Cobaltz Pathways

Legal

Privacy Policy

Last updated: 2 May, 2026

1. Who we are

Cobaltz Pathways ("we", "us", "our") is an independent UK education consultancy. Our registered address is [INSERT ADDRESS], United Kingdom. For data protection enquiries, contact ask@cobaltzpathways.com.

2. What data we collect

We collect personal data necessary to provide our consultancy services, including:

  • Identity data: name, date of birth, residency status, nationality, passport details
  • Contact data: email address, phone number, postal address
  • Academic data: qualifications, institution history, references, CV, personal statement drafts
  • Financial data (where applicable to SFE): household income evidence, employment status, household member details
  • Document copies: passport, utility bills, payslips, exam certificates, where relevant to your application
  • Technical data: anonymised IP address, browser type, time of visit (via analytics)
  • Communication data: records of correspondence with us

3. Why we collect it (lawful basis)

Under UK GDPR, we process your data on these lawful bases:

  • Consent — for marketing communications and initial enquiries.
  • Contract — to provide consultancy services you've engaged us for.
  • Legal obligation — to comply with UK tax, anti-money-laundering, and education regulations.
  • Legitimate interests — to maintain our service, prevent fraud, and improve our offering.

4. How we use your data

We use your personal data to:

  • Assess Student Finance England eligibility
  • Prepare and submit university applications via UCAS where authorised
  • Communicate with you about your enquiry or active case
  • Share necessary information with universities, the Student Loans Company, or partner agencies only with your explicit consent
  • Comply with legal and regulatory obligations

We will never sell your data to third parties.

5. Document handling (passports, CVs, evidence)

If you submit sensitive documents (e.g. passport scans, financial evidence, academic certificates):

  • They are stored on encrypted, access-controlled systems
  • Only authorised advisors handling your case have access
  • Documents are retained only for the duration necessary to complete your application plus a minimum legal retention period
  • You may request deletion at any time, subject to ongoing legal obligations

6. Data sharing

We share your data only with:

  • Universities and UCAS, where you've authorised us to apply on your behalf
  • The Student Loans Company, where you've authorised us to assist with your SFE application
  • Partner education agencies (B2B partners), under formal Data Processing Agreements, only as needed to deliver services
  • Service providers (email, hosting, analytics) under appropriate contractual safeguards
  • Regulators or law enforcement, where legally required

7. Data retention

  • Enquiry data: 24 months from last contact
  • Active client records: duration of engagement plus 7 years (financial/legal record-keeping)
  • Marketing consents: until withdrawn
  • Anonymised analytics: indefinitely

8. Your rights

Under UK GDPR, you have the right to:

  • Access your data (Subject Access Request)
  • Correct inaccurate data
  • Request erasure ("right to be forgotten")
  • Restrict processing
  • Data portability
  • Object to processing
  • Withdraw consent at any time

To exercise any right, email privacy@cobaltzpathways.com. We will respond within one calendar month.

9. Security

We use industry-standard security measures including HTTPS encryption, access controls, secure storage, and regular review. No system is 100% secure; in the event of a breach affecting your rights, we will notify you within 72 hours as required by law.

10. International transfers

Where service providers process data outside the UK, we ensure equivalent protection via UK Adequacy Decisions, Standard Contractual Clauses, or other lawful transfer mechanisms.

11. Cookies

See our separate Cookie Policy for details.

12. Children's data

We do not knowingly collect data from anyone under 16. Applicants under 18 should engage with parental/guardian awareness.

13. Changes to this policy

We may update this policy. The "last updated" date at the top reflects the latest version. Material changes will be communicated by email to active clients.

14. Contact

Data Protection enquiries: ask@cobaltzpathways.com
General contact: ask@cobaltzpathways.com