Privacy Policy

It applies when you visit our website, contact us, enquire about or use our education-support services, take part in an application, communicate with us or give permission for us to use a testimonial or other content.

1. Who We Are

United Kingdom: the data controller

STUDY WITH FM LTD, trading as Study With FM, is a company registered in England and Wales and is the data controller responsible for personal information processed for the Study With FM services described in this policy, including relevant client information handled through our Nigerian operations and the initial enquiries referred by contacts in Iran.

Company number: 11417586 Registered office: 7 Westmoreland House, Cumberland Park, Scrubs Lane, London, England, NW10 6RE, United Kingdom.

Being the data controller means STUDY WITH FM LTD decides why and how personal information is processed for these services.

Nigeria

Study With FM Global Limited is a separate company registered in Nigeria. It supports Study With FM's activities in Nigeria. For the client-information processing covered by this policy, STUDY WITH FM LTD determines the purposes and essential means of processing.

RC number: 7602429 Registered on: 21 June 2024 Registered address: No. 25, Aare Avenue, New Bodija, Ibadan, Oyo State, Nigeria. Company email: info@studywithfm.com

Study With FM Global Limited may have separate responsibilities for information it processes for its own corporate or legal obligations.

Iran: initial enquiries and referrals

We have enquiry and referral contacts in Tehran, Iran. Their role is limited to receiving initial expressions of interest and passing relevant introductory information to STUDY WITH FM LTD in the United Kingdom. The UK team handles subsequent communication, education advice, document collection and application support.

Initial referral information may include your name, contact details, preferred study destination or course, and a short description of your enquiry. Our Iran-based contacts do not request or receive payments from students or families on our behalf. Our Iran-based contacts do not manage the full application process or request passports, bank statements or health documents for an initial referral.

STUDY WITH FM LTD determines how the information referred to it is used for Study With FM services and is the controller for that processing. We will explain what further information is needed when our UK team takes over your enquiry.

2. Privacy and Data Protection Contact

For questions about this policy, requests concerning your information or privacy complaints, please contact:

Email: coordinator@studywithfm.com UK telephone: +44 7557 271171

You may also write to STUDY WITH FM LTD at the UK registered office shown in Section 1. Our Nigerian registered address is provided there for local correspondence.

3. Who This Policy Applies To

This policy covers prospective, current and former students and clients; parents, guardians and family members; children and young people; people enquiring on someone else's behalf; website visitors; people who contact us through forms, email, telephone, messaging or social media; participants in testimonials, case studies, photographs, audio or video; event attendees; educational-institution representatives; business contacts; and anyone else whose information we handle in connection with our services.

It also covers people who initially enquire through our contacts in Iran and whose introductory details are referred to our UK team.

4. Personal Information We May Process

The types of information we handle depend on your circumstances and the support you request. They may include:

Identity and contact details

Names, date of birth, nationality, country of residence, addresses, telephone numbers, email addresses, emergency contacts, parent or guardian details and identity-document information.

Education and applications

Education history, qualifications, transcripts, grades and predicted grades, language-test results, references, CVs, personal statements, course and institution preferences, applications, offers, admissions decisions and enrolment information.

Visas, immigration and travel

Passport details, immigration status, visa history and refusals, supporting application evidence, relevant correspondence and travel or arrival arrangements where needed for the requested service. Universities, schools and immigration authorities make their own admissions and immigration decisions.

Financial information

Where relevant to an education or visa application, we may process tuition and deposit amounts, scholarship or funding information, and evidence of financial means supplied for the application. This helps us support the application and does not mean that Study With FM receives tuition or institutional deposits.

Study With FM may receive commissions paid by universities under the relevant institutional arrangements for eligible recruitment or enrolment. We do not charge Iranian students for Study With FM consultations or other services. For other clients, certain consultations, detailed application reviews, specialist assessments and other agreed professional services may carry a fee.

