1Introduction
Welcome to PARAGON INTERNATIONAL ("Company", "we", "our", or "us"). We are committed to protecting your privacy and ensuring that your personal information is processed lawfully, fairly, and transparently. This Privacy Policy explains how we collect, use, disclose, store, and protect your personal data when you visit our website, enquire about our services, submit an application, or engage with us for education counselling, admissions, or visa-related services.
Our services include student recruitment and admissions support for universities and higher education institutions in the United Kingdom, Germany, Europe, Canada, Australia, and other international destinations.
We process all personal data strictly in compliance with the following data protection laws:
- The UK General Data Protection Regulation (UK GDPR);
- The Data Protection Act 2018 (DPA 2018); and
- The UK Visas and Immigration (UKVI) Agent Quality Framework (AQF).
2Data Controller & Contact Details
For the purposes of the UK GDPR, PARAGON INTERNATIONAL is the Data Controller of your personal data. This means we determine the purposes and means of processing your personal information.
Our identity and full contact details are as follows:
| Data Controller Name | PARAGON INTERNATIONAL |
| Registered Address | Office No:9, 1st Floor, Raiwind Trade Center. 10-G, PIA Housing Society Wapda Town Lahore. |
| Email Address | Paragonint2002@gmail.com |
| Telephone Number | +92 300 4027794 |
| Data Protection Officer (DPO) | Our Data Protection Officer can be contacted directly at the email address provided above. |
3Lawful Basis, Purposes & Categories of Data
We must have a valid lawful basis under Article 6 (and Article 9 for special category data, where applicable) of the UK GDPR to process your personal data. Below, we set out the categories of data we collect, how we collect it, the purposes of processing, and the exact lawful bases we rely on:
| Category of Personal Data | How We Collect It | Purpose of Processing | UK GDPR Lawful Basis |
|---|---|---|---|
| Identity & Contact Data (Name, DOB, gender, nationality, passport details, address, email, phone number) | Directly from you via enquiry forms, online portal, CV submissions, emails, and meetings. | To identify you, verify your eligibility for international study, and communicate about programs. | Performance of a Contract (Art. 6(1)(b)) to take steps prior to entering into a contract, and Legitimate Interests (Art. 6(1)(f)) to manage student enquiries. |
| Academic & Employment Data (Certificates, transcripts, personal statements, CV, reference letters, English test scores) | Provided directly by you or via designated third-party referees / language testing bodies. | To assess your academic eligibility and submit applications to target universities/colleges. | Performance of a Contract (Art. 6(1)(b)) — necessary to process and submit university applications on your behalf. |
| Financial & Immigration Data (Bank statements, sponsorship letters, previous visa history, share codes, CAS) | Provided by you, sponsors, or financial institutions. | To verify financial capability and complete visa/CAS compliance reviews as required by educational partners & UKVI. | Performance of a Contract (Art. 6(1)(b)) and Compliance with Legal Obligations (Art. 6(1)(c)) under UKVI immigration rules. |
| Special Category Data (Health conditions, accessibility needs, criminal offense disclosures — where strictly required) | Voluntarily disclosed by you during the application/visa medical assessment stages. | To coordinate necessary reasonable adjustments with universities and comply with mandatory medical checks. | Explicit Consent (Art. 9(2)(a)) and/or Social Protection Law (Art. 9(2)(b)). |
| Technical & Analytical Data (IP address, cookies, usage logs, browser type) | Automatically collected via cookies and tracking pixels when you visit our website. | To maintain website security, analyze usage trends, and improve system performance. | Consent (Art. 6(1)(a)) for non-essential cookies, and Legitimate Interests (Art. 6(1)(f)) for essential security cookies. |
4Data Retention Schedule
We do not store your personal data indefinitely. We only retain personal data for as long as necessary to fulfill the purposes for which it was collected, including legal, accounting, compliance, and regulatory reporting obligations.
The criteria we use to determine our retention periods include:
- The duration of our active relationship with you (e.g., while actively counselling or managing your applications);
- The existence of statutory limitation periods under relevant national laws (typically 6 years for contractual claims in the UK);
- Regulatory requirements set by international educational institutions, accreditation boards, and immigration authorities (such as UKVI and the AQF).
| Category of Data | Retention Period | Retention Rationale / Criteria |
|---|---|---|
| Enquiries & General Communication | 2 Years from the date of last contact | Kept to handle follow-up admissions queries or re-engagement within standard academic cycles. |
| Successful Applications & Visa Records | 6 Years after the conclusion of our service contract / course intake date | Necessary to fulfill legal contract claims, audit requirements of university partners, and comply with UKVI/AQF verification requests. |
| Unsuccessful / Withdrawn Applications | 2 Years from the closure of the target academic intake year | Retained briefly to answer appeals, verify previous attempts, and fulfill institutional audit logs. |
| Financial Documents & Audit Records | 7 Years from the end of the financial year in which the transaction occurred | To comply with legal corporate tax and accounting obligations under national legislation. |
| Technical & Analytics Cookies | Up to 12 months from your website visit | Based on industry standard cookie decay policies. |
5International Data Transfers & Safeguards
Because we support recruitment and admissions to universities located worldwide, we may transfer your personal data to institutions and service providers located outside of the United Kingdom or the European Economic Area (EEA).
