Privacy Policy

1.Introduction

This Privacy Policy ("Policy") is issued by Universal University Group Private Limited ("Universal University Group", "UUG", "the Company", "we", "us" or "our"), a company incorporated under the laws of Nepal, in connection with InCountryRepresentative.com (the "Platform" or the "Site") and the services made available through it (together, the "Service").

This Policy explains what information we collect through the Platform, how and why we collect it, how it is used and shared (including with our internally operated administrative system, GlobalSathi.com, and with universities, colleges and other institutions), how long we keep it, and the rights available to individuals whose information is processed. It applies specifically to InCountryRepresentative.com and does not, by itself, govern InterviewForYou.com or any other platform operated by UUG, each of which has its own separate privacy policy.

InCountryRepresentative.com is a portal used by education agents, representatives and other authorised users ("Agents" or "Representatives") to create and manage accounts and to submit information and documents concerning prospective students ("Students" or "Applicants") for the purpose of processing applications to universities, colleges and other educational institutions ("Institutions"). Because of this structure, this Policy addresses two distinct groups of individuals whose information may be processed through the Platform: registered Agents/Representatives, and Students/Applicants whose information is submitted by an Agent. Section 8 below deals specifically with information submitted by Agents on behalf of Students.

[BUSINESS INPUT REQUIRED: Confirm the actual effective date and insert it above before publication, and update it whenever a materially revised version of this Policy is published.]

2.Who We Are

Universal University Group Private Limited is a company registered in Nepal with the following details:

• Company Registration No.: 379885/82/83, registered with the Office of the Company Registrar, Nepal
• PAN No.: 622491970
• Registered/Business Address: Devkota Road, Kathmandu-31, Kathmandu, Nepal
• Legal & Support Email: info@uugglobal.com

UUG is the operator of, and the entity responsible for, InCountryRepresentative.com. UUG also operates GlobalSathi.com, which is not a separate or unrelated company but an internal, central administrative platform used by UUG to receive, manage, process and oversee information that originates from InCountryRepresentative.com (and from other UUG-operated platforms, including InterviewForYou.com). Authorised UUG personnel use GlobalSathi to administer agent accounts, review and process student applications, provide customer support, manage security, and generate internal reports. Section 9 explains this relationship in more detail.

3.Scope of This Policy

This Policy applies to:

• individuals who register for, or are granted, an Agent or Representative account on InCountryRepresentative.com;
• individuals employed by, or associated with, an Agent's business or agency who access the Platform under that Agent's account, where applicable; and
• Students/Applicants whose personal information is submitted through the Platform, whether by the Student directly or, more commonly, by an Agent acting on the Student's behalf.

This Policy covers the InCountryRepresentative.com website and the account, application-submission, document-upload, messaging and related functionality made available on it. It does not cover the separate websites, apps or services of any Institution, embassy, visa authority, payment processor or other independent organisation that a Student's application may subsequently involve. Where a Student's or Agent's information is provided to, or accessed by, such an independent organisation in connection with an application, that organisation's own privacy notices and legal obligations will also apply, and UUG does not control and is not responsible for that organisation's separate handling of the information once it is properly within that organisation's own systems.

4.Categories of Information We Collect

The categories of information collected through the Platform depend on whether the individual is an Agent or a Student, and on the specific application or service being requested. We do not collect every category listed below in every case; the relevant categories will depend on the particular application, Institution requirements and the information an Agent chooses, or is required, to submit.

5.How Information Is Collected

We collect information through the Platform in the following ways:

• Directly from Agents when they register an account, update their profile, or communicate with UUG through the Platform;
• Indirectly, from Agents, on behalf of Students — this is the most common way Student information reaches the Platform. Agents enter or upload Student personal information and documents when preparing and submitting an application. Section 8 sets out the responsibilities that apply to Agents when they do this;
• Directly from a Student, in the limited circumstances where a Student personally creates or accesses an account, or otherwise directly provides information to UUG (for example, by email correspondence with UUG's support team) — ordinarily, however, a Student tracks the progress of their own application through their Agent rather than through a separate, independent Student account;
• From an Institution or other authorised organisation involved in an application, where that organisation provides UUG with updates, requests or decisions concerning a specific application, which may be recorded against the relevant Student's record;
• Automatically, through the ordinary technical operation of the Platform (for example, IP address, device/browser information, and log-in and activity timestamps) and through cookies and similar technologies as described in Section 14; and
• Generated through use of the Service, such as application status updates, internal notes made by authorised UUG staff reviewing an application, and records of correspondence.

