrective action monitoring.

Where appropriate, PARPL may engage internal or external auditors to assess compliance with applicable legal and regulatory requirements.

21. Changes to this Policy

PARPL reserves the right to modify or update this Data Processing Policy to reflect changes in applicable laws, technology, business operations, regulatory requirements, or services offered through the Pathway Group ecosystem.

The latest version of this Policy will always be published on www.parpl.org together with the updated "Last Updated" date.

Continued use of the Website or PARPL's services after publication of an updated Policy constitutes acknowledgement of the revised Policy to the extent permitted by applicable law.

22. Contact Us

If you have any questions regarding this Data Processing Policy or the manner in which PARPL processes personal information, please contact:

Pathway Academic Resource Private Limited (PARPL)
A Pathway Group Company

Corporate Identification Number (CIN):
U80300GJ2013PTC076270

Registered Office:
404, Atlantis Heights,
Opp. Vadiwadi Fire Station,
Sarabhai Main Road,
Vadodara – 390023, Gujarat, India.

Website:
www.parpl.org

Privacy Email:
privacy@parpl.org