Privacy Policy.

1.1 IEDP Private Limited is the organisation responsible for the Hexallt Abroad service and acts as the data fiduciary or data controller for personal information processed for its own purposes.

1.2 Hexallt Abroad may also work with independent employers, professional authorities, credential evaluators, education or examination providers, immigration-related service providers and other pathway organisations. Those organisations may act as separate data controllers or data fiduciaries for information they receive and will be responsible for their own processing.

1.3 Questions or privacy requests may be sent to support@fly.hexallt.com or through the Hexallt Abroad contact page.

2.1 This policy applies when you:

• browse or interact with a Hexallt Abroad website;
• submit an enquiry, application or support request;
• communicate with us by email, telephone, WhatsApp, video meeting or another approved channel;
• complete VIARA or another assessment;
• enrol in or use a language, learning or professional-preparation service;
• provide documents for suitability, progression, verification or pathway support;
• participate in interview preparation or employer-facilitation activity; or
• purchase, receive or ask about a Hexallt Abroad service.

2.2 A third-party website, employer portal, government system, professional-authority system or external service linked from our website may have its own privacy notice. This policy does not replace the notice of an independent third party.

3.1 Depending on your interaction and pathway stage, we may collect the following categories of information:

• identity and contact information: name, date of birth, gender where relevant, address, country of residence, email address, telephone or WhatsApp number and identification details;
• professional and educational information: profession, qualifications, institutions attended, registration or licence information, employment history, experience, skills and professional references;
• enquiry and preference information: pathway interests, countries or professions considered, questions, communication preferences and information you provide about your goals;
• assessment information: answers, scenario responses, scores, observations, readiness indicators, assessment reports and human-review notes;
• learning and participation information: attendance, course access, assignments, language progress, trainer feedback, communication records and readiness development;
• documents and verification information: identity, qualification, employment, registration, language, credential-evaluation, immigration or other records reasonably required for the relevant stage;
• interview and progression information: preparation records, availability, employer interactions, feedback, selection status, offers and progression notes;
• payment and transaction information: invoices, amounts, payment status, refunds and transaction references, but not complete card or bank-account credentials handled directly by a payment provider;
• support and communication information: enquiries, calls, emails, WhatsApp messages, meeting notes, support tickets and complaints; and
• technical and usage information: IP address, browser or device information, cookies, page activity, referral information, form-source information and security logs.

3.2 We may request health, accommodation, background or other sensitive information only where it is relevant to a pathway, safety, legal or regulatory requirement, reasonable accommodation, or a candidate's specific request. Such information will be handled with additional care and only for an identified purpose.

3.3 Please do not provide information that has not been requested or is not reasonably relevant to your enquiry or pathway.

4.1 We ordinarily obtain personal information directly from you through forms, assessments, documents, meetings, learning systems, support channels and your use of our services.

4.2 We may also receive information:

• from an employer, institution, reference, pathway partner or service provider where you have authorised the exchange or another lawful basis applies;
• from assessment, learning, CRM, support, scheduling, communication or payment systems used to provide the service;
• from professional registers, credential-verification sources or other lawful public sources where verification is appropriate; and
• automatically through website technology, cookies and security logs.

4.3 Where information is received from another source, we use it only for the relevant lawful purpose and provide notice where required.

5.1 We may process personal information to:

• answer enquiries and recommend an appropriate starting point;
• evaluate suitability, adaptability and readiness for a pathway;
• administer VIARA and other assessments and explain their outcomes;
• provide language learning, professional preparation, pathway guidance and support;
• verify identity, qualifications, experience, documents and eligibility information;
• maintain candidate, service, attendance, progress, communication and payment records;
• prepare candidates for interviews and, where appropriate, facilitate interaction with employers;
• support credential evaluation, professional-recognition, examination, documentation or other external pathway steps;
• manage contracts, payments, refunds, complaints and legal obligations;
• protect candidates, staff, systems and services from fraud, misuse and security threats;
• improve services, content, systems and candidate experience using appropriate analytics; and
• send service communications and, where permitted, relevant updates or information about Hexallt Abroad services.

