Last Updated: September 3, 2025.

This Privacy and Data Retention Policy (“Policy”) governs the collection, use, retention, and protection of personal information by Welbright Consulting (“Welbright,” “we,” “our,” or “us”). For the purposes of this Policy, “Client,” “you,” or “your” refers to any individual or entity that engages or seeks to engage Welbright’s services. This Policy forms an integral part of Welbright’s Terms and Conditions and shall be read in conjunction therewith. By using our services, the Client acknowledges and agrees to be bound by the terms of this Policy.

1. Scope and Definitions

This Policy applies to personal information processed by Welbright in connection with the provision of educational admission, immigration, translation, interpretation, and related consulting services. “Personal information” means information that identifies, relates to, describes, or could reasonably be linked with a particular individual or household, including personal identifiers, academic records, financial information, and immigration-related materials.

2. Information We Collect

Welbright may collect personal information necessary to deliver services, comply with legal obligations, and respond to Client requests. This may include, without limitation, personal identifiers such as name, contact details, and government-issued identification, as well as academic records, financial information, and immigration-related materials. Welbright does not collect or store payment card information; all transactions are processed securely by third-party payment providers selected by the Client and are subject to such providers’ own terms and privacy policies, as described in Section 9 – Third-Party Services. The scope of information collected by Welbright will be limited to what is reasonably required for the purposes described in this Policy and our Terms and Conditions.

3. Use of Information

Welbright shall use personal information solely for providing and improving our services, facilitating admissions and immigration-related processes, maintaining communications with Clients, and satisfying applicable legal, regulatory, and tax obligations. Welbright shall not use personal information for marketing purposes unrelated to our services, and shall not sell personal information.

4. Data Retention

Welbright shall retain Client records, including financial, business, and immigration-related documents, for a minimum period of seven (7) years from the date of service completion or the relevant tax year, whichever is later. This retention period is intended to align with IRS recommendations and industry practices and to support potential Client needs. Upon expiration of the retention period, Welbright shall ensure that such records are permanently deleted or securely destroyed.

5. Data Security

Welbright shall maintain appropriate administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. Client records are maintained electronically in secure systems with restricted access. Any physical materials provided to Welbright are promptly converted to digital format and securely shredded. Payment information is not stored by Welbright; all payment processing is handled solely by third-party providers selected by the Client and is subject to such providers’ own terms and privacy policies, as described in Section 9 – Third-Party Services.

6. Disclosure of Information

Welbright shall not share or disclose personal information to third parties except as required by applicable law, regulation, or lawful order; as necessary to carry out the services requested by the Client (for example, when submitting materials to schools, credential evaluators, or other relevant institutions at the Client’s direction); or with the Client’s prior authorization. Such third parties are subject to their own terms, conditions, and privacy policies, as described in Section 9 – Third-Party Services. Welbright does not sell personal information under any circumstances.

7. Client Rights

Subject to legal and regulatory retention requirements, the Client may request access to or deletion of certain personal information. Welbright will respond to such requests as required by applicable law and consistent with operational and recordkeeping obligations. Requests should be submitted in writing using the contact information provided on Welbright’s website.

8. Updates to This Policy

Welbright reserves the right to amend or update this Policy from time to time to reflect changes in legal, regulatory, or business requirements. Any such updates shall be effective upon publication. The most current version will be available on Welbright’s website.

9. Third-Party Services

Welbright’s services may involve the use of third-party providers, including but not limited to payment processors, educational institutions, credential evaluators, testing agencies, and other entities relevant to the Client’s case. Any information shared with such third parties is subject to their respective terms, conditions, and privacy policies. Welbright is not responsible for the practices of these third parties, and Clients are encouraged to review the applicable terms and privacy policies directly.