Privacy Policy | First Counselor – AI Study Abroad Guidance

(Last modified on 01,08.2025)

(Last modified on 01,08.2025)

Your privacy is important to us. The purpose of this privacy policy (“Privacy Policy”) is to make you aware of: (a) what personal data First Counselor collects, a brand under Manifest Global (“First Counselor”, “we”, “us” or “our”) when someone interacts with First Counselor directly and/or through its website or social media channels (“Channels”), and (b) how First Counselor uses, discloses and otherwise processes such personal data of personnel, agents, account holders, students and/or legal guardians (“User” or “you”). This Privacy Policy applies to personal data that we collect through the Channels as a controller. By using any of the Channels, you agree to the processing of your information as explained in this Privacy Policy.

If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), please also consult the EEA/UK GDPR Annex A below. For residents in the People’s Republic of China (“PRC”), please also consult the PRC Annex B below.

1. Who We Are and Our Data Processing Role

First Counselor acts as a CONTROLLER – It processes personal data on its own initiative and discretion. How to process your personal data and for which purposes, as explained in this Privacy Policy.

2. Contact Us

If you have any questions about this Privacy Policy or want to exercise any rights you may have with respect to your personal data, as set out in this Privacy Policy, please contact us at: legal@manifest.inc. Our mailing address is 52 Joo Chiat Rd, #02-01, Singapore 427374. Please mark all correspondence to us for the attention of the Data Protection Officer.

3. Information We Collect

We may collect the following information when a user interacts with our Channels or provides us with such information:

Contact details: We collect the following information about you, including when (a) we meet you at events or workshops, (b) you interact with us (through our Channels or otherwise) by filling any forms or raising queries, (c) you send us emails, (d) you call us, (e) you write to us and/or (f) otherwise seek information from us: your first and last name, email address, phone number, job title, organization name, country and city. If the Channel used by you to interact with First Counselor is a social media platform, you may allow us to have access to certain personal data from your social media profile based on your privacy preference settings on such social media platform. In some instances, First Counselor automatically collects personal data pertaining to you when you visit our website and through e-mails that we may exchange.
Feedback or Correspondence: We may collect information such as when you contact us with questions, feedback, or otherwise correspond with us online.
Usage information: We may collect information about how you use the Channels and interact with us, including information you submit to us. First Counselor’s website will collect a combination of the IP address and cookie ID from website visitors. We may use automated technologies (including the use of web server logs) to collect such IP addresses, device details, cookies, and web beacons.

4. How We Use Your Personal Data

For marketing purposes: We and/or our third-party marketing partners may use personal data collected from you for our marketing purposes. We may organize events and workshops in which your contact details may be collected for this purpose. You can opt out of our marketing emails at any time by clicking on the unsubscribe button at the bottom of our email communications.
For security and maintenance of our Channels: We process your personal data for security and maintenance purposes, including to measure the performance of our Channels; to enforce applicable terms and conditions; to protect our rights, privacy, safety or property and/or that of you or others; and to protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
To analyze and improve our Channels and develop new products and services: We may use personal data, including through the use of analytics, to improve our Channels, to better understand how our Channels are used, to understand what web content may be of interest to you and to deliver relevant web content to you and to measure or understand the effectiveness of the content we serve to you. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal data we collect. We may make personal data anonymous by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the service and promote our business. For this purpose, we may also ask for your feedback and send you satisfaction surveys.
To comply with any legal or regulatory requirements: We may use collected personal data to comply with legal or regulatory requirements, lawful requests, and legal processes (such as to respond to subpoenas or requests from government authorities) and to audit our internal processes for compliance with such requirements or with our internal policies.
To establish, exercise, and defend ourselves in the context of legal claims: We may process collected personal data as we, in good faith, believe is necessary or appropriate to defend our legal interests.
To disclose your personal data to a prospective or actual purchaser or seller: We may disclose your personal data if Manifest Global (First Counselor's parent company) is involved in, or is contemplating, a business transaction, including in the context of a merger, acquisition, sale of all or a portion of our business or assets, bankruptcy, reorganization or similar event.

5. Who We Share Your Personal Data With

We may share your personal data with the following categories of third parties for purposes described in this Privacy Policy:

Affiliates: We may share your personal data with our subsidiaries and affiliates, including but not limited to Manifest Global.
Service providers/Sub-processors: We may share your personal data with, or transfer your personal data to, our service providers/sub-processors to help us operate the Channels (e.g. hosting, information technology, marketing, and analytics, etc.).
Authorities and others: We may share your personal data with government, law enforcement officials or private parties as required by law, when we believe such disclosure is necessary or appropriate to (a) comply with applicable law; (b) enforce applicable terms and conditions; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
Organizations Involved in Business Transfers or Potential Business Transfers: We may disclose or transfer your personal data in connection with an actual or potential business transaction, including in the context of a merger, acquisition, sale of all or a portion of our business or assets, bankruptcy, reorganization or similar event involving Manifest Global.