Because Student information is, in the great majority of cases, obtained indirectly through an Agent rather than directly from the Student, Section 8 below sets out in detail the responsibilities that fall on Agents when submitting Student information, and the position of UUG in relation to information it receives in that way.

6.Purposes for Which We Use Information

We use the information described above for the following purposes:

• creating, verifying and administering Agent accounts on the Platform;
• managing the relationship between UUG and the Agent, including account permissions and support;
• receiving, processing, reviewing and managing Student applications submitted through the Platform;
• forwarding relevant application information and documents to the selected university, college or other Institution, and to organisations reasonably necessary to process that application (for example, an admissions or scholarship-processing partner nominated by the Institution);
• communicating with Agents (and, where appropriate, Students) about the status, requirements or outcome of an application;
• enabling authorised UUG personnel, through GlobalSathi, to administer, review, track and report on applications and agent activity across the business;
• detecting, investigating and preventing fraud, misuse of the Platform, submission of falsified documents, or unauthorised submission of Student information;
• maintaining the security, integrity and proper functioning of the Platform, including technical troubleshooting;
• keeping records reasonably necessary for administrative, contractual, accounting or legal purposes; and
• complying with applicable legal, regulatory or contractual obligations, and responding to lawful requests from courts, regulators or law-enforcement authorities; and
• sending Agents and Students promotional or informational communications about UUG's own services (for example, new Institutions, features, or application deadlines), where the recipient has not opted out — see Section 18 for how to opt out.

We do not share Student or Agent personal information with third parties for their own marketing purposes, and we do not use it to train third-party artificial-intelligence models, sell it, or otherwise use it for purposes unrelated to the operation of the Platform and the services described in this Policy.

7.Legal Grounds for Processing

Nepal's Privacy Act, 2075 (2018) and its subordinate regulations govern the protection of personal and sensitive personal information in Nepal, together with the constitutional right to privacy recognised under the Constitution of Nepal. Consistent with that framework, we process personal information on the following grounds, as applicable to the particular processing activity:

• Consent/authorisation — where an Agent registers an account, or a Student (or, where applicable, their parent, guardian or authorised representative) provides information directly, or authorises an Agent to submit information on their behalf, we rely on that consent or authority as the basis for collecting and processing the relevant information;
• Performance of the service requested — where information is necessary to create an account, process an application, or otherwise deliver the specific service that has been requested through the Platform;
• Legitimate administrative and operational purposes — such as maintaining accurate records, preventing fraud, and ensuring the security and proper functioning of the Platform, carried out in a manner that is proportionate and consistent with the purposes described in this Policy; and
• Compliance with legal obligations — where processing or disclosure is required under Nepalese law, a court order, or a lawful request from a competent authority.

Because a very significant proportion of Student information is submitted by an Agent rather than by the Student personally, UUG's ability to rely on consent as a basis for processing Student information depends, in practice, on the Agent having properly obtained that consent or authority before submitting the information. Section 8 explains this in detail. Where an individual is located in a jurisdiction that recognises additional or different lawful bases for processing (see Section 20), those bases apply in addition to, and do not replace, the Nepalese legal framework described above.

8.Student Information Submitted by Agents

This section applies specifically to personal information and documents that an Agent submits on behalf of a Student, and sets out the responsibilities and understanding that apply to that process. Before an Agent can submit a Student's personal information or documents, the Platform requires the Agent to complete a mandatory confirmation step (a checkbox declaration) affirming the matters set out below. Completing that step does not, by itself, verify the underlying facts it confirms — it records the Agent's representation to UUG, on which UUG is entitled to rely as described further below.