5.2 We do not sell personal information. We do not charge for or sell employment, and personal information is not shared with an employer merely because a candidate has made an initial enquiry.

6.1 We process personal information for lawful purposes. Depending on the circumstances and the law that applies, processing may be based on:

• your consent for a specified purpose;
• information you voluntarily provide for the purpose you request;
• steps requested before entering a contract or performance of a contract or Service Agreement;
• compliance with a legal, regulatory, accounting or record-keeping obligation;
• protection of legitimate legal rights, safety, systems or services; or
• a legitimate interest where permitted and not overridden by your rights.

6.2 A consent request will identify its purpose and should be read before you agree. Consent for marketing, employer disclosure, sensitive information or another distinct purpose may be requested separately.

6.3 You may withdraw consent by contacting us. Withdrawal does not invalidate processing already carried out lawfully and may prevent us from continuing a service that requires the information.

7.1 Information submitted through an enquiry or application form may be entered into our customer or candidate relationship systems so that we can respond, avoid duplicate records, record consent, assign follow-up and understand the source of the enquiry.

7.2 An enquiry does not itself enrol you in a paid service or authorise disclosure of your profile to an employer.

7.3 We may use enquiry information to provide relevant pathway guidance and reasonable follow-up. Promotional communication will be handled in accordance with your choices and applicable law.

8.1 VIARA and other Hexallt assessments may collect scenario responses, scores, behavioural or readiness indicators, written or spoken responses, timestamps, integrity information and reviewer observations.

8.2 Assessment information is used to understand areas such as professional adaptability, language and learning adaptability, cultural and normative adaptability, motivation, resilience and pathway alignment.

8.3 Structured scoring or automated calculation may support an assessment. Material progression or suitability decisions are not intended to be made solely by an automated score; assessment information may be reviewed by authorised Hexallt personnel and considered with other relevant information.

8.4 You may ask for clarification of an assessment outcome or request a reasonable human review. An assessment does not determine an employer, licensing, immigration or government decision.

8.5 Assessment reports may be shared with you. A candidate-facing or employer-facing report will be shared with an employer only at an appropriate stage, with notice or authority, and only to the extent reasonably relevant.

9.1 As the service or pathway progresses, you may be required to provide appropriate and genuine documentation needed for assessment, learning administration, credential evaluation, professional recognition, employer review, immigration-related coordination or other processing applicable to that stage.

9.2 We may check documents for completeness, consistency and apparent authenticity and may ask for clarification, updated copies, certified copies or verification through an appropriate source.

9.3 Documents will be used and disclosed only for the relevant purpose. Where an external authority, evaluator, employer or service provider requires the document, we will explain the applicable step or obtain appropriate authority before disclosure unless the disclosure is otherwise required or permitted by law.

9.4 You must not submit another person's personal information without authority and must promptly tell us if submitted information is inaccurate, outdated or no longer authorised.

10.1 When you use a learning or preparation service, we may process enrolment, access, attendance, progress, assignment, assessment, trainer-feedback and support information.

10.2 Sessions may be recorded only where recording is reasonably necessary and participants have been informed or consent has been obtained where required. A recording will not be used for an unrelated purpose without further authority.

10.3 Learning information may be used to provide feedback, determine readiness for a subsequent stage, maintain quality and resolve service or participation concerns.

11.1 When a candidate reaches an appropriate stage, Hexallt may facilitate an employer interaction or interview. Before relevant profile information is disclosed, the candidate will be informed of the intended employer interaction or otherwise provide appropriate authority.

11.2 Information disclosed may include relevant identity, contact, qualification, experience, registration, language, readiness, assessment, document or interview-preparation information.

