Data Sharing 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 protecting the confidentiality, integrity, and security of personal information entrusted to us.
As part of providing educational counselling, admission assistance, student support, and related services, PARPL may need to share personal information with authorized third parties. This Data Sharing Policy explains when, why, and how such sharing occurs and the safeguards implemented to protect personal information throughout the sharing process.
This Policy should be read together with our Privacy Policy, Consent Management Policy, Data Processing Policy, Data Retention Policy, Cookie Policy, Terms & Conditions, and other applicable legal policies available 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 transparent framework governing the sharing of personal information by PARPL.
PARPL aims to ensure that personal information is shared:
- Only where necessary for legitimate educational, contractual, operational, regulatory, or legal purposes.
- Only with authorized recipients.
- Only to the extent necessary for the intended purpose.
- Securely and responsibly.
- In accordance with applicable laws.
- With appropriate contractual and organizational safeguards wherever reasonably practicable.
3. Scope
This Policy applies to all personal information processed or shared through:
- www.parpl.org
- Student registration forms
- Admission enquiry forms
- Counselling services
- University applications
- Scholarship applications
- Visa assistance services
- MBBS Admission Predictor
- Student Portal
- Future Medico Campus platforms
- Future OSMAT platforms
- CRM systems
- Email communications
- WhatsApp communications
- Telephone enquiries
- Offline documentation
- Educational seminars and webinars
- Marketing campaigns
- Future digital platforms operated by PARPL
This Policy applies to all employees, counsellors, consultants, contractors, interns, directors, service providers, and authorized third parties acting on behalf of PARPL.
4. Principles of Data Sharing
PARPL follows the following principles whenever personal information is shared.
Necessity
Personal information shall only be shared where reasonably necessary to deliver requested services or comply with legal obligations.
Purpose Limitation
Information shall only be shared for the specific purpose for which it was collected or another compatible lawful purpose.
Data Minimization
Only the minimum amount of personal information necessary for the receiving party to perform its responsibilities shall be shared.
Accuracy
Reasonable efforts shall be made to ensure that shared information is accurate and up to date.
Security
Appropriate technical and organizational safeguards shall be implemented during the sharing process.
Accountability
PARPL remains responsible for ensuring that information sharing is carried out in accordance with applicable laws and internal policies.
5. Categories of Personal Information That May Be Shared
Depending upon the services requested by the individual, PARPL may share one or more of the following categories of personal information:
Identity Information
- Full name
- Date of birth
- Gender
- Nationality
- Passport details
- Government-issued identification details
- Photograph
Contact Information
- Mobile number
- Email address
- Residential address
- Parent or guardian contact information
- Emergency contact details
Academic Information
- Educational qualifications
- Marksheets
- Entrance examination details
- Examination scores
- Academic certificates
- Preferred universities
- Preferred countries
- Course preferences
Admission Information
- Application forms
- Counselling records
- University selections
- Offer letters
- Admission status
- Enrollment information
Financial Information
Where necessary:
- Scholarship information
- Education loan information
- Payment confirmations
- Financial supporting documents
Supporting Documents
- Passport
- Identity proof
- Academic certificates
- Recommendation letters
- Statement of Purpose
- Curriculum Vitae or Resume
- Visa documentation
- Other documents voluntarily submitted by the student
6. Parties With Whom Information May Be Shared
PARPL may share personal information only with authorized organizations where necessary to provide requested educational services.
Such recipients may include:
Educational Institutions
- Universities
- Colleges
- Medical institutions
- Educational boards
- Academic partners
Admission Partners
- Authorized university representatives
- Recruitment partners
- International admission offices
- Educational consultants working on behalf of partner institutions
Scholarship Organizations
Where scholarship guidance has been requested, information may be shared with:
- Scholarship providers
- Sponsoring organizations
- Funding agencies
- Educational trusts
Visa and Immigration Service Providers
Where international education services are requested, information may be shared with:
- Visa consultants
- Immigration support agencies
- Authorized document verification agencies
- Embassy-authorized service providers
Government Authorities
Where required by law or official procedures, information may be shared with:
- Government departments
- Regulatory authorities
- Statutory bodies
- Educational regulators
- Law enforcement authorities where legally required
Financial Service Providers
Where relevant:
- Payment gateway providers
- Banking institutions
- Education loan providers
- Financial verification agencies
Technology Service Providers
To operate our digital services, PARPL may engage:
- Cloud hosting providers
- CRM providers
- Email communication providers
- SMS gateway providers
- WhatsApp Business service providers
- Analytics providers
- IT infrastructure providers
- Cybersecurity service providers
Professional Advisors
Where reasonably necessary:
- Auditors
- Legal advisors
- Chartered accountants
- Compliance consultants
- Insurance providers
Pathway Group Entities
Where necessary to provide integrated educational services, personal information may be shared among authorized entities operating within the Pathway Group ecosystem, provided such sharing remains consistent with the purposes for which the information was originally collected and is subject to appropriate confidentiality and security safeguards.
7. Conditions for Sharing Personal Information
PARPL shares personal information only where one or more of the following conditions apply:
- The individual has provided valid consent.
- Sharing is necessary to provide the educational or counselling services requested.
- Sharing is required to process university applications, scholarship applications, visa applications, or related educational services.
- Sharing is required to comply with applicable laws, regulations, judicial orders, or lawful requests from competent authorities.
- Sharing is necessary to protect the rights, safety, or legitimate interests of PARPL, its users, or third parties.
- Sharing is necessary to investigate or prevent fraud, cybersecurity incidents, or unlawful activities.
- Sharing is otherwise permitted under applicable law.
PARPL shall not share personal information for purposes unrelated to those described in this Policy without obtaining additional consent where required by law.