6. International Data Transfer

We are headquartered in Singapore and may use service providers/sub-processors that operate in other countries. We may also transfer your personal data to our affiliates that are located outside of Singapore for purposes described in this Privacy Policy. Your personal data may be transferred to locations where privacy laws may be different from those in your state, province, or country.

If you are located in the EEA or the UK, or China, we will transfer your personal data outside the EEA/UK or China in accordance with the provisions on data transfers in the EEA/UK GDPR Annex A and China Annex B below.

7. Your Privacy Rights

Under certain circumstances, if and to the extent provided by any law applicable to your personal data, you may have certain rights with respect to your personal data. Such rights may include the right to access, update, rectify, or erase certain personal data that we have about you, or restrict or object to certain activities with respect to your personal data. To the extent you have such rights, you may exercise them as described herein.

Since we process your personal data as a controller, you may exercise any rights you may have under applicable privacy laws by contacting us using the details in Section 2 of this Privacy Policy. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

8. Data Retention

We may retain your personal data as long as necessary for the purpose for which it was collected, including to comply with and enforce the terms of our agreements with our business customers, and beyond such time to the extent legally permitted and based on our legal obligations or legitimate interests (e.g. in retaining data for the purposes of responding to possible disputes or complaints).

9. Information Security

First Counselor uses technical, organizational, and physical safeguards designed to protect information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. We cannot, however, guarantee that any safeguards or security measures will be sufficient to prevent a security issue.

10. Age Limitations

The Channels are not intended for children under the age of thirteen (13), and we do not knowingly collect data relating to such children. If we learn that we have collected personal data through our Channels from a child under the age of thirteen (13) without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information. We encourage parents or guardians to contact us using the details in Section 2 of this Privacy Policy if the child has accessed the Channel without their authorization.

11. Third-Party Channels

Our Channels may integrate with or enable access to third-party tools (such as social media plug-ins). If you register, install, or access any third-party tools, you may be required to accept privacy notices provided by those third-party tools. Please review any applicable third-party notices carefully. First Counselor does not control and is not responsible for these third parties’ privacy or information security practices.

12. Changes to this Privacy Policy

First Counselor reserves the right to modify this Privacy Policy at any time. We, thus, advise you to check this Privacy Policy regularly for the latest information on our privacy practices. Any material changes to this Privacy Policy will be announced via our website or other appropriate means, such as via email or other manners through our Channels, whichever is more practical.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes in the services (or as otherwise indicated at the time of posting).

In all cases, the continued use of the Channels by you after the posting of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

EEA/UK GDPR Annex A

If you are located in the EEA or the UK, this EEA/UK GDPR Annex also applies to you.

1. The controller of your personal data

First Counselor, established at the address stated in Section 2 of this Privacy Policy, is the controller of your personal data for the purposes referred to in Section 4 of this Privacy Policy.

2. Legal basis

We use your personal data only as permitted by law. Our legal bases for processing the personal data described in this Privacy Policy are described in the table below.

Processing purpose	Legal basis
For marketing purposes	Your consent to receive marketing communications. We will offer you a chance to opt out of each subsequent marketing communication.
For the security and maintenance of our Channels	We process your personal data based on our legitimate interests to protect and maintain the security of our day-to-day business activities.
To analyze and improve our Channels and develop new products and services	We process your personal data based on our legitimate interest in getting to know the Channels’ users’ preferences so as to enable us to better personalize our web content, and ultimately, offer an experience that better meets our users’ needs and desires.
To comply with any legal or regulatory requirements	We process your personal data based on compliance with our legal obligations.
To establish, exercise and defend ourselves in the context of legal claims	We rely on our legitimate interests to defend our legal rights or interests in courts.
To disclose your personal data to a prospective or actual purchaser or seller	We rely on our legitimate interests to ensure the sustainability of our business.

3. How to access your personal data and your other rights

You have the following rights in relation to the personal data we hold about you:

Your right of access: If you ask us, we will confirm whether we are processing your personal data and, if necessary, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
Your right to rectification: If the personal data we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified. If you are entitled to rectification and if we have shared your personal data with others, we will let them know about the rectification where possible. If you ask us where it is possible and lawful to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.
Your right to erasure: You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us where it is possible and lawful for us to do so, we will also tell you who we've shared your personal data with so that you can contact them directly.
Your right to restrict processing: You can ask us to “block” or suppress the processing of your personal data in certain circumstances, such as where you contest the accuracy of that personal data or you object to us. If you are entitled to restrictions and if we have shared your personal data with others, we will let them know about the restriction, where it is possible for us to do so. If you ask us where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.
Your right to data portability: You have the right, in certain circumstances, to obtain personal data you have provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
Your right to object: You can ask us to stop processing your personal data, and we will do so, if we are:

relying on our own or someone else's legitimate interests to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or
processing your personal data for direct marketing purposes.