• Agents act on behalf of Students. InCountryRepresentative.com is designed to allow an Agent to submit a Student's personal information and supporting documents for the purpose of a specific application or service. In doing so, the Agent is submitting that information as the Student's representative and not as an independent data source of UUG.
• Agents must have proper authority. Before uploading, entering or otherwise submitting any information or document relating to a Student, the Agent represents to UUG that the Agent has obtained the Student's informed authorisation (or, where the Student is a minor or otherwise unable to give authorisation, the authorisation of a parent, guardian or other person legally entitled to act for the Student) to collect and to submit that information for the relevant application or service.
• Agents must provide appropriate privacy information to the Student. The Agent is responsible for informing the Student, in a manner the Student can understand, that their personal information and documents will be submitted to UUG, processed through GlobalSathi, and shared with the relevant Institution and organisations reasonably necessary to process the application, and for directing the Student to this Policy or an equivalent explanation of how their information will be handled.
• Agents must obtain any consent required by applicable law. Where the law applicable to the Student (which may include Nepalese law and, depending on the Student's location, other applicable law) requires a specific form of consent or notice before personal information is collected, uploaded or transmitted, the Agent is responsible for obtaining and, where appropriate, recording that consent before submitting the information through the Platform.
• Agents must not submit information without authority. An Agent must not upload, enter or otherwise submit a Student's personal information or documents without having the authority described above. Doing so is a serious breach of the Terms & Conditions governing use of the Platform and may result in suspension of the Agent's account, rejection of the submission, and other consequences described in those Terms.
• Accuracy. Agents are responsible for taking reasonable care that the information they submit on behalf of a Student is accurate, current and submitted with the Student's knowledge. UUG relies on Agents to submit accurate information and does not independently verify the accuracy of every field, statement or document an Agent submits, except to the extent that verification is genuinely part of the service being provided (for example, standard checks that may be carried out by UUG staff, or by the Institution, as part of ordinary application processing).
• Handling of Student documents and identification information. Where identification documents (such as passport details) or other sensitive supporting documents are submitted, UUG processes them only for the purposes described in this Policy — principally, progressing the Student's application — and shares them only as described in Sections 9 and 10.
• Sharing with UUG, GlobalSathi and the Institution. By submitting a Student's information, the Agent acknowledges and agrees that the information will be transferred into GlobalSathi for administration by authorised UUG personnel, and will be shared with the relevant Institution (and organisations reasonably necessary to process the application) as described in Sections 9 and 10.

UUG does not independently verify every Agent's authority to submit a Student's information, or the authenticity of every document submitted, except where verification is genuinely built into the service being provided (for example, standard checks UUG or an Institution ordinarily carries out as part of processing a particular type of application). UUG is entitled to rely on the Agent's representations described above. Where UUG becomes aware, or has reasonable grounds to believe, that information has been submitted without proper authority, or that a document is falsified, UUG may suspend the relevant account, decline to process the submission, and take the other steps described in the Terms & Conditions.

If you are a Student and believe your information has been submitted through this Platform without your knowledge or authorisation, or you wish to make a privacy request concerning information submitted about you, please contact us at info@uugglobal.com. We will respond in accordance with Section 20 (User Privacy Rights) below, subject to reasonable identity verification and to any legal, contractual or administrative requirements that may limit what action can be taken (for example, where an Institution has already received and is separately holding a copy of the relevant information).

9.GlobalSathi and Internal Data Sharing

GlobalSathi.com is not an unrelated third party. It is an internal administrative platform operated by UUG within the Universal University Group ecosystem, used by authorised UUG personnel to receive, manage, process, oversee and report on the information generated across UUG's platforms, including InCountryRepresentative.com.

Information submitted through InCountryRepresentative.com — including Agent account information and Student application information and documents — is transferred to, or made accessible through, GlobalSathi so that authorised UUG staff can review applications, manage agent relationships, provide customer support, oversee compliance and security, and generate internal management reports. This is an internal transfer within the same corporate operator, carried out for administration of the Service, and is not a disclosure to an unrelated third party and not a sale of personal information.

Access to information within GlobalSathi is limited to UUG personnel and contractors who reasonably require access to perform their role (for example, application-processing staff, customer support, compliance and IT security personnel), and such access is subject to internal access controls described in Section 16.

10.Sharing With Universities and Other Organisations

Where a Student's information relates to a specific application, we share the relevant application information and supporting documents with the university, college or other Institution to which the application is being made, and with any other organisation reasonably necessary to process that application (for example, a scholarship body, an admissions-processing partner engaged by the Institution, or a document-verification service specifically required for the application).

• We share only the information reasonably necessary for the Institution (or other relevant organisation) to consider and process the application.
• Institutions and other independent organisations that receive Student information in this way are separate legal entities from UUG. They maintain their own privacy policies, are separately responsible for their own handling of the information once properly received, and may contact the Student or Agent directly in connection with the application.
• We encourage Agents to make Students aware, before an application is submitted, of which Institution(s) will receive their information and that those Institutions have their own separate privacy practices.

Where an application additionally involves a visa authority, embassy, or other government or regulatory body, information may also need to be shared with that body as part of the ordinary application or visa process; such bodies act under their own legal authority and are not controlled by UUG.

UUG has separate written agreements with certain Institutions governing its working relationship with them. Where such an agreement imposes additional data-handling obligations on UUG in respect of Student information shared with that Institution, UUG complies with those additional obligations in addition to this Policy.

11.Service Providers

We engage third-party service providers to help us operate the Platform. Depending on how the Platform's infrastructure is configured from time to time, this may include providers of categories such as:

• hosting and cloud-infrastructure providers;
• database and data-storage providers;
• email and communication providers;
• security and fraud-prevention providers; and
• analytics providers, where used (see Section 14).