Where a paid service applies, we may process details of the agreed service and fee, invoices, payment status, transaction references, refunds and related accounting records. If a third-party payment provider is used, it may process payment-card information under its own privacy terms. We may also process university commission invoices and records needed to verify an eligible referral or enrolment.

Health, disability, SEN and other sensitive information

Where necessary for an agreed service, we may handle information about health, disability, Special Educational Needs (SEN), accessibility, welfare, safeguarding or other sensitive circumstances. We limit access to those who need the information and apply the additional legal protections required for sensitive information.

Where UK law applies, processing of special-category information requires both a lawful basis under Article 6 of the UK GDPR and an applicable condition under Article 9. We seek explicit consent where that is the appropriate condition. Additional requirements may apply in Nigeria or Iran.

Criminal convictions and offences

We do not routinely seek criminal-record certificates. If an offence or related matter is relevant to a particular application or is disclosed to us, we process it only where lawful and necessary, subject to any additional legal conditions.

Communications

Information included in enquiries, consultations, telephone notes, emails, forms, text messages, WhatsApp messages, social-media messages and communications with schools, universities or service providers.

Testimonials and other media

With appropriate permission, we may use an agreed name or pseudonym, education-journey details, institution and course information, quotations, photographs, videos, audio recordings, captions or translations. Participation is voluntary and does not affect access to our core services.

Website and technical information

Depending on the website features and technologies in use, this may include IP addresses, browser and device details, pages viewed, referral information, access times, interactions, security logs and technical or performance information.

5. Initial Enquiries and Referrals from Iran

If you first contact Study With FM through our Tehran-based enquiry contacts, they collect only the introductory information reasonably needed to understand your interest and pass your enquiry to our UK team. This can include your name, contact details, intended study level, subject or destination, and any brief explanation you volunteer.

The initial enquiry information is forwarded to STUDY WITH FM LTD in the United Kingdom, where our team manages the follow-up and any application-related processing. Iran-based enquiry contacts do not request or handle payments, collect documents for full applications or carry out the subsequent admissions process on our behalf.

We make this policy available when introductory information is collected or at our first direct contact with you, as required by applicable privacy law. Please send passports, financial evidence, medical records and other sensitive supporting documents only when our UK team specifically requests them through an appropriate channel.

6. How We Obtain Information

We may receive information directly from you; from a parent, guardian or authorised representative; from a school, university, referee, application platform or other service provider involved in your case; from authorised Study With FM personnel, previous records or lawful public sources; or through initial-enquiry contacts in Iran.

If we obtain your information indirectly, we provide privacy information within the timeframe required by applicable law. When an enquiry is referred from Iran, this policy should be available at the point of initial contact or by the time we first contact you directly.

7. Why We Use Personal Information

We use personal information only where we have an appropriate lawful basis. Under UK law, the bases relevant to our activities may include taking steps at your request before entering a contract, performing a contract, complying with a legal obligation, pursuing legitimate interests, obtaining consent or protecting vital interests. The appropriate basis depends on the particular activity; applicable Nigerian and Iranian requirements must also be met.

Enquiries and consultations

We respond to enquiries, understand your needs and discuss appropriate support. This will generally involve pre-contractual steps or our legitimate interests in responding to enquiries.

Education and related services

We use information to provide education planning, course and institution selection, school or university application support, document preparation, appropriate visa-related administrative support, relocation and arrival assistance, guardianship-related coordination, and SEN or other agreed support. This will generally involve a contract or steps requested before entering one.

Applications and external providers

We share and use relevant information to prepare, submit and follow up on requests to institutions, application systems and other organisations involved in your agreed service. Contractual steps and, where appropriate, legitimate interests may apply.

