PRIVACY POLICY

Effective Date: November 2026

Operating Entity: Positive Consultancy (A Division of Sadiqi Holdings LLC)

Corporate Hub: Washington State, USA | Compliance Contact: compliance@positivecons.com

1. OVERVIEW & SCOPE

Positive Consultancy (“Company,” “we,” “our,” or “us”), operating as the international academic mobility and student recruitment division of Sadiqi Holdings LLC, respects the privacy of prospective international students, recruitment partners, sub-agents, and institutional higher education clients. This Privacy Policy explains how we collect, process, store, and protect personal and institutional data submitted through positivecons.com and our affiliated digital portals.

2. INFORMATION WE COLLECT

Depending on your interaction with our network, we may collect:

• Recruitment Partner & Applicant Data: Full legal name, corporate email address, phone/WhatsApp number, country of operation, LinkedIn profile URL, business registration details, and historical student placement metrics.
• Student Academic & Identity Data: Academic transcripts, diplomas, language proficiency scores (IELTS/TOEFL/Duolingo), passport identification pages, statements of purpose, and financial sponsorship records required for university admissions.
• Technical & Usage Data: IP addresses, browser types, and standard security logs used to protect our servers from unauthorized access.

3. HOW WE USE INFORMATION

We process collected data strictly for legitimate B2B recruitment and higher education admissions purposes, including:

• Vetting and onboarding remote recruitment leads and sub-agents into our global network.
• Evaluating student eligibility and submitting verified admission applications to partner universities and accredited aggregator portals.
• Processing cross-border agent commission clearings and maintaining corporate tax and audit records.

4. REGULATORY COMPLIANCE (GDPR & FERPA)

All cross-border data transfers and student records are managed through our centralized compliance framework in Washington State, USA. We adhere to strict data minimization and security controls aligned with the U.S. Family Educational Rights and Privacy Act (FERPA) and the European Union General Data Protection Regulation (GDPR). We never sell, rent, or trade personal or student data to unauthorized third parties.

5. DATA SHARING & RETENTION

Data is shared strictly with accredited partner higher education institutions, authorized university admissions aggregators, and verified financial payment processors solely as required to complete student enrollments or partner payouts. Records are retained only for as long as necessary to satisfy institutional audit, legal, and regulatory obligations.

6. YOUR PRIVACY RIGHTS & CONTACT

Individuals and partners may request access to, correction of, or deletion of their personal data—or withdraw consent for data processing—by submitting a written request to our U.S. Compliance Desk at compliance@positivecons.com.