Privacy policy.

This privacy policy explains how Alpha Step Links Group (“Alpha Step Links”, “we”, “us”) collects and uses personal information when you visit alphasteplinks.com, contact us, book a consultation or use services provided by our divisions: ASL Travels, Alpha Step Links Aviation School, ASL Business Growth (including escrow services), the ASL Foundation and the Alpha Travels platform.

The organisation responsible for your personal information (the “data controller”) is [legal entity name and registration details to be confirmed]. Some divisions may act as separate controllers for their own services; where that applies, they will tell you before you use the service.

• United Kingdom (group headquarters): 2nd Floor, College Road, 17 King Edwards Road, Ruislip HA4 7AE, United Kingdom
• Nigeria (West Africa operations): 7 Chief Tajudeen Odubiyi Street, Ilasamaja, Lagos 102214, Nigeria
• Canada: enquiries are handled through the group desk at [email protected].

Information you give us

• Enquiries: your name, email address, phone number and company (if you provide them), the subject you choose and your message.
• Consultation requests: your goal, whether you are an individual, business or institution, your organisation’s name, your country, your preferred contact method and time of day, and any message you add.
• Updates you subscribe to: your email address, first name (if given) and the topics you choose.
• Communications: emails, calls, WhatsApp messages and notes from meetings or consultations.
• Service information: if you go on to use a division’s services, the information that service needs — for example travel dates and passport details for a booking, qualifications for a training programme, or company and transaction details for business growth or escrow. Each service explains this in its own terms before you commit.

Information collected automatically

Like most websites, our hosting provider records basic technical information when you visit, such as your IP address, browser type, device, the pages you view and the time of your visit. We use this to keep the website working and secure. See cookies and similar technologies for more detail.

How our website forms work

When you send an enquiry, a consultation request or a quote request, the website checks your answers and passes them to an email delivery provider, Resend [processor and its data processing terms to be confirmed], which delivers them as an email to our team inbox and sends you a receipt with your reference. The receipt repeats only the options you chose, not the message you wrote. The website itself does not keep a copy of what you submit. Resend keeps a copy of each message and its delivery records for a limited period [retention period to be confirmed].

When you subscribe to updates, we first email you a link to confirm that the address is yours. Nothing is added to our mailing list until you confirm, and every update includes a link to unsubscribe. Once you confirm, your email address, first name (if you gave it) and topics are added to our mailing list [mailing-list provider to be confirmed].

To protect the forms from spam, the website briefly holds the network (IP) address each submission comes from in temporary memory, so it can limit repeated submissions; it is not saved to a database. If a form can’t be sent, it offers to prepare the same message as an email for you to send from your own email account instead.

We use personal information to:

• reply to your enquiries and route them to the right division;
• arrange, hold and follow up on consultations;
• provide the services you ask us for, and manage our relationship with you;
• send updates and newsletters you have asked to receive;
• operate, secure and improve this website and our services;
• meet our legal, regulatory, tax and accounting obligations.

We do not sell your personal information.

Data protection law, including the UK General Data Protection Regulation (UK GDPR) and the Nigeria Data Protection Act 2023, requires us to have a lawful basis for using personal information. Depending on the situation, we rely on:

• Consent — for example, when you ask to receive updates. You can withdraw consent at any time.
• Contract — to take steps you ask for before entering into an agreement, and to deliver the services we agree to provide.
• Legitimate interests — to respond to enquiries, run and secure our website and improve our services, where this does not override your rights.
• Legal obligation — where we must keep or share information to comply with the law.

The specific basis for each activity will be confirmed as part of the legal review of this policy [to be confirmed].

We share personal information only where it is needed for the purposes described above:

• Within the group: with the Alpha Step Links division best placed to help you — for example, passing a study-abroad enquiry from the group desk to ASL Travels.
• Service providers: with organisations that support us, such as email, hosting, IT and communications providers — including Resend, which delivers the messages sent through our website forms [to be confirmed] — who may only use the information on our instructions [list of processors to be confirmed].
• Partners needed to deliver a service you request: such as airlines, hotels, training or certification bodies, or financial institutions involved in an escrow transaction — only as far as necessary, and as explained in that service’s terms.
• Authorities: where we are required to by law, or to protect the rights, safety or property of our clients, our team or others.

Alpha Step Links operates in the United Kingdom, Nigeria and Canada, so your information may be accessed by our team in more than one of these countries. Some service providers may also process information in other countries.

When information is transferred internationally, we put in place the safeguards that applicable law requires, such as adequacy decisions or approved contractual clauses [transfer mechanisms to be confirmed].

We keep personal information only for as long as we need it for the purpose it was collected, including any legal, accounting or reporting requirements. In general:

• enquiries that do not lead to a service are kept for [retention period to be confirmed];
• client and service records are kept for as long as the law requires — for example, for tax and accounting purposes;
• subscription details are kept until you ask us to stop sending updates.

We use appropriate technical and organisational measures to protect personal information, and limit access to the people who need it. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

Email is not always encrypted. Please avoid sending sensitive documents — such as passport scans or financial details — by ordinary email unless we have agreed a secure way to share them with you.

Depending on where you live and the law that applies, you may have the right to:

• access the personal information we hold about you;
• ask us to correct information that is inaccurate or incomplete;
• ask us to delete information, or to restrict how we use it;
• object to our use of your information, including for direct marketing;
• receive your information in a portable format;
• withdraw consent where we rely on it;
• not be subject to decisions based solely on automated processing that significantly affect you.

To use any of these rights, email [email protected]. We may need to confirm your identity first, and we will respond within the time limits set by applicable law.

Cookies are small files stored on your device. This website does not use advertising cookies. It may use strictly necessary technical storage that is needed for the site to work [cookie audit to be confirmed].

The office maps on our contact page come from Google Maps and only load when you choose “Show map”; until then, the page loads nothing from Google. Once a map is shown, Google receives your IP address and browser details and may set its own cookies, under Google’s privacy policy [Google Maps cookies to be confirmed in the cookie audit].

If we introduce analytics or other non-essential cookies, we will update this policy and ask for your consent where the law requires it. You can also control cookies through your browser settings.

This website is intended for adults. Some of our programmes — for example aviation training for school leavers, or ASL Foundation youth initiatives — involve young people. Where we collect information about someone under 18, we do so with the involvement of a parent, guardian or school where the law requires it.

We will update this policy when our practices or the law change. The date at the top of the page will show when it was last updated [date to be confirmed on publication], and we will highlight significant changes on this page.

If you have a question or concern about how we handle personal information, please contact us first at [email protected] so we can try to put it right. You can also write to us at either office listed in who we are.

You also have the right to complain to a data protection authority:

• United Kingdom: the Information Commissioner’s Office (ICO) — ico.org.uk (opens in a new tab)
• Nigeria: the Nigeria Data Protection Commission (NDPC) — ndpc.gov.ng (opens in a new tab)
• Elsewhere: the data protection authority in the country where you live.