Paid services, university commissions and accounting

For clients other than Iranian students, we may process agreed service fees, invoices, payments, refunds and accounting information for paid consultations and other agreed professional services. Universities may also pay Study With FM commissions for eligible recruitment or enrolment. We use relevant referral, application, offer and enrolment details to verify commission eligibility, invoice universities and maintain the necessary business records. We do not charge Iranian students for our consultations or other services. Depending on the activity, the relevant UK lawful bases may include contract, legitimate interests and legal obligations.

Security, safeguarding and legal matters

We may process information to protect people and systems, prevent fraud, handle complaints, respond to legal claims, comply with lawful requests or respond to safeguarding emergencies, using the lawful basis relevant to the circumstances.

Service improvement

We may use appropriate service and website information to improve our operations, subject to the lawful basis and any consent requirements applicable to the technology involved.

Marketing and public content

We send marketing only where permitted by law. We generally rely on appropriate consent for the publication of identifiable testimonials, photographs, case studies, audio or video, as explained below.

8. Legitimate Interests

Where appropriate, our legitimate interests include responding to enquiries, coordinating international education-support services, administering client relationships, agreed paid services and university-commission arrangements, maintaining necessary records, protecting information and systems, preventing misuse, improving services, managing complaints and protecting our legal rights.

Before relying on legitimate interests, we assess the impact on individuals and whether their rights and interests override ours. We take particular care where children or sensitive information are involved.

9. Your Right to Object

You can object to the use of your personal information for direct marketing at any time. We will stop processing it for that purpose.

You may also have the right to object to processing based on legitimate interests, depending on the circumstances. Contact coordinator@studywithfm.com to exercise these rights.

10. Marketing Communications

We may contact you about Study With FM services, events and educational opportunities where applicable law permits. For UK electronic marketing, we follow the Privacy and Electronic Communications Regulations (PECR), including applicable consent requirements and any valid statutory exceptions.

Being referred to us by someone in Iran or elsewhere does not automatically give us permission to send you marketing. Where consent is required, we seek it separately and explain which organisation will contact you and for what purpose.

You can unsubscribe or object to direct marketing at any time. We may keep minimal information needed to respect your opt-out.

11. Do You Have to Provide Information?

Some information is needed to respond to your enquiry, assess your circumstances, arrange or deliver education-support services, complete an application or meet a legal requirement. Institutions, admissions services and public authorities may also require particular documents.

If essential information is not provided, we may be unable to offer part or all of the requested support. Where a paid service has been agreed with a client other than an Iranian student, relevant billing or payment information may also be needed to administer that service. We do not ask Iranian students to pay Study With FM for consultations or other services. You do not have to agree to optional marketing, public testimonials, photographs, video or other promotional activity to receive our core services.

12. Who We May Share Information With

Where necessary and lawful, we may share relevant information with:

• Schools, universities, colleges, admissions platforms, pathway providers and examination or language-testing organisations.
• Accommodation, guardianship, welfare, safeguarding, relocation and other providers involved in the service you request.
• Hosting, cloud-storage, IT, communications and security providers; website or analytics providers where used; payment-service providers where used; and professional accounting providers.
• Authorised Study With FM personnel, Study With FM Global Limited in Nigeria, and Iran-based contacts to the limited extent required to handle initial enquiries and referrals.
• Accountants, auditors, insurers, legal advisers, regulators, courts, public authorities and other recipients where a lawful reason applies.
• Relevant parties in a genuine and lawful business transfer or restructuring.

We share only information appropriate to the purpose. Some recipients, such as universities, immigration authorities and independent service providers, decide for themselves how they use your information and have their own privacy notices.

Universities may also receive the relevant application, admission or enrolment information needed to confirm a referral and administer university-paid commission under our institutional arrangements. Our Iran-based contacts are not responsible for the later application process and do not ordinarily need access to full UK-managed student files.

13. International Processing and Transfers

Education services often involve applicants, universities and service providers in different countries. Your information may therefore be processed or shared internationally where necessary for the support you request.

