Privacy Policy

Student Referral and Education Pathway Services

Last updated: 1 October 2026

1. About Global Pathway Partners (GP2)

Global Pathway Partners Ltd (GP2) is a company registered in England and Wales. GP2 operates as an international education referral business. We help prospective students explore study opportunities, collect and assess initial enquiry information, and refer suitable prospective students through our Agent Partners and/or relevant education-provider pathways.

GP2 is not a university, college or awarding body. GP2 does not make admission decisions, issue qualifications, issue a Confirmation of Acceptance for Studies (CAS), make visa decisions or guarantee an offer, admission, visa or enrolment.

Depending on the relevant arrangement, applications and subsequent admissions support may be handled by an Agent Partner, university, college or other education provider. Final admission decisions remain the responsibility of the relevant education institution.

For personal information where GP2 decides why and how it is processed, GP2 acts as the data controller. An Agent Partner, university, college or other organisation receiving information may act as a separate controller for its own processing, depending on its role, and may provide its own privacy information.

Global Pathway Partners Ltd is registered in England and Wales under company number 17347718.

Registered Office:
Gatehouse Kiosk, The Wharf,
16 Bridge Street, Birmingham,
United Kingdom.

Privacy contact: privacy@gp2.online
General enquiries: info@gp2.online

2. Scope of This Privacy Policy

This Privacy Policy explains how GP2 collects, uses, stores, protects and shares personal information when you:

  • visit or interact with gp2.online;
  • submit an enquiry or referral form;
  • communicate with GP2 or a GP2 Student Referral Executive (SRE);
  • ask GP2 to help identify or refer you to a suitable education pathway;
  • provide information or documents for an education enquiry or referral;
  • participate in GP2 marketing campaigns or social-media activities; or
  • otherwise use GP2’s services.

GP2 may support prospective students in different countries and study destinations. This policy is therefore not limited to a fixed list of recruitment territories.

3. Information We May Collect

Personal and Contact Information

  • full name, date of birth, nationality and country of residence;
  • email address, telephone number and address details; and
  • other contact or identification information reasonably required for the referral.

Education and Study Information

  • academic qualifications, certificates and transcripts;
  • previous study history;
  • preferred course, subject, institution, destination and intake;
  • academic grades and relevant entry information; and
  • information required to assess an initial study pathway or referral.

English Language, Employment and Career Information

  • English-language test details, results or other relevant evidence;
  • CV information and employment history; and
  • career information relevant to the proposed course or study pathway.

Identity and Application Documents

Where reasonably required and provided to GP2, this may include passport or travel-document copies, references, personal statements, application-related forms and other supporting documents.

Funding, Visa and Application Information

GP2 may collect information about your intended education budget, source of funding, sponsorship and other information reasonably necessary to assess or progress an education enquiry or referral. Where financial evidence or visa-related documentation is required later in an application process, it may instead be provided to or processed by the relevant Agent Partner, education provider or other authorised organisation.

GP2 aims not to collect detailed financial or visa documentation at the initial referral stage unless it is reasonably necessary.

Communication, Referral and Technical Records

  • enquiries and communication history;
  • referral information and application-progress information received by GP2;
  • offers, withdrawals, deferrals, enrolment or registration information where relevant;
  • IP address, browser and device information; and
  • cookies and analytics information where permitted.

Special Category Information

GP2 does not normally require special category personal information at the initial referral stage. However, a student may sometimes provide information such as health or disability information because it is relevant to a requested adjustment or education-support need. Where GP2 intentionally processes special category data, GP2 will identify an Article 6 lawful basis and an applicable Article 9 condition. Where appropriate, GP2 may rely on the student’s explicit consent. GP2 will seek to minimise the amount of special category information collected and shared.

4. How We Collect Your Information

We may collect information directly from you when you complete a form, contact GP2, communicate with an SRE, upload or send documents, request referral support or otherwise engage with GP2.

We may also receive relevant information from:

  • a GP2 Student Referral Executive who has introduced or referred you to GP2;
  • an authorised referral source or representative;
  • an Agent Partner involved in progressing your enquiry or application;
  • a university, college or other education provider involved in your enquiry or application; or
  • a relevant service provider involved in the education pathway.

Where GP2 obtains your personal information from another source, GP2 will provide or make available the required privacy information within the period required by applicable law. Where relevant, this will be no later than the first communication with you, before the information is disclosed onward, or otherwise within one month, unless a lawful exception applies.