The Platform's core hosting and database infrastructure is provided by a Nepal-based hosting provider. We do not name specific providers in this Policy because the underlying infrastructure may change over time; instead, we commit that any such provider is engaged under contractual terms that limit its use of information to the services it provides to us, and that it receives only the information reasonably necessary to perform its role, subject to appropriate contractual and, where applicable, legal safeguards.

[BUSINESS INPUT REQUIRED: Confirm the name of the Nepal-based hosting provider (if UUG wishes to name it specifically) and the email/communication provider used for transactional emails, so this section and Section 17 can reference them precisely if desired.]

12.Cookies and Similar Technologies

The Platform uses cookies and similar technologies that are strictly necessary for it to function, such as cookies used to maintain a logged-in session, remember security tokens, and protect against certain forms of fraud or abuse. Without these, core functions such as logging in and submitting an application would not work.

We do not currently use analytics cookies or tools on the Platform. If we introduce an analytics tool in the future to help us understand how the Platform is used and to improve reliability, we will update this Policy to describe it before doing so. We do not use advertising cookies or share Platform usage data with advertisers. We may introduce a separate, more detailed Cookie Policy in the future if warranted by the scale or complexity of the technologies used.

13.Data Retention

We do not apply an arbitrary fixed retention period across all information. Instead, we retain Agent and Student information for as long as reasonably necessary to fulfil the purposes described in this Policy, taking into account:

• the duration of the Agent's account relationship with UUG, or the period reasonably needed to complete a Student's application process;
• contractual requirements between UUG, the Agent, and where applicable the Institution;
• legitimate administrative needs, such as being able to respond to later queries about a past application;
• the need to prevent, investigate or resolve disputes, fraud or misuse; and
• applicable legal, regulatory or accounting retention requirements under Nepalese law.

As a general rule, applying the criteria above: we retain an Agent's account information for up to 90 days after the Agent's account is closed, and we retain a Student's application information for up to 90 days after the relevant application is completed, rejected, or withdrawn, before it is deleted or anonymised. We do not intend to retain personal information for longer than is reasonably necessary for the purposes described in this Policy, unless a longer period is required or permitted by law — for example, a longer period may apply where information must be kept for accounting, regulatory, or dispute-resolution purposes, or where an Institution separately requires UUG to retain records for a longer period in connection with a specific application.

[BUSINESS INPUT REQUIRED: Confirm whether any minimum retention period is required for accounting or regulatory purposes under Nepalese law that is longer than the 90-day operational period stated above, and adjust this section if so.]

14.Data Security

We use reasonable technical and organisational safeguards designed to protect information submitted through the Platform against unauthorised access, use, alteration or disclosure, consistent with the security obligations recognised under Nepal's Privacy Act, 2075 and the Electronic Transactions Act, 2063. These measures may include access controls limiting which personnel can view particular records, authentication requirements for accounts, restricted internal access on a need-to-know basis, encryption of data where appropriate, activity logging, and routine backups.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security of information submitted through the Platform. We encourage Agents to use strong, unique passwords, to keep login credentials confidential, and to notify us promptly at info@uugglobal.com if they suspect unauthorised access to their account.

15.International Data Transfers

The Platform's core hosting infrastructure is located in Nepal. However, InCountryRepresentative.com may be accessed by Agents located outside Nepal, and applications are, by the nature of the Service, sent to Institutions located outside Nepal. Certain supporting service providers (for example, an email-delivery provider) may also be located outside Nepal. As a result, personal information handled through the Platform may sometimes be processed or transferred internationally, including to countries whose data-protection laws may differ from those of Nepal.

Where such transfers occur, we take reasonable steps to ensure that the recipient is subject to appropriate contractual, technical or organisational safeguards consistent with the purposes described in this Policy.

16.Data Sale

UUG does not sell personal information collected through InCountryRepresentative.com for monetary consideration. The disclosures described in Sections 9 and 10 — namely, internal transfer to GlobalSathi and disclosure to a selected Institution or organisation reasonably necessary to process an application — are made to enable UUG to provide the Service that has been requested, and are not sales of personal information.

17.Children's / Minors' Information

Many prospective students who apply to study abroad are, or may be, under 18 years of age at the time an application is prepared. This Policy therefore does not set an unrealistically high minimum age for Students whose information may be processed through the Platform. Instead:

• Where a Student is a minor under the law applicable to them, the Agent submitting the Student's information is responsible for obtaining the authorisation of a parent, guardian, or other person or authority legally entitled to consent on the minor's behalf, before submitting the minor's personal information, in addition to any information appropriate for the minor themselves to understand.
• Agent (Representative) accounts on the Platform are intended for use by adult professionals acting in a business capacity, and are not intended for use by minors.
• If we become aware that a minor's information has been submitted without appropriate parental, guardian or other lawful authorisation, we will take reasonable steps to address the situation, which may include suspending processing of the relevant record pending confirmation of proper authority, consistent with Section 8.