From Iran to the United Kingdom

Initial-enquiry information referred through our Iran-based contacts is forwarded to STUDY WITH FM LTD in the United Kingdom. Our UK team handles subsequent application records. We take appropriate steps to protect this information in transit and to meet applicable privacy requirements in each relevant jurisdiction.

Transfers or access from the UK to other countries

We may need to make relevant information available to overseas educational institutions, our Nigerian support company or other service providers. Where a transfer from the UK is a restricted transfer under UK data-protection law, we use an applicable legal mechanism, such as UK adequacy regulations, appropriate safeguards or a legally available exception, and carry out any necessary assessment.

This includes considering whether information held by our UK team is made accessible to a separate organisation outside the UK. You may contact us for information about safeguards relevant to your data. Using Study With FM does not itself authorise unrestricted international transfers.

14. How Long We Keep Personal Information

We keep information only as long as reasonably necessary for the purpose for which it was collected, subject to applicable legal, accounting, contractual, safeguarding and dispute-related requirements.

Enquiries that do not become client matters

We normally retain these records for up to 24 months after the last meaningful contact, unless an earlier deletion is appropriate or a longer period is legally justified.

Active and completed client files

We keep information needed for an active service while that service continues. General completed client and application records may be retained for up to six years after the service or client relationship ends, where justified by contractual, legal, complaint or dispute-related needs.

Passports, financial evidence and sensitive documents

We review particularly sensitive documents when the relevant service finishes and remove them earlier than the wider client file where there is no continuing need. Health, disability, SEN and accessibility information is retained only while necessary for an applicable service or other lawful purpose.

Safeguarding and welfare records may need different retention periods because of the nature of the concern and applicable duties. We restrict access and retain such records only for as long as necessary and lawful. Criminal-offence information is not kept longer than required for the lawful purpose for which it was processed.

Paid-service, commission and business records

Invoices, payment and refund information relating to paid client services, as well as university commission, accounting, tax and other statutory business records, are retained for the periods required by applicable law.

Marketing and publication permissions

Marketing records are retained only while relevant, with limited opt-out records kept as needed to honour objections. Consent and publication records for testimonials and media may be retained while authorised content remains in use and afterwards where reasonably needed to demonstrate the permission given.

Initial enquiry records handled in Iran

Our Iran-based enquiry contacts handle only the details needed for initial referral. Any locally held enquiry details are retained only for as long as needed to complete the referral or meet an applicable legal obligation, and are not used as a parallel application file.

Cookies and technical records

Retention for website technologies depends on the tools actually in use. Further information is available in our Cookie and Similar Technologies Policy.

15. Cookies and Similar Technologies

Our website may use cookies, browser storage and similar technologies to support functionality, security and, where applicable, preferences or website measurement. Some services may also use third-party technologies.

Where the law requires consent for a technology, we will request it before using that technology. For further information and any available choices, see our Cookie and Similar Technologies Policy.

16. Security

We use technical and organisational measures appropriate to the nature and sensitivity of the information we handle. These may include access restrictions, authentication, secure accounts and communications, confidentiality obligations and measures to protect against unauthorised access, loss, alteration or disclosure.

The Iran-based initial-enquiry role is limited to referral information; ongoing applications and supporting documents are managed by our UK team. No method of online transmission or electronic storage can be guaranteed completely secure.

17. Children and Young People

Our services may involve children and young people, including school and boarding applications, guardianship-related coordination, welfare and safeguarding support, and SEN or accessibility arrangements.

When handling information about someone under 18, we take account of their age and understanding, collect only what is relevant, involve a parent or guardian where appropriate, respect the young person's rights and views where relevant, and limit access to sensitive information. We seek the necessary permissions before publishing identifiable images, recordings or testimonials.

These protections also apply to initial enquiries referred from Iran. Where an enquiry concerns a child, a parent or guardian should be involved where appropriate and only the minimum introductory information should be shared. Children may have privacy rights in their own information.