5. Why We Use Your Information and Our Lawful Bases

Purpose

Typical lawful basis

Responding to enquiries and assessing whether GP2 can support or refer a prospective student

Article 6(1)(b) – steps taken at your request before entering a contract, where applicable; and/or Article 6(1)(f) – legitimate interests

Managing an education enquiry and referring relevant information through an appropriate Agent Partner or education-provider pathway

Article 6(1)(b), where applicable; and/or Article 6(1)(f) – legitimate interests. GP2 will also record appropriate instruction or authorisation where relevant

Managing and tracking a prospective student enquiry, referral and, where applicable, application progress

Article 6(1)(f) – legitimate interests in operating and administering GP2’s referral and education-support activities

Confirming enrolment or commencement for referral administration, performance and commission records

Article 6(1)(f) – legitimate interests in administering referral arrangements, contractual records and accounting

Complying with legal duties, regulatory requests, fraud prevention or legal claims

Article 6(1)(c) – legal obligation, and/or Article 6(1)(f) – legitimate interests, depending on the circumstances

Website security and essential operation

Article 6(1)(f) – legitimate interests; strictly necessary technologies are handled in accordance with applicable cookie rules

Optional analytics or advertising cookies

Consent where required

Email, SMS or other direct marketing

Consent where required, or legitimate interests where a lawful route is available and applicable electronic-marketing rules permit it

Where GP2 relies on legitimate interests, it considers the purpose, necessity and impact of the processing. Where GP2 relies on consent, you may withdraw consent at any time without affecting processing already carried out lawfully before withdrawal.

6. Student Referral and Application Pathways

GP2 supports prospective students by collecting relevant enquiry information, assessing their initial study interests and referring suitable prospective students through the appropriate education pathway.

Depending on the circumstances, relevant information may be shared with:

  • an Agent Partner working with GP2;
  • a university, college or other education provider;
  • an admissions or application-processing organisation involved in the relevant education pathway; or
  • another service provider reasonably necessary to progress the education enquiry, referral or application.

GP2 will only share information that is reasonably necessary for the relevant enquiry, referral or application.

Where an application is progressed following a GP2 referral, subsequent application and admissions activities may be handled by an Agent Partner and/or the relevant education provider.

GP2 does not guarantee that a referral will result in an application, offer, admission, CAS, visa or enrolment.

7. Student Referral Executives

GP2 may use Student Referral Executives (SREs) to identify prospective students, explain GP2’s referral service, collect initial enquiry information, qualify the prospective student’s study interests and submit the referral to GP2.

An SRE’s role is primarily to identify, qualify and refer prospective students to GP2. Unless GP2 expressly confirms otherwise, an SRE is not responsible for making university admission decisions, issuing offers or CAS documents, making visa decisions, or managing the full admissions process after the referral has been handed to GP2.

SREs should collect only information reasonably necessary for the initial enquiry and referral and must handle prospective-student information in accordance with GP2’s applicable data-protection and confidentiality requirements.

8. Who We May Share Your Information With

Where necessary for the purposes described in this policy, GP2 may share relevant information with:

  • Agent Partners and authorised education referral, recruitment or application partners;
  • universities, colleges and other education providers relevant to your enquiry or application;
  • admissions or application-processing organisations where applicable;
  • service providers supporting secure hosting, forms, communications, CRM/case management, document handling and other necessary business functions, subject to appropriate protections;
  • professional advisers such as accountants, auditors or legal advisers where necessary; and
  • regulators, courts, law-enforcement bodies or other authorities where disclosure is legally required or reasonably necessary to establish, exercise or defend legal rights.

Some recipients may process personal information on GP2’s behalf, while others may act as separate controllers for their own purposes. Where another organisation acts as a separate controller, its own privacy information may also apply.

GP2 does not sell or rent prospective-student personal information to unrelated lead brokers. Personal information and documents are not used by GP2 for unrelated lead resale, unrelated marketing databases or unrelated third-party commercial purposes.

9. International Transfers

GP2 is a UK company and may work with prospective students, Agent Partners, education providers and service providers in other countries. As a result, personal information may be transferred internationally.

Where UK data-protection law treats a GP2-initiated transfer as a restricted transfer, GP2 will use an applicable lawful transfer mechanism. Depending on the circumstances, this may include UK adequacy regulations, an appropriate safeguard such as the UK International Data Transfer Agreement or UK Addendum together with any required assessment, or another lawful transfer route or exception where applicable.