18.User Privacy Rights

Subject to applicable law and to the limitations described in this Policy (including the fact that a substantial proportion of Student information originates from Agents rather than the Student directly), individuals may contact us to request:

• access to, or a copy of, personal information we hold about them;
• correction of inaccurate or incomplete information;
• deletion of personal information, where appropriate and not inconsistent with a legal, contractual or legitimate administrative requirement to retain it;
• withdrawal of consent to processing, where processing is based on consent, recognising that withdrawal may mean we can no longer provide the relevant part of the Service (for example, we may be unable to continue progressing an application without the information withdrawn);
• objection to, or restriction of, certain processing, where applicable under the law governing the individual's use of the Service;
• opting out of promotional or informational communications from UUG at any time, by using the unsubscribe link included in such communications or by contacting us; and
• general information about how their personal information has been processed.

Requests should be sent to info@uugglobal.com. We may need to verify the identity of the person making the request, and may need to confirm the requester's relationship to the relevant record (for example, that a person claiming to be the Student is in fact that Student, or their authorised parent/guardian/representative), before acting on it. We will not always be able to delete information where we are legally or contractually required to retain it (for example, records an Institution requires us to keep, or records needed for legal or accounting compliance), and we will explain the reason where a request cannot be fulfilled in full.

19.Legal Disclosure

We may disclose personal information where we reasonably believe disclosure is necessary to: comply with a court order, subpoena, or other lawful legal process; respond to a lawful request from a law-enforcement or regulatory authority; investigate or prevent actual or suspected fraud, security threats, or violations of our Terms & Conditions; or protect the rights, property or safety of UUG, our users, Institutions, or the public, as permitted under applicable Nepalese law.

20.Additional Rights for Certain Jurisdictions

This Platform is operated from, and governed primarily by the law of, Nepal. Where an individual accesses or uses the Platform from a jurisdiction that recognises additional privacy rights — for example, the European Economic Area, the United Kingdom, or other jurisdictions with broadly similar data-protection laws — the following additional principles apply where applicable under the laws governing that individual's use of the Service, in addition to the rights described in Section 18:

• the right to request confirmation of, and access to, personal information processed about the individual;
• the right to request correction of inaccurate personal information;
• the right to request deletion of personal information, subject to the limitations described in Section 18;
• the right to object to, or request restriction of, certain processing;
• the right to request a portable copy of certain information the individual has provided, where technically feasible and legally applicable;
• the right to withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing before withdrawal;
• the right to lodge a complaint with the data-protection authority competent for the individual's jurisdiction, if applicable; and
• information about safeguards applicable to any international transfer of the individual's personal information, as described in Section 15.

We do not represent that we are certified or fully compliant with the General Data Protection Regulation or any other specific foreign data-protection regime; rather, we aim to honour the substance of these principles where they genuinely apply to an individual's use of the Service, consistent with Nepalese law as our primary governing framework.

21.Business Restructuring

If UUG is involved in a merger, acquisition, corporate restructuring, or the sale or transfer of all or part of its business or assets, personal information may be transferred as part of that transaction, subject to applicable law and to safeguards intended to ensure that the information continues to be protected consistently with this Policy (or a successor policy of which affected individuals are notified).

22.Third-Party Links

The Platform may contain links to, or facilitate communication with, websites or systems operated by Institutions or other third parties. This Policy does not apply to those third-party websites or systems, which are governed by their own privacy policies and terms. We encourage individuals to review the privacy practices of any third-party site they interact with in connection with their application.

23.Changes to This Privacy Policy

We may update this Policy from time to time to reflect changes in our practices, the Platform's functionality, or applicable law. We will update the "Last Updated" date at the top of this Policy when changes are made. Where a change is material, we will take reasonable steps to bring it to the attention of registered Agents (for example, by notice on the Platform or by email) before, or as soon as reasonably practicable after, it takes effect. Continued use of the Platform after a revised Policy takes effect constitutes acceptance of the revised Policy, to the extent permitted by applicable law.

24.Contact Us

Questions, requests or concerns about this Policy or about how your personal information is handled can be directed to:

Universal University Group Private Limited

Devkota Road, Kathmandu-31, Kathmandu, Nepal

Company Registration No.: 379885/82/83 | PAN No.: 622491970

Email: info@uugglobal.com