Your right to withdraw consent: If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time.
Your right to lodge a complaint with the supervisory authority: If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, you can report it to the relevant supervisory authority.

Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the data or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations.

4. International data transfers

We may transfer your personal data outside of the EEA and/or UK. Some of these recipients are located in countries in respect of which either the European Commission and/or UK Government (as and where applicable) has issued adequacy decisions, in which case, the recipient’s country is recognized as providing an adequate level of data protection under UK and/or European data protection laws (as applicable) and the transfer is therefore permitted under Article 45 of the GDPR.

Some recipients of your personal data may be located in countries outside the EEA and/or the UK for which the European Commission or UK Government (as and where applicable) has not issued adequacy decisions in respect of the level of data protection in such countries (“Restricted Countries”). For example, Singapore and the United States are Restricted Countries. Where we transfer your personal data to a recipient in a Restricted Country, we will either:

enter into appropriate data transfer agreements based on so-called Standard Contractual Clauses approved from time-to-time under GDPR Art. 46 by the European Commission, the UK Information Commissioner’s Office or UK Government (as and where applicable); or
rely on other appropriate means permitted by the EU/UK GDPR, which establish that such recipients will provide an adequate level of data protection and that appropriate technical and organizational security measures are in place to protect personal data against accidental or unlawful destruction, loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.

You may ask for a copy of such appropriate data transfer agreements by contacting us using the contact details in Section 2 of this Privacy Policy.

When we receive requests for information from law enforcement or regulators, we carefully validate these requests before disclosing any personal data.

PRC Annex B

This PRC Annex supplements the other sections of this Privacy Policy and applies to individuals located in the PRC. In case of any inconsistencies between this PRC Annex and other sections with respect to how we collect, process, share, transfer, and protect personal data of individuals located in PRC, this PRC Annex prevails.

1. Collection and use of your personal data

We collect and use your personal data to provide you with services on our Channels in accordance with what is described under Section 3 “Information We Collect” and Section 4 “How We Use Your Personal Data” of this Privacy Policy.

You need to provide us with your personal data that is necessary for us to provide the basic functions of our services to you on our Channels. For the categories of personal data that are not necessarily needed for the basic functions of our services, if you choose not to provide them to us, you may still use the basic functions of our services, but may not be able to use the specific functions that require such personal data. We will ask for your consent if we process your personal data for new purposes that are not described in this Privacy Policy.

To the extent that we display online advertisements or other marketing messages to you on our Channels, you may choose to opt out of receiving such online advertisements or marketing messages by contacting us using Section 2 of this Privacy Policy. Please note that if you choose to opt out, we may not be able to continue providing you with access to our Channels.

We may also collect and use your personal data without obtaining your consent under the following circumstances:

it is necessary for the conclusion or performance of a contract to which you are a party;
it is necessary for the fulfillment of our statutory obligations;
it is necessary for coping with public health emergencies or for the protection of an individual’s life, health or property; and
your personal data is processed within a reasonable scope in accordance with applicable Chinese laws if such personal data has already been publicly disclosed by yourselves or by other legal sources.

2. Sharing and disclosure of personal data

We share your personal data with entities and for purposes as described under Section 5 “Who We Share Your Personal Data With”.

In the event of a merger, reorganization, dissolution, or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal data, will be transferred to the surviving entity in a merger or the acquiring entity. We will notify you of the name and contact information of the recipient of your personal data. The recipient shall comply with this Privacy Policy when processing your personal data. If the processing methods and purposes of the recipient fall beyond the scope of this Privacy Policy, the recipient shall obtain your new consent.

We will not publicly disclose your personal data unless we have obtained your explicit prior consent or the public disclosure is required by applicable laws, regulations, or legally binding enforcement actions or court orders.

3. International transfer of personal data

For the purposes described under Section 4 “How We Use Your Personal Data” of this Privacy Policy, we may transfer your personal data described under Section 3 “Information We Collect” to our Affiliates, business customers, and service providers located outside of China.

We will rely on a lawful international data transfer mechanism available under applicable Chinese laws to transfer your personal data overseas and adopt necessary measures to ensure that the overseas recipients of your personal data can provide the same level of protection as required under applicable Chinese laws.

4. Security

In case a security incident occurs, we will take remediation actions immediately and notify relevant government authorities and affected users, when required by applicable Chinese law.

5. Your privacy rights