You may contact privacy@gp2.online for further information about safeguards relevant to a particular GP2-initiated transfer.

10. Data Minimisation and Security

GP2 aims to collect, use and share only personal information reasonably necessary for the relevant enquiry, referral, application-support activity or legitimate business requirement.

GP2 uses appropriate technical and organisational measures intended to protect personal information against unauthorised access, loss, misuse, alteration or disclosure. Access should be limited to people who reasonably need the information for their role.

No method of electronic transmission or storage can be guaranteed to be completely secure, but GP2 will take proportionate measures appropriate to the nature and sensitivity of the information.

11. When Information Is Required

You are not generally required by law to provide GP2 with personal information simply to make an initial enquiry. However, certain information may be necessary for GP2 to assess or make a referral, or for an Agent Partner or education provider to progress an application. If you choose not to provide information that is reasonably necessary, GP2 may be unable to assess your enquiry, make the requested referral or support the relevant pathway.

12. How Long We Keep Information

GP2 keeps personal information only for as long as reasonably necessary for the purpose for which it was collected, including enquiry and referral administration, legal or regulatory obligations, dispute handling, fraud prevention, accounting, audit and contractual requirements.

As an operational standard, unsuccessful, withdrawn or inactive prospective-student enquiry records will normally be reviewed for deletion or anonymisation after 24 months from closure or last meaningful activity, unless a longer period is reasonably required for a legal, regulatory, contractual, safeguarding, dispute or record-keeping reason.

Successful referral and commission-related records may be retained for up to 6 years after the relevant transaction or closure where necessary for contractual, tax, accounting, audit or legal-claims purposes.

Document copies that are no longer required should be deleted sooner where reasonably practicable. GP2 will periodically review its retention periods.

13. Your Data Protection Rights

Depending on the circumstances and applicable law, you may have rights to:

  • request access to your personal information;
  • ask for inaccurate or incomplete information to be corrected;
  • request deletion of personal information in certain circumstances;
  • request restriction of processing in certain circumstances;
  • object to processing in certain circumstances;
  • request data portability where the legal requirements for that right apply; and
  • withdraw consent where processing is based on consent.

Your right to object: Where GP2 relies on legitimate interests, you may have the right to object to that processing. You have an absolute right to object to the use of your personal information for direct marketing.

These rights are not absolute and may be subject to legal conditions or exemptions.

To exercise a data-protection right, contact privacy@gp2.online. GP2 may request reasonable information to verify your identity before responding.

14. Marketing and Cookies

GP2 may communicate with prospective students about its services where permitted by applicable law. Where consent is required for electronic direct marketing, GP2 will seek that consent. You may opt out of marketing communications at any time using the unsubscribe method provided or by contacting GP2.

GP2 may use essential cookies and similar technologies required for website operation. Optional analytics or advertising technologies will be used in accordance with applicable consent requirements. Further details should be provided in GP2’s cookie notice or consent interface where applicable.

15. Complaints

If you have concerns about how GP2 handles your personal information, please contact privacy@gp2.online so that GP2 can investigate.

You also have the right to complain to the UK Information Commissioner’s Office (ICO). Information about making a complaint is available at ico.org.uk.

16. Automated Decision-Making

GP2 does not currently make decisions producing legal or similarly significant effects solely through automated processing. If this changes, this Privacy Policy will be updated and the additional information required by applicable data-protection law will be provided.

17. Children’s Information

Some prospective students may be under 18. Where GP2 processes a child’s personal information, GP2 will take account of the child’s age and interests, use clear and appropriate privacy information, collect only information reasonably necessary for the relevant referral or education pathway, and involve a parent or guardian where appropriate or required.

18. Changes to This Privacy Policy

GP2 may update this Privacy Policy from time to time because of changes in its services, referral arrangements, technology, legal requirements or data-processing activities.

The latest version will be published on gp2.online. Where a change materially affects how GP2 processes personal information, GP2 will take reasonable steps to communicate the change where required.

19. Contact Us

Global Pathway Partners Ltd (GP2)
Registered in England and Wales: 17347718
Registered Office: Gatehouse Kiosk, The Wharf, 16 Bridge Street, Birmingham, United Kingdom
Privacy: privacy@gp2.online
General enquiries: info@gp2.online
Website: gp2.online

 
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