11.3 Employers make their own selection and employment decisions and may process candidate information under their own privacy practices. Hexallt does not control an employer's independent processing after lawful disclosure.

11.4 We may receive interview feedback, selection information, offer information or onboarding updates and use it to support the candidate and maintain an accurate progression record.

12.1 A pathway may involve credential evaluators, examination providers, professional authorities, government bodies, immigration or relocation services, translators, education providers and other independent organisations.

12.2 Where Hexallt assists with such a stage, relevant information may be shared with the applicable organisation on your instruction, with your authority, for contract performance or where otherwise permitted by law.

12.3 External organisations determine their own requirements, security practices, retention and decisions. You should read their privacy notices before submitting information directly to them.

13.1 We may use carefully selected providers for website hosting, forms, CRM and candidate management, assessment delivery, learning delivery, document storage, support, scheduling, video communication, messaging, email, analytics, security, invoicing and payments.

13.2 A provider may process information only to deliver the relevant service, under appropriate confidentiality, security and data-protection terms where required.

13.3 We limit provider access to information reasonably needed for its function and review providers according to the nature and risk of the processing.

14.1 Hexallt Abroad operates from India and supports international pathways. Personal information may therefore be accessed, hosted or processed in India, the Netherlands, another destination country, or another country where an authorised employer, authority or service provider operates.

14.2 Where a cross-border transfer is made, we use the safeguards required by applicable law. Depending on the circumstances, these may include contractual protections, transfer terms, consent, security controls, data minimisation or another recognised transfer mechanism.

14.3 Where European data-protection law applies, transfers outside the European Economic Area will be handled using an applicable adequacy basis, contractual safeguard, permitted derogation or other lawful mechanism.

15.1 Payments may be processed by an external payment service. Hexallt normally receives transaction status, amount, date, reference and limited payer information needed for accounting, support, refunds and fraud prevention.

15.2 Complete card credentials, banking passwords, one-time passwords and similar payment authentication information should be entered only in the authorised payment provider's secure interface and not sent to Hexallt by email, WhatsApp or a general enquiry form.

15.3 Financial and transaction records may be retained for the period required by tax, accounting, contract, audit and legal obligations.

16.1 Our websites may use strictly necessary cookies and similar technology for security, forms, navigation, accessibility and essential functionality.

16.2 With appropriate notice or consent where required, analytics or preference technology may be used to understand page performance, referral sources and how visitors use the website so that we can improve it.

16.3 You may manage optional cookies through any available consent control or your browser settings. Blocking necessary cookies may affect website or form functionality.

16.4 More detailed cookie information may be presented through the website's cookie notice or consent interface.

17.1 We may use email, telephone, WhatsApp, support tickets or another channel to respond to you and provide service, assessment, learning, payment, interview or pathway information.

17.2 Messages sent through a third-party communication service are also subject to that service's privacy practices. Do not send highly sensitive documents through a channel unless Hexallt has asked you to use it for that purpose.

17.3 We may send relevant service information where permitted. Optional marketing messages will include a practical way to opt out, and an opt-out will not stop essential communications about an active service.

18.1 We retain personal information only for as long as reasonably required for the stated purpose, an active enquiry or service, candidate progression, quality or safety, dispute resolution, enforcement of agreements and applicable legal, accounting or regulatory obligations.

18.2 Retention is determined by the nature and sensitivity of the information, the pathway stage, the length of the relationship, legal limitation periods, external-authority requirements and the risk created by continued retention.

18.3 Typical retention categories are:

• enquiry records for a reasonable follow-up and service-development period;
• assessment and learning records for progression, report access, quality, integrity and dispute purposes;
• candidate and document records for the active pathway and any legally required post-service period;
• employer or external-process records for the relevant interaction and necessary follow-up;
• finance and contract records for statutory accounting, tax, audit and claims periods; and
• marketing preferences until consent is withdrawn, an objection is received or the record is no longer reasonably useful.

