Privacy Policy

Introduction

This Privacy Policy explains how FirstGrad Private Limited ("FirstGrad," "we," "us," or "our") collects, uses, shares, and protects personal data across our services. This policy applies to:

• Visitors to our website ("Website Visitors")
• Students and applicants using our counseling, application, and related services ("Service Users")
• Everyone who otherwise interacts with us (collectively, "you")

By using our website, applying through our platform, or otherwise engaging with services that link to this policy, you agree to its terms.

Note: This Privacy Policy works in tandem with our Terms of Use, which describe additional conditions governing your access to our services. In the event of any conflict between this Privacy Policy and our Terms of Use regarding data handling, this Privacy Policy will govern.

We encourage you to review this Privacy Policy periodically, as we may update it to reflect changes in our practices or applicable law.

Scope of This Privacy Policy

To help you find relevant information quickly, this policy is divided into three sections:

• Section A: Privacy Policy for Website Visitors
• Section B: Privacy Policy for Students & Applicants
• Section C: General Privacy Practices (applicable to everyone)

Following these, you will find Your Privacy Rights, Data Protection & Security, Children's Privacy, and other standard provisions.

Section A — Privacy Policy for Website Visitors

This section applies to anyone who visits or browses our website, whether or not they go on to apply for our services.

Information We Collect

Automatic Data Collection

• Cookies and Similar Technologies: We use cookies and similar tools to understand website usage and improve user experience.
• Device and Usage Data: Information about your device (IP address, browser type, operating system) and how you interact with our website (pages viewed, links clicked, time spent).

Information You Provide

• Contact details submitted through inquiry or "get started" forms (e.g., name, phone number, email address).
• Questions or feedback shared via our website or chatbot.

How We Use This Information

• To respond to inquiries and follow up on applications you start.
• To analyze website performance and improve usability.
• To secure our website against unauthorized access or misuse.

Your Choices as a Website Visitor

• Cookie Management: You can configure cookie preferences through our cookie banner or your browser settings. Disabling non-essential cookies will not affect your ability to browse the site, but may affect personalization.
• Communications: If you submit an inquiry form, we will follow up about that inquiry. You can ask us to stop at any time by emailing hello@firstgrad.in.

Section B — Privacy Policy for Students & Applicants

This section applies once you start an application, counseling relationship, or any service engagement with us ("Service Users").

Information We Collect

Contact & Account Data. Name, phone number, email address, date of birth, gender, nationality, and residential address.

Academic & Application Data. Academic transcripts and certificates, standardized test scores (IELTS, TOEFL, GRE, GMAT, etc.), course preferences and career goals, resume/CV, Statements of Purpose, Letters of Recommendation, and essays.

Identity & Financial Data ("Sensitive Personal Data"). Passport details, visa information, government-issued identification, bank statements or income proof, loan documentation, and sponsor/guarantor information.

We collect this category of data only with your separate, explicit consent, given at the point we need it (for example, when you apply for loan facilitation or visa support), not bundled into a general sign-up consent.

Parent/Guardian Information. Where you are a minor, we collect your parent or legal guardian's name, contact details, and verifiable consent (see "Children's Privacy" below).

Communication Records. WhatsApp messages, email correspondence, SMS logs, form submissions, and chatbot interactions. Phone calls are recorded only with your express, advance consent.

How We Collect This Information

We collect this data when you submit forms, communicate with us via WhatsApp, email, SMS, or phone, upload or share documents, attend counseling sessions, or engage with our partner institutions.

How We Use This Information

Service Delivery

• Counseling and profile assessment
• University and course shortlisting
• Application preparation and submission
• Document review and verification
• Visa guidance, loan facilitation, and scholarship identification
• Accommodation and "essentials" setup (bank account, phone plan) where you request it

Application Submission Authority

By engaging our counselling and application services, you expressly authorise FirstGrad to submit applications, enquiries, and supporting documents to universities, educational institutions, and relevant partners on your behalf. This authorisation covers all institutions included in your agreed shortlist and remains in effect until you withdraw it in writing to hello@firstgrad.in or your engagement with us concludes. FirstGrad acts as your representative in this process and is not liable for decisions made independently by institutions. FirstGrad is not liable for any outcomes from already-submitted applications upon withdrawal.

Communication & Support

• Sending application updates, deadline reminders, and verification requests
• Coordinating with universities, lenders, insurers, and other partners on your behalf

Platform Improvement

• Improving our counseling tools, dashboards, and recommendation features
• Developing and refining AI-assisted matching and recommendation tools

Security & Compliance

• Fraud and identity-document verification
• Meeting legal, regulatory, and contractual obligations

Automated Tools & AI-Assisted Recommendations

We use AI-assisted tools to help generate university shortlists and profile recommendations. These tools assist our counselors, they do not make final decisions on your behalf, and they never replace the independent decisions made by universities, lenders, insurers, or immigration authorities.

Legal Grounds for Processing

We process your personal data on the following grounds, consistent with the Digital Personal Data Protection Act, 2023:

• Your explicit consent, particularly for sensitive personal data
• Performance of the services you have requested from us
• Legal obligations we are subject to
• Legitimate uses permitted under applicable law

Partner Relationships & Compensation Disclosure

We work with university partners, lending institutions, insurance providers, and accommodation partners to deliver our services. We may receive a referral fee or commission from some lending, insurance, or accommodation partners when you use their services through us. This does not change the price you pay those partners, and it does not influence our university shortlisting recommendations, which are based on your academic and career profile. We do not guarantee admission, loan approval, visa approval, or any other outcome, these decisions rest solely with the relevant third party.

Data Retention

We retain your personal data only for as long as necessary to deliver the specific service you requested, or as required by law, whichever is longer. As a general matter:

• Academic and application documents are retained for the duration of your active application cycle and for a reasonable period afterward to handle follow-up queries, disputes, or re-applications.
• If your account is inactive for 24 months, we will attempt to notify you before deleting your data, subject to any legal retention requirement.
• Sensitive personal data (passport, financial, visa documents) is deleted once the specific purpose it was collected for is complete, unless you ask us to retain it for a future application or we are legally required to keep it.

You may request earlier deletion at any time by contacting us (see "Your Privacy Rights" below).

Section C — General Privacy Practices

These practices apply to everyone: Website Visitors and Service Users alike.

How We Share or Disclose Your Personal Information

By using our services, you authorize us to share your personal information and application materials with universities, educational institutions, lenders, scholarship providers, accommodation partners, insurers, and other third parties that are reasonably necessary to provide the services you request. We share only the information required for the relevant purpose.

(You represent and warrant that all information and documents you provide to us are accurate, complete, and that you have the authority to permit us to use and disclose them for these purposes.)

We share personal data only where necessary, and only the categories relevant to that purpose:

• Universities & Educational Institutions: for application submission, eligibility checks, and admissions decisions, with your consent.
• Financial Institutions & Loan Partners: only if you request loan or financing assistance.
• Insurance Providers: only if you request health-coverage assistance.
• Accommodation Partners: only if you request housing support.
• Service Providers (Subprocessors): for hosting, CRM, communications, analytics, and payment processing, bound by confidentiality obligations (see Section B).
• Professional Advisors: such as lawyers and auditors, as necessary.
• Legal Authorities: in response to a valid legal request. Where lawful and feasible, we will attempt to notify you before disclosure, and we reserve the right to challenge requests we consider overly broad.
• Business Transferees: during a merger, acquisition, or similar transaction, under confidentiality obligations.

Cross-Border Data Transfers

Your data may be stored or processed outside India (for example, with cloud infrastructure providers). Where this happens, we use appropriate contractual safeguards. We will comply with any country-specific transfer restrictions notified by the Government of India under the Digital Personal Data Protection Act, 2023.

