Privacy Policy
We collect contact details you submit via forms to respond to counseling requests. Contact support@subraxo.com for privacy questions.
Privacy Policy - Subraxo
Last Updated: August 2026
1. Who We Are and What This Policy Covers
Subraxo ("Subraxo," "we," "us," or "our") is a study abroad consultancy platform operated by Subraxo Pvt. Ltd, a company incorporated under the laws of India, having its registered office at [REGISTERED ADDRESS]. Subraxo helps Indian students explore universities abroad, apply for scholarships, and access education loan facilitation through our partner lending institutions, at no cost to the student.
This Policy explains what personal data we collect when you use subraxo.com or our mobile applications ("Platform"), why we collect it, who we share it with, and the choices and rights you have over it. It applies to every visitor, registered user, and student who interacts with the Platform, regardless of whether you eventually use our services.
This Policy is drafted in line with the Digital Personal Data Protection Act, 2023 (DPDP Act), and, to the extent applicable, the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021.
If you do not agree with this Policy, please do not use the Platform or share any information with us.
2. Key Terms Used in This Policy
- "Personal Data" means any data about an individual who is identifiable by or in relation to such data, as defined under the DPDP Act, 2023.
- "Processing" means any operation performed on Personal Data, including collection, storage, use, sharing, or deletion.
- "Data Fiduciary" means Subraxo, which determines the purpose and means of processing your Personal Data.
- "Data Principal" means you, the individual whose Personal Data is being processed.
- "University Partners" means the foreign educational institutions listed or represented on the Platform.
- "Lending Partners" means the banks and non-banking financial companies (NBFCs) that offer education loans through the Platform.
- "Services" means university guidance, scholarship discovery, and education loan facilitation offered through the Platform.
3. How Your Data Moves Through Subraxo
Rather than listing every data point in isolation, it helps to understand what we collect at each stage of your journey with us, since the categories and purposes shift as you move deeper into our Services.
Stage 1 - Browsing and Sign-up. When you create an account, we collect your name, email address, phone number, and a password. If you sign up using Google or another third-party login, we receive your basic profile information from that provider.
Stage 2 - Building Your Academic Profile. To recommend universities and scholarships, we ask for your academic records (grades, standardized test scores such as IELTS/TOEFL/GRE/GMAT, target countries and courses), work experience where relevant, and your budget range for studies abroad.
Stage 3 - Counseling and Application Support. If you engage with our counseling team, we record notes from calls or chats, documents you upload (transcripts, statements of purpose, recommendation letters, passport copies), and your application status with University Partners.
Stage 4 - Loan Facilitation. If you choose to explore an education loan, we collect financial information such as co-applicant details, income proof, collateral documents, and KYC identifiers (PAN, Aadhaar, passport), which we share only with the Lending Partner(s) you choose to apply through.
Stage 5 - Visa and Pre-Departure. If you use our visa guidance resources, we may collect visa application status and travel-related information to help you track next steps.
You are never required to complete every stage - you can use Subraxo purely for university research without ever sharing financial or visa information.
4. Information We Collect Automatically
- Device and usage data: IP address, browser type, device identifiers, pages visited, time spent, and referring links.
- Cookies and similar technologies: used to keep you signed in, remember your preferences, and understand how students use the Platform. See Section 9 for details.
- Communication metadata: if you email, WhatsApp, or call us, we retain records of that interaction to provide support and improve our counseling quality.
We do not access your phone's contact list, call logs, or SMS inbox, and we do not collect biometric data.
5. Why We Process Your Data
We process your Personal Data to:
- Match you with suitable universities, courses, and scholarships based on your academic profile.
- Facilitate your loan application with Lending Partners of your choice and support you through disbursal.
- Provide personalized counseling, including through calls, emails, and WhatsApp.
- Share your application material with University Partners at your request.
- Improve our recommendation algorithms and content using aggregated, de-identified data.
- Send you service updates, deadline reminders, and - where you have opted in - promotional communication.
- Comply with applicable law, respond to lawful government requests, and enforce our Terms & Conditions.
- Detect fraud and protect the security of the Platform.
We rely on your consent as the primary basis for processing, except where processing is necessary to comply with a legal obligation or to respond to a request you have made to us (such as an application).
6. Who We Share Your Data With
We do not sell your Personal Data. We share it only in the following circumstances:
- Lending Partners: Financial and KYC information is shared only with the specific bank(s) or NBFC(s) you choose to apply to, so they can assess and process your loan application. We earn a commission from Lending Partners when a loan is disbursed through the Platform - this is how Subraxo remains free for students, and it does not influence which lender is right for your application.