18. Your Data Protection Rights

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

• Be informed about how your information is used and request access to it.
• Have inaccurate or incomplete information corrected.
• Request deletion or restriction of processing where the law allows.
• Receive certain information in a portable format where applicable.
• Object to processing based on legitimate interests and object to direct marketing at any time.
• Withdraw consent where consent is the lawful basis, without affecting processing lawfully carried out beforehand.
• Exercise rights relating to qualifying solely automated decisions, where applicable.

These rights are subject to legal conditions and exceptions. To make a request, email coordinator@studywithfm.com. We may ask for information needed to verify your identity. If your enquiry came through our contacts in Iran, you can contact STUDY WITH FM LTD directly about its use of your information.

19. Automated Decision-Making and Profiling

We may use digital systems to organise information, administer services or understand website use. These routine tools should not be confused with admission or immigration decisions, which are made by the relevant institutions or authorities.

If we introduce solely automated decision-making about individuals that has legal or similarly significant effects, we will assess it and provide the information, rights and safeguards required by law.

20. Privacy Complaints

If you are concerned about our handling of your information, please contact coordinator@studywithfm.com or call +44 7557 271171.

For complaints governed by UK data-protection law, we will acknowledge receipt within 30 days, investigate appropriately without undue delay, keep you informed as appropriate and communicate the outcome.

United Kingdom

You also have the right to complain to the Information Commissioner's Office (ICO) where UK law applies.

Website: ico.org.uk/make-a-complaint Telephone: 0303 123 1113

Nigeria

Where Nigerian data-protection law applies, you may complain to the Nigeria Data Protection Commission (NDPC).

Website: ndpc.gov.ng Email: info@ndpc.gov.ng Telephone: +234 916 061 5551 Address: 1919 Cadastral Zone C06, Mbora District, Opposite Efab City Estate, Life Camp, FCT, Abuja, Nigeria.

Enquiries referred from Iran

If you first contacted our team in Iran, you can contact STUDY WITH FM LTD using the details above about the handling of your information.

21. Other Websites and Platforms

Our website and services may link to websites, portals and platforms operated by schools, universities, government authorities, accommodation providers and other organisations. We do not control the privacy practices of independent providers. Please review their own privacy information when using their services.

22. Business and Corporate Changes

If a Study With FM business is reorganised, sold, merged or transferred, relevant personal information may be shared where necessary and lawful. We will review applicable privacy responsibilities and inform affected individuals where required.

23. Changes to This Policy

We may update this policy when our services, legal entities, providers, technology, referral arrangements, data-sharing practices or legal obligations change. The date at the top indicates when this text was last updated.

We will review the policy before materially expanding the role or system access of our contacts in Iran or making any other significant change to international information flows. Where required by law, we will tell affected individuals about a material change.

24. Applicable Data Protection Laws

For processing covered by UK law, the relevant framework includes the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations (PECR) and relevant changes made by the Data (Use and Access) Act 2025.

Processing involving our Nigerian operations may also be subject to the Nigeria Data Protection Act 2023 and applicable requirements of the Nigeria Data Protection Commission. Initial collection and referral of personal information in Iran must also comply with any applicable Iranian privacy and electronic-data requirements.

25. Contact Us

For privacy enquiries, information requests, objections or complaints, please contact:

Privacy and Data Protection Contact Email: coordinator@studywithfm.com UK telephone: +44 7557 271171

United Kingdom — STUDY WITH FM LTD Company number: 11417586 7 Westmoreland House, Cumberland Park, Scrubs Lane, London, England, NW10 6RE, United Kingdom.

Nigeria — Study With FM Global Limited RC number: 7602429 No. 25, Aare Avenue, New Bodija, Ibadan, Oyo State, Nigeria. Company email: info@studywithfm.com

Iran — initial enquiries and referrals Tehran, Iran. For privacy matters relating to an enquiry referred from Iran, please contact STUDY WITH FM LTD at coordinator@studywithfm.com.