18.4 Information will be deleted, anonymised or access-restricted when it is no longer required, subject to technical backup cycles and lawful retention duties.

19.1 We use reasonable administrative, contractual, organisational and technical measures appropriate to the information and processing risk. Measures may include access controls, role-based permissions, authentication, encryption in transit, backups, logging, staff obligations and provider controls.

19.2 Access is limited to people and organisations with a legitimate need for the relevant purpose.

19.3 No internet or storage system can be guaranteed completely secure. If a personal-data incident creates a notification duty, we will take appropriate containment, investigation and notification steps under applicable law.

20.1 You should provide accurate, complete and current information and promptly correct any material change affecting your enquiry, assessment, service or pathway.

20.2 You are responsible for protecting account credentials, using approved submission channels and not sharing another person's information without authority.

20.3 Hexallt may pause processing, request verification or restrict access if information appears fraudulent, materially inconsistent, unsafe or unauthorised.

21.1 Subject to applicable law and any lawful limitation, you may request:

• confirmation or a summary of personal information being processed;
• access to relevant personal information and information about its use or sharing;
• correction, completion or updating of inaccurate or incomplete information;
• deletion or erasure where the information is no longer required and retention is not legally necessary;
• withdrawal of consent for future consent-based processing;
• restriction of or objection to particular processing where the law provides that right;
• a portable copy where applicable; or
• review of a material decision supported by automated processing.

21.2 You may also nominate another person to exercise applicable rights in the event of death or incapacity where Indian law provides that right.

21.3 To protect candidates and prevent unauthorised disclosure, we may verify identity and authority before acting on a request. We may ask you to clarify the information or processing concerned.

21.4 A request may be refused or limited where retention or processing is required by law, necessary for legal claims, protects another person's rights, or another lawful exception applies. We will explain the reason where required.

22.1 Privacy questions, rights requests or grievances should first be sent to support@fly.hexallt.com with sufficient information for us to identify the relevant record and concern.

22.2 We will acknowledge and address the matter within the period required by applicable law and may contact you for verification or clarification.

22.3 If the matter is not resolved, you may use the further complaint or regulatory route available under the privacy law that applies to you, including the Data Protection Board of India when its jurisdiction and procedure apply, or the relevant European supervisory authority where European data-protection law applies.

23.1 Hexallt Abroad's professional pathways and paid candidate services are intended for adults. We do not knowingly enrol a person under 18 in a professional migration pathway.

23.2 If information about a child is required for a lawful dependent, family, travel or immigration-related purpose, it will be requested only at the relevant stage and handled with appropriate parental or guardian authority and legal safeguards.

23.3 If you believe a child has submitted personal information without proper authority, contact us so that we can investigate and take appropriate action.

24.1 Our websites and communications may link to employers, authorities, payment providers, support systems, learning platforms, social networks or other independent services.

24.2 Hexallt is not responsible for an independent service's privacy practices. Review the privacy notice and security of the service before providing personal information.

25.1 We may update this policy when services, systems, pathways or legal requirements change.

25.2 The current version will be published at Hexallt Abroad Privacy Policy with its effective or revision date.

25.3 A material change affecting active candidates may also be communicated through an appropriate service channel. Continued use after an update does not replace any consent that applicable law requires us to obtain separately.

26.1IEDP Private Limited – Hexallt Abroad
#202, Nandini Elegance 1
1st Main, 3rd Cross, MLA Layout
Kalena Agrahara, Bannerghatta Road
Bengaluru, Karnataka 560076
India

26.2Phone: +91 80 4710 8000
Email: support@fly.hexallt.com
Contact page: Hexallt Abroad contact page
Support Centre: Hexallt Abroad Support Centre

26.3 When contacting us about privacy, use the subject Privacy Request – Hexallt Abroad and describe the record, service or processing involved. Do not include passwords, one-time passwords or unnecessary sensitive documents in the initial message.