Privacy Policy

1. Who We Are

Hitouch Global Ltd (“Hitouch Global”, “we”, “us”, or “our”) is an educational and immigration consultancy registered and operating in Nigeria. We operate the website at hitouchglobal.com and the student portal at portal.hitouchglobal.com.

For the purposes of applicable data protection law, Hitouch Global Ltd is the Data Controller responsible for your personal data.

Our contact details for data protection matters are:

Data Controller: Hitouch Global Ltd
Email: info@hitouchglobal.com
Website: hitouchglobal.com

2. Information We Collect

We collect the following categories of personal data, depending on the nature of your engagement with us:

Data Category	Examples	Why We Collect It
Identity Data	Full name, date of birth, gender, nationality, passport number, photograph	To verify identity and process applications
Contact Data	Email address, phone number, home address, emergency contact details	To communicate with you about your application and services
Academic Data	Transcripts, certificates, IELTS/TOEFL scores, previous study history, CGPA	To assess programme eligibility and prepare applications
Financial Data	Income statements, bank statements, sponsor letters, GIC details (no card/account numbers stored)	To support visa and financial eligibility assessments
Immigration Data	Visa history, travel records, refusal letters, immigration status, study permits	To provide accurate immigration advisory services
Technical Data	IP address, browser type, device information, cookies, session data	To maintain Platform security and improve user experience
Usage Data	Pages visited, search queries, time on site, referral sources	To improve our website and service offerings
Communications Data	Emails, messages, enquiry forms, consultation notes	To respond to your enquiries and record advice given
Marketing Data	Preferences, subscriptions, opt in/opt-out records	To send relevant information about our services (with consent)

We do not collect sensitive personal data (such as health information, biometric data, or criminal records) unless strictly required for a specific immigration or visa process, in which case we will obtain your explicit consent.

We do not store full credit card numbers, bank account numbers, or other payment card data. Any payment processing is handled by third-party payment providers.

3. How We Collect Your Information

We collect personal data through the following means:

• Direct submission — when you register on our portal, submit an application, fill in a consultation form, send us an email, or speak with our team
• Automated technologies — cookies, web analytics tools, and server logs when you browse our website or use the portal
• Third parties — partner institutions, recruitment agents, or financial service providers who refer you to us or who we work with on your application
• Publicly available sources — for verification purposes, such as publicly available academic or professional information
• Document uploads — when you upload supporting documents (passports, transcripts, financial statements) through our portal

4. How We Use Your Information

We use your personal data for the following purposes:

• Service delivery — to provide educational consultancy, application processing, visa assistance, accommodation sourcing, education loan facilitation, and all related services
• Identity verification — to confirm your identity and prevent fraud
• Application processing — to prepare and submit applications to partner institutions and visa authorities on your behalf
• Communication — to respond to enquiries, provide updates on your application, and deliver consultations
• Portal management — to manage your account, process registrations, and maintain the student portal
• Compliance — to comply with legal and regulatory obligations, including anti-money laundering checks and immigration compliance
• Service improvement — to analyse usage of our Platform and improve our services, website, and processes
• Marketing — to send you information about our services, programmes, and offers — only where you have given explicit consent or where permitted by law
• Dispute resolution — to investigate complaints, resolve disputes, and enforce our Terms and Conditions
• Safety and security — to detect and prevent fraud, cybersecurity threats, and other harmful activities on our Platform

We will never use your personal data to make solely automated decisions that have significant legal or similar effects on you without your knowledge and the ability to request human review.

5. Legal Basis for Processing

Under the Nigeria Data Protection Act (NDPA) 2023 and applicable law, we process your personal data on the following legal bases:

CONTRACT

Processing is necessary to perform the services your request before entering into a service agree your request before entering into a service agree

CONSENT

Where we send marketing communications or process sensitive data, we rely on your freely given, specific, and informed consent. You may withdraw consent at any time.

LEGAL OBLIGATION

Processing is necessary to comply with Nigerian law, immigration regulations, anti-money laundering obligations, or other applicable legal requirements

LEGITIMATE INTERESTS

Processing is necessary for our legitimate interests (e.g. fraud prevention, business operations, service improvement), provided these are not overridden by your rights.

6. Data Sharing and Disclosure

We share your personal data only where necessary to deliver our services or comply with legal obligations. Recipients may include:

• Partner Institutions — universities, colleges, and schools to which you are applying, for admissions processing
• Immigration Authorities — government visa and immigration bodies in relevant countries, for visa and permit applications
• Recruitment Agents — partner agents who referred you to us or are assisting with your application
• Financial Service Providers — education loan providers (e.g. MPower Financing), GIC providers, and payment processors
• Accommodation Providers — housing partners such as University Living, Housemates, U Homes, and Vanmates
• Insurance Providers — travel and health insurance partners facilitating coverage for your journey
• Technology Providers — cloud hosting, CRM, email, and portal technology providers who process data on our behalf under strict data processing agreements
• Legal and Compliance Advisors — lawyers, auditors, or regulators where required by law or for legitimate legal defence

We do not sell, rent, or trade your personal data to any third party for their own commercial or marketing purposes.

All third parties with whom we share personal data are required to handle it in accordance with applicable data protection law and our data processing agreements.

7. International Data Transfers

Given the international nature of our services, your personal data may be transferred to and processed in countries outside Nigeria, including Canada, the United Kingdom, Ireland, the United States, Australia, and other study destinations.