Your Privacy Rights

If you have any questions or wish to exercise any of these rights, contact our Grievance Officer (see "Contact Us" below). We will verify your identity before fulfilling requests and aim to respond within the timelines prescribed by applicable law.

• Access: Request a copy of your personal data and information on how we process it.
• Correction: Have inaccurate or incomplete data corrected.
• Erasure: Request deletion of your personal data, subject to legal or contractual exceptions.
• Withdraw Consent: Withdraw consent for any consent-based processing at any time. Withdrawing consent is as simple as giving it, a single email to us is sufficient, though it will not affect processing already carried out, and it may limit our ability to continue certain services (for example, loan facilitation).
• Grievance Redressal: Raise a complaint with our Grievance Officer about how your data has been handled.
• Nomination: Nominate another individual to exercise these rights on your behalf in the event of your death or incapacity.
• Lodge a Complaint: Approach the Data Protection Board of India if you believe your complaint has not been satisfactorily resolved by us.

We will not discriminate against you, or reduce the quality of service we provide, for exercising any of these rights.

Data Protection & Security

Security Measures: We implement reasonable technical and organizational safeguards, including encryption in transit, access controls, and restricted internal access to sensitive documents (passport, financial, and visa data). While no system is entirely immune from intrusion, we maintain incident-response procedures to investigate and contain any breach.

Data Breach Response: If a security incident occurs affecting your personal data, we will investigate and contain it promptly, assess its scope, notify the Data Protection Board of India and affected individuals within the timelines required by applicable law, and implement corrective measures.

Children's Privacy

Some of our Service Users are under 18, particularly undergraduate applicants. If you are under 18, you may use our services only with the verifiable consent of a parent or legal guardian. The parent or guardian is responsible for the minor's use of our services. We do not use minors' personal data for advertising or behavioral tracking. If we learn that a minor's data was collected without valid guardian consent, we will take steps to delete it.

Cookies & Tracking

We use cookies and similar technologies for functionality, analytics, and performance, as described in Section A. You may adjust your browser settings to limit cookies, though this may affect some website features.

Communications

By using our services, you consent to receive communications via WhatsApp, email, SMS, and phone for application updates, deadlines, verification requests, and service instructions. You may opt out of marketing messages at any time by contacting hello@firstgrad.in; essential service communications related to your active application will continue regardless, as they are necessary to deliver the service you requested.

Third-Party Links & Tools

Our website may link to or integrate with third-party tools (including university portals, lender platforms, and insurance providers). We are not responsible for the privacy practices of these third parties. Please review their privacy policies separately.

Success Stories & Testimonials

As outlined in our Terms of Use, we may use your success story, admission results, and related information (including your name and program details) in our promotional materials. We will make reasonable efforts to notify you before featuring your story, and you may opt out at any time by contacting hello@firstgrad.in.

Changes to This Policy

We may update this Privacy Policy at any time. Updated versions will be posted with a revised Effective Date, and where changes are material, we will provide additional notice (for example, by email). Your continued use of our services after an update constitutes acceptance of the changes.

Contact Us / Grievance Officer

For any questions, rights requests, or grievances regarding this Privacy Policy:

Grievance Officer: Sunitha Nair
Email: hello@firstgrad.in
Address: FirstGrad Private Limited, 1B 606, Elan Divayshree, Sarjapur Rd, Bangalore, Karnataka, India 560035

We aim to respond to all inquiries within 30 days or the timeframe required by applicable law (whichever is more). If your concern is urgent or involves a potential data breach, please mark it as such so we can prioritize accordingly.

Disclaimer: While we strive to comply with all applicable privacy regulations, nothing in this policy should be construed as legal advice. If you have specific legal questions or concerns about our data practices, we encourage you to consult with an attorney.

By using FirstGrad's services, you acknowledge that you have read and understood this Privacy Policy.