8. Consent for Data Sharing
Where required under applicable law, PARPL shall obtain appropriate consent before sharing personal information with third parties.
Consent may be obtained through:
- Website registration forms.
- Admission application forms.
- Counselling registration forms.
- Digital consent checkboxes.
- Written consent forms.
- Electronic agreements.
- Email confirmations.
- Parent or guardian consent for minors.
- Other legally acceptable methods.
Consent shall clearly explain:
- The categories of information being shared.
- The purpose of sharing.
- The categories of recipients.
- Whether international sharing may occur.
- The individual's rights regarding such sharing.
Where processing or sharing is necessary to fulfil a service specifically requested by the individual, additional consent may not be required where permitted by applicable law.
9. Sharing Within the Pathway Group Ecosystem
To provide integrated educational services and improve the user experience, PARPL may share personal information with authorized entities operating within the Pathway Group ecosystem.
Such sharing may occur for purposes including:
- Student counselling.
- Admission assistance.
- Student account management.
- Educational assessments.
- Academic guidance.
- Operational administration.
- Technical support.
- Customer relationship management.
- Internal reporting.
- Compliance and risk management.
Any sharing within the Pathway Group shall remain limited to the minimum information necessary for the relevant purpose and shall be subject to confidentiality obligations and appropriate security controls.
10. International Data Sharing
As PARPL provides admission guidance for educational institutions located outside India, personal information may be transferred to organizations located in other countries where necessary to provide requested services.
International recipients may include:
- Universities.
- Colleges.
- Medical schools.
- Admission offices.
- Scholarship organizations.
- Visa authorities.
- Immigration support agencies.
- International education partners.
- Cloud service providers supporting international operations.
Where reasonably practicable, PARPL shall implement appropriate contractual, technical, and organizational safeguards to protect personal information transferred internationally.
Individuals requesting overseas admission services acknowledge that international sharing of relevant personal information may be necessary for the processing of their applications.
11. Security During Data Sharing
PARPL takes reasonable steps to protect personal information during transmission and sharing.
Security measures may include:
- Encrypted communication channels where appropriate.
- Secure document transfer methods.
- Password-protected files.
- Access controls.
- Identity verification before disclosure.
- Confidentiality agreements.
- Role-based access permissions.
- Secure cloud platforms.
- Audit logging where applicable.
- Vendor security assessments.
Despite implementing reasonable safeguards, no method of electronic transmission or storage can guarantee absolute security.
12. Responsibilities of Third-Party Recipients
Organizations receiving personal information from PARPL are expected to:
- Process information only for the authorized purpose.
- Maintain appropriate confidentiality.
- Implement reasonable security safeguards.
- Restrict access to authorized personnel.
- Comply with applicable privacy and data protection laws.
- Prevent unauthorized disclosure.
- Notify PARPL of significant security incidents affecting shared information where contractually or legally required.
- Securely dispose of information when it is no longer required.
PARPL undertakes reasonable due diligence before engaging service providers that process personal information on its behalf.
13. Information We Do Not Sell
PARPL does not sell, rent, lease, trade, or commercially exploit personal information belonging to students, parents, institutions, or other users.
Personal information is shared solely for legitimate educational, operational, contractual, regulatory, or legal purposes as described in this Policy and our Privacy Policy.
PARPL does not permit third parties to purchase personal information for marketing or unrelated commercial purposes.
14. Requests from Government and Regulatory Authorities
PARPL may disclose personal information where required to comply with:
- Applicable laws.
- Court orders.
- Government investigations.
- Regulatory requirements.
- Law enforcement requests.
- Judicial proceedings.
- Statutory obligations.
Before disclosing information, PARPL will, where reasonably practicable, verify the legitimacy of the request and disclose only the information necessary to comply with the applicable legal obligation.
Where legally prohibited, PARPL may be unable to notify affected individuals before such disclosure.
15. Data Subject Requests
Individuals may request information regarding the sharing of their personal information, subject to applicable laws and operational limitations.
Where permitted by law, individuals may request to:
- Obtain information regarding categories of recipients.
- Correct inaccurate information before sharing.
- Withdraw consent for future sharing where processing is based on consent.
- Request deletion of personal information, subject to legal and contractual obligations.
- Raise concerns regarding information sharing practices.
PARPL may require reasonable identity verification before acting upon any request.
Certain requests may be declined where disclosure or deletion would conflict with applicable legal obligations, contractual commitments, or the legitimate interests of PARPL or third parties.
16. Data Sharing Incident Management
PARPL maintains procedures for identifying, investigating, documenting, and responding to incidents involving the unauthorized disclosure or sharing of personal information.
Where a data sharing incident occurs, PARPL may:
- Assess the nature and scope of the incident.
- Contain the incident.
- Investigate the underlying cause.
- Implement corrective measures.
- Strengthen security controls.
- Notify affected individuals where required by applicable law.
- Notify competent regulatory authorities where legally required.
PARPL periodically reviews its data sharing practices to reduce operational and security risks.
17. Compliance and Policy Review
PARPL periodically reviews this Policy to ensure continued compliance with applicable laws, business requirements, contractual obligations, technological developments, and recognized industry practices.
Internal reviews may include:
- Assessment of information sharing practices.
- Vendor and partner reviews.
- Compliance audits.
- Security assessments.
- Risk evaluations.
- Documentation reviews.
- Policy effectiveness assessments.
Where appropriate, updates will be made to improve transparency, accountability, and the protection of personal information.
18. Changes to this Policy
PARPL reserves the right to modify or update this Data Sharing Policy from time to time to reflect changes in applicable laws, regulatory requirements, technology, business operations, 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.
19. Contact Us
If you have any questions regarding this Data Sharing Policy or wish to obtain further information regarding how PARPL shares 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