- University Partners: Academic and application documents are shared with the specific institutions you apply to, only after you authorize the application.
- Service Providers: We engage vendors for hosting, analytics, payment processing (where applicable), and customer support, bound by confidentiality obligations and permitted to use your data only to perform their function for us.
- Legal and Regulatory Authorities: Where required by law, court order, or a valid request from a government authority.
- Business Transfers: If Subraxo is involved in a merger, acquisition, or asset sale, your data may be transferred as part of that transaction, subject to this Policy or an equivalent standard of protection.
7. Cross-Border Transfer of Your Data
Because Subraxo helps you apply to universities and scholarship bodies outside India, parts of your academic and application data will necessarily be transferred to institutions located abroad, including in the United States, the United Kingdom, Canada, Germany, Australia, France, New Zealand, and Ireland. This transfer happens only for the specific applications you choose to submit, and only to the institution(s) you are applying to. We take reasonable steps to ensure that recipients handle your data under confidentiality and security standards consistent with this Policy, and, where applicable, in accordance with the DPDP Act, 2023 and any rules issued by the Central Government regarding cross-border data transfer.
8. Data Storage, Security and Retention
Your data is stored on secure servers with access restricted to authorized Subraxo personnel on a need-to-know basis. We use encryption, access controls, and regular security reviews to protect your information against unauthorized access, alteration, or loss.
We retain your Personal Data only for as long as necessary to provide the Services, comply with legal obligations, or resolve disputes. As a general guide:
- Academic and application data is retained for the duration of your active use of the Platform and for a reasonable period afterward in case you return to the process.
- Financial and KYC data shared for loan facilitation is retained as required under applicable financial regulations, and deleted or anonymized thereafter.
- If you request account deletion, we will delete or anonymize your Personal Data within [NUMBER] days, except where retention is required by law.
9. Cookies
We use cookies and similar technologies to keep you logged in, remember your preferences (such as your target country or course interest), and understand which content helps students the most. You can manage or disable cookies through your browser settings, though this may limit some Platform features. Where required, we will present a cookie consent banner allowing you to accept or customize cookie categories before non-essential cookies are set. For full details, refer to our separate Cookie Policy.
10. Your Rights
As a Data Principal under the DPDP Act, 2023, you have the right to:
- Access a summary of the Personal Data we hold about you and how it is being processed.
- Correct or update inaccurate or incomplete information.
- Erase your Personal Data, subject to our legal and regulatory retention obligations.
- Withdraw consent at any time for processing based on consent, without affecting the lawfulness of processing carried out before withdrawal.
- Nominate another individual to exercise these rights on your behalf in the event of your death or incapacity.
- Grievance redressal through our Grievance Officer detailed in Section 12.
To exercise any of these rights, write to us at [PRIVACY EMAIL] with the subject line describing your request. We will respond within [NUMBER] days.
11. Children's Privacy
Subraxo's Services are intended for individuals who are 18 years of age or older, or who have the consent of a parent or legal guardian where local law permits use below that age. We do not knowingly collect Personal Data from children without appropriate parental or guardian consent. If we become aware that we have collected data from a minor without such consent, we will take steps to delete it.
12. Grievance Officer
In accordance with applicable Indian law, we have appointed a Grievance Officer to address any concerns regarding this Policy or the processing of your Personal Data.
Name: [GRIEVANCE OFFICER NAME] Designation: Grievance Officer / Data Protection Contact Email: support@subraxo.com Address: [REGISTERED ADDRESS]
We aim to acknowledge grievances within [NUMBER] days and resolve them within [NUMBER] days of receipt.
13. Links to Other Websites
The Platform may contain links to University Partner websites, Lending Partner portals, or other third-party resources. This Policy does not extend to those websites. We encourage you to review the privacy policy of any third-party site before sharing information with it.
14. Changes to This Policy
We may update this policy from time to time to reflect changes in our practices, services, or applicable law. The updated version will be posted on this page with a revised "Last Updated" date. Where changes are significant, we will notify you through the platform or by email.
15. Governing Law and Jurisdiction
This Policy is governed by the laws of India. Any disputes arising out of or in connection with this Policy shall be subject to the exclusive jurisdiction of the courts at [CITY], India.
16. Contact Us
If you have questions about this Privacy Policy or how your data is handled, reach out to us at
Email: support@subraxo.com Address: [REGISTERED ADDRESS]