Where we transfer data internationally, we take appropriate safeguards to ensure your data receives a level of protection equivalent to that required under Nigerian law. These safeguards may include:

• Transferring to countries with adequate data protection laws as recognised by the Nigerian Data Protection Commission (NDPC)
• Using standard contractual clauses or data processing agreements with receiving parties
• Obtaining your explicit consent for specific international transfers where required

You may contact us at info@hitouchglobal.com to request information about the specific safeguards applied to any international transfer of your data.

8. Data Retention

We retain your personal data for as long as necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required by law.

Data Type	Retention Period	Reason
Application & admissions records	7 years after service completion	Legal and contractual obligations
Immigration & visa records	7 years after service completion	Immigration compliance requirements
Financial records and invoices	7 years	Nigerian tax and financial regulations
Portal account data	Duration of account + 2 years after last activity	Service delivery and fraud prevention
Marketing preferences / consent records	Until consent is withdrawn + 3 years	Demonstrating lawful marketing compliance
Enquiry and consultation records	3 years after last contact	Dispute resolution and service continuity
Website technical and usage data	Up to 24 months	Platform security and analytics

When data is no longer required, we securely delete or anonymise it in accordance with our internal data disposal procedures.

9. Your Rights

Under the Nigeria Data Protection Act (NDPA) 2023 and applicable law, you have the following rights in relation to your personal data:

Right to Access	You have the right to request a copy of the personal data we hold about you and information about how we use it.
Right to Rectification	You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
Right to Erasure	You have the right to request deletion of your personal data where there is no legitimate reason for us to continue processing it.
Right to Restriction	You have the right to request that we restrict the processing of your personal data in certain circumstances.
Right to Data Portability	You have the right to receive your personal data in a structured, machine-readable format and to transfer it to another controller.
Right to Object	You have the right to object to processing of your personal data based on legitimate interests or for direct marketing purposes.
Right to Withdraw Consent	Where processing is based on consent, you may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.
Right to Lodge a Complaint	You have the right to lodge a complaint with the Nigerian Data Protection Commission (NDPC) at ndpc.gov.ng if you believe your data rights have been violated.

To exercise any of the above rights, please contact us in writing at info@hitouchglobal.com. We will respond to your request within 30 days. In complex cases, we may extend this by a further 60 days, in which case we will notify you.

We may need to verify your identity before fulfilling your request to ensure the security of your data.

10. Cookies and Tracking Technologies

Our website (hitouchglobal.com) uses cookies and similar tracking technologies to enhance your browsing experience, analyse website traffic, and support marketing activities.

We use the following types of cookies:
• Strictly Necessary Cookies — essential for the website to function correctly; these cannot be disabled
• Performance / Analytics Cookies — collect anonymous data about how visitors use the site (e.g. Google Analytics) to help us improve the Platform
• Functionality Cookies — remember your preferences (e.g. language, login status) to improve your experience
• Marketing / Targeting Cookies — used to deliver relevant advertisements and track the effectiveness of marketing campaigns; only set with your consent

When you first visit our website, you will be presented with a cookie consent banner. You can manage your cookie preferences at any time through your browser settings or by contacting us.

Please note that disabling certain cookies may affect the functionality of our website and portal.

11. Children's Privacy

Our services are primarily intended for individuals aged 16 and above. We do not knowingly collect personal data directly from children under the age of 16 without verifiable parental or guardian consent.

Where a parent or legal guardian is engaging our services on behalf of a minor applicant, the parent or guardian is responsible for providing consent for the processing of the child’s personal data and for ensuring the accuracy of information provided.

If you believe we have inadvertently collected personal data from a child under 16 without appropriate consent, please contact us immediately at info@hitouchglobal.com and we will take prompt steps to delete such data.

12. Data Security

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Encrypted data transmission using SSL/TLS protocols across our website and portal
• Password-protected access to our systems with role-based access controls
• Regular security assessments and vulnerability monitoring
• Staff training on data protection and information security
• Secure data storage with reputable cloud service providers
• Data breach detection and response procedures

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and the Nigerian Data Protection Commission (NDPC) without undue delay and within 72 hours of becoming aware of the breach, as required by the NDPA 2023.

While we take all reasonable steps to protect your data, no method of electronic transmission or storage is 100% secure. You are responsible for keeping your portal login credentials confidential.

13. Third-Party Links

Our website and portal may contain links to third-party websites and services, including partner institutions, financial providers, accommodation platforms, and social media channels. These links are provided for your convenience only.

We are not responsible for the privacy practices or content of any third-party websites. We encourage you to read the privacy policies of any third-party websites you visit.

The presence of a link to a third-party website does not constitute an endorsement of that website, its content, or its data practices.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. The updated policy will be posted on our website at hitouchglobal.com/privacy-policy with a revised effective date.

Where changes are material, we will provide you with prominent notice — such as an email notification or a notice on the Platform — prior to the changes taking effect.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data. Continued use of our services after any updates constitutes your acceptance of the revised policy.

15. Contact Us and Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or the way we handle your personal data, please contact us:

Hitouch Global Ltd — Data Privacy Enquiries

Email: info@hitouchglobal.com
Website: hitouchglobal.com
Portal: portal.hitouchglobal.com

If you are not satisfied with our response, you have the right to lodge a complaint with the Nigerian Data Protection Commission (NDPC):

Nigerian Data Protection Commission (NDPC)

Website: ndpc.gov.ng