When your personal data is transferred internationally, we implement strict legal and technical safeguards to ensure that it receives an equivalent level of protection to that under the UK GDPR. These safeguards include:
- UK Adequacy Regulations: Transferring data to countries that have been officially recognized by the UK Government as providing an adequate level of data protection.
- Standard Contractual Clauses (SCCs) & UK Addendum: Utilizing approved Standard Contractual Clauses with the UK Addendum to enforce data protection obligations on international recipients.
- International Data Transfer Agreements (IDTAs): Employing the UK ICO-approved IDTA where custom transfer terms with overseas institutions are established.
- Explicit Necessity: Where transfer is strictly required to execute the pre-contractual steps of submitting your overseas application, we rely on Article 49 derogations, ensuring your prior informed consent.
6Automated Decision-Making & Profiling
Under Article 22 of the UK GDPR, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects concerning you.
Our Commitment: We do not perform any automated decision-making or profiling that results in legal or significant consequences for you. All academic evaluations, visa eligibility consultations, and university application reviews are conducted with substantial human intervention by our trained educational counselors.
7Your Rights Under UK GDPR
Under the UK GDPR, you possess several legal rights regarding your personal data. We are committed to facilitating these rights whenever you request:
Right to Access (SAR)
You have the right to request a copy of the personal data we hold about you, along with detailed explanations of how and why we process it.
Right to Rectification
You have the right to demand that we correct inaccurate or incomplete personal information we hold about you without undue delay.
Right to Erasure
You have the right to request that we delete your personal data under certain conditions, such as when the data is no longer necessary for the original purposes, or you have withdrawn your consent and no other lawful basis exists.
Right to Restrict Processing
You have the right to request that we temporarily suspend the processing of your personal data (for example, while we verify the accuracy of your data or investigate your objection).
Right to Object
You have the right to object to us processing your data under Legitimate Interests. We will cease processing unless we can demonstrate compelling, overriding legitimate grounds that supersede your rights.
Right to Data Portability
You have the right to request that we transfer your personal data to you or directly to another data controller in a structured, commonly used, and machine-readable format.
8Right to Withdraw Consent
Where we rely on your explicit consent as our lawful basis for processing your personal data (such as for certain non-essential marketing, special category data collection, or particular application procedures), you have the absolute right to withdraw your consent at any time.
To withdraw your consent, please contact us directly using the details provided in Section 16 of this policy. Once received, we will immediately stop the processing of your data for that specific purpose, unless there is another legally valid lawful basis under the UK GDPR that allows us to continue.
9Right to Lodge a Complaint with the ICO
We strive to handle your personal data securely and in full accordance with your expectations. However, if you believe we have not processed your data in compliance with the UK GDPR, you have the legal right to lodge a formal complaint with the UK supervisory authority, the Information Commissioner's Office (ICO).
Information Commissioner's Office (ICO)
Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline Telephone: 0303 123 1113
Website: https://ico.org.uk/
10Data Security
We implement appropriate technical and organizational security measures to protect your personal data, including:
- SSL Encryption
- Password-protected systems
- Secure cloud storage
- Restricted physical and digital access controls
- Two-factor authentication
- Secure backup procedures
Although we take reasonable precautions, no online transmission can be guaranteed to be completely secure.
12Children's Privacy
Our services may involve applicants under the age of 18. Where required, parental or guardian consent will be obtained before processing the personal information of minors.
13UKVI Agent Quality Framework Commitment
As an authorized education recruitment agency, we are committed to the principles of the UKVI Agent Quality Framework. We undertake to:
- Provide honest, transparent, and ethical advice
- Protect applicant confidentiality
- Handle personal data securely
- Maintain accurate student records
- Prevent fraud and document manipulation
- Act in the best interests of applicants
14GDPR Compliance Statement
We are fully committed to complying with the UK General Data Protection Regulation. Our organization strictly follows the core principles of:
Lawfulness, Fairness & Transparency · Purpose Limitation · Data Minimization · Accuracy · Storage Limitation · Integrity & Confidentiality · Accountability
15Changes to this Privacy Policy
We may amend this Privacy Policy from time to time to reflect changes in legislation, business practices, or our services. The updated version will always be published on this page with the revised effective date.
16Contact Us
If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact us at: