Newland Pathway ("Newland Pathway", "we", "us", "our") helps students and professionals secure university admission, study visas, work permits and relocation support in Bulgaria and across Europe. This Privacy Policy explains how we collect, use, share and protect your personal data when you use newlandpathway.com, our student portal, WhatsApp, social media pages and our services. We process personal data in line with the Nigeria Data Protection Act 2023 (NDPA), the General Application and Implementation Directive (GAID) 2025 issued by the Nigeria Data Protection Commission (NDPC), and, where it applies, the EU General Data Protection Regulation (GDPR) and the Bulgarian Personal Data Protection Act.
1. Who we are (Data Controller)
- Name: Newland Pathway. Registered business details available on request.
- Director: Sarah Raji
- Offices: Sofia, Bulgaria and Nigeria
- Email: newlandpathway@gmail.com
- Phone: +234 815 486 9745 (Nigeria), +359 87 694 4800 and +359 88 238 1863 (Bulgaria)
- Data Protection Officer (DPO): Data Protection Officer, privacy@newlandpathway.com
2. Personal data we collect
Some of this is sensitive personal data under the NDPA (for example health records or a police certificate). We collect it only when a university, embassy, employer or immigration authority requires it, and only with your explicit consent.
| Category | Examples |
|---|---|
| Identity | Full name, date of birth, gender, nationality, passport details, photographs |
| Contact | Email, phone and WhatsApp number, home address |
| Education | WAEC/NECO/GCE results, transcripts, certificates, degree records, reference letters |
| Work and career (work-permit clients) | CV, employment history, skills, professional certificates |
| Visa and travel | Visa history, travel history, bank statements, sponsor details, police character certificate, medical/insurance documents requested by an embassy or employer |
| Guarantor data | Name, contact details and ID of any guarantor or sponsor you give us |
| Payment | Amounts paid, payment dates, receipts (we do not store full card numbers) |
| Portal and technical | Login details, IP address, device and browser type, pages visited, cookie choices |
| Communications | Messages, call notes and consultation notes |
3. How we collect it
- Directly from you: forms on our website, the student portal, WhatsApp, email, calls and consultations.
- From third parties with your permission: schools, exam bodies (for results verification), universities, employers, guarantors and sponsors.
- Automatically: cookies and similar technologies (see our Cookie Policy).
4. Why we use your data and our lawful basis
We do not sell your personal data.
| Purpose | Lawful basis (NDPA s.25 / GDPR Art. 6) |
|---|---|
| Booking consultations and answering enquiries | Consent; steps before a contract |
| Verifying your results before you pay | Consent |
| Preparing and submitting university applications | Performance of contract |
| Visa, residence and work-permit applications | Performance of contract; explicit consent for sensitive data |
| Matching work-permit candidates with licensed partner employers/agencies | Performance of contract; consent |
| Running your student portal account | Performance of contract |
| Payments, invoices and record-keeping | Legal obligation; contract |
| Arrival support, accommodation and airport pickup | Performance of contract |
| Sending updates, intake offers and newsletters | Consent (you can opt out any time) |
| Improving our website and services | Legitimate interest; consent for non-essential cookies |
| Fraud prevention and legal claims | Legitimate interest; legal obligation |
5. Automated tools and AI
We use digital and AI-assisted tools to organise documents, track your progress and draft communications. No final decision about your admission, visa or employment is made by a machine alone; a member of our team reviews every decision. You may ask for a human review at any time.
6. Who we share your data with
We share only what is needed for your application:
- Universities and colleges in Bulgaria and Europe you apply to.
- Embassies, consulates, the Bulgarian Migration Directorate, Employment Agency and other government authorities.
- Licensed recruitment partners and employers in Bulgaria (for work-permit clients).
- Our legal advisers, including Olusegun Raji Chambers, Lagos.
- Trusted service providers: website hosting, cloud storage, email, WhatsApp (Meta), payment processors, courier and document translation/legalisation services.
- Authorities where the law requires it.
Every service provider must sign a data processing agreement and keep your data secure.
7. International transfers
Our work involves moving your data between Nigeria, Bulgaria and other EU countries. The EU and Bulgaria are covered by the GDPR, which provides an adequate level of protection. Where we transfer data to any other country, we rely on NDPA Part VIII safeguards: adequacy, standard contractual clauses, your consent, or transfers needed to perform our contract with you.
8. How long we keep your data
| Data | Retention |
|---|---|
| Enquiry and consultation data (no contract signed) | 12 months after last contact |
| Client files (admission, visa, work permit) | 6 years after the service ends, for legal and tax purposes |
| Payment records | 6 years (tax law) |
| Marketing consent | Until you withdraw it |
| Cookie consent records | 12 months |
After that we delete or anonymise the data.
9. Your rights
Under the NDPA (sections 34-38) and GDPR you have the right to:
- Be informed about how your data is used.
- Access a copy of your data.
- Correct inaccurate or incomplete data.
- Delete your data (where we have no legal reason to keep it).
- Restrict or object to processing, including direct marketing.
- Receive your data in a portable format.
- Withdraw consent at any time (this does not affect processing already done).
- Not be subject to decisions based solely on automated processing.
- Complain to the Nigeria Data Protection Commission (ndpc.gov.ng) or, in Bulgaria, the Commission for Personal Data Protection (cpdp.bg).
To exercise a right, email privacy@newlandpathway.com or use the request option in your portal. We reply within 30 days and may ask you to confirm your identity.
10. Security
We use encrypted connections (HTTPS), password-protected portal accounts, restricted staff access, and secure cloud storage. Staff and partners are bound by confidentiality. If a data breach puts your rights at risk, we will notify the NDPC within 72 hours and inform you without undue delay.
11. Children
Some of our students are under 18. If you are under 18, a parent or guardian must give consent and sign our service agreement on your behalf. We verify parental consent before processing a minor's data.
12. Third-party links
Our website links to WhatsApp, Instagram, TikTok, Facebook, YouTube and our course finder on Canva. Those sites have their own privacy policies, which we do not control.
13. Changes to this policy
We may update this policy. We will post the new version here with a new "Last updated" date, and notify portal users of major changes by email. Current version date: 23 September 2026.
14. Contact
Questions or complaints: Data Protection Officer, privacy@newlandpathway.com, newlandpathway@gmail.com, +234 815 486 9745.
Related: Privacy Policy · Cookie Policy · Terms and Conditions