Privacy Policy

Oxford Comma Advisory Ltd

Last updated: 18 October 2026

1. Who We Are

Oxford Comma Advisory Ltd, trading as Oxford Comma (“Oxford Comma”, “we”, “us” or “our”), is an educational consultancy providing advice and support relating to international education, school and university admissions, educational programmes and associated services.

Our website address is https://oxfordcomma.uk/.

Oxford Comma Advisory Ltd is generally the data controller responsible for personal information collected directly through our website, enquiries, consultations and customer relationships, under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Contact information

Oxford Comma Advisory Ltd
Email: hello@oxfordcomma.uk
Website: https://oxfordcomma.uk/
Registered office: [Insert registered office address]
Company registration number: [Insert company number]

This Privacy Policy explains how we collect, use, store, share and protect personal information, and how individuals can exercise their data protection rights.

It applies to visitors to our website, prospective customers, existing clients, students, parents and guardians, and individuals who communicate with or receive services from Oxford Comma.

2. Personal Information We Collect

The information we collect depends on your relationship with Oxford Comma and the services you request.

2.1 Identity and Contact Information

We may collect names, email addresses, telephone numbers, countries of residence, postal addresses and other information necessary to communicate with customers.

Where an enquiry concerns a child or young person, we may also collect contact information relating to their parent or legal guardian.

2.2 Educational and Application Information

Where relevant to our services, we may collect:

• Current school, college or university.

• Educational background, qualifications and academic results.

• Intended study destination and preferred institutions.

• Proposed courses, educational programmes and study pathways.

• Admissions requirements and application documentation.

• Educational interests, preferences and objectives.

• Anticipated education budgets and funding information.

• Information needed to coordinate placements, accommodation or related support.

We seek to collect only the information reasonably necessary to respond to your enquiry or provide an agreed service.

2.3 Appointments, Enquiries and Communications

When you contact Oxford Comma or book a consultation, we may collect:

• Your identity and contact information.

• Appointment dates, times and meeting details.

• Answers provided through booking questionnaires.

• Questions, preferences and educational requirements.

• Email, telephone, website and social media correspondence.

• Consultation notes and agreed follow-up actions.

• Relevant records of enquiries and services requested.

2.4 Financial Information

When you purchase services, we may process billing information, invoices, payment records, transaction references and information needed to administer payments, refunds and contractual arrangements.

Payments may be processed through third-party payment providers. We do not necessarily receive or store full payment-card details.

2.5 Technical and Website Information

When you use our website, certain technical information may be collected, including IP addresses, browser and device details, security logs and information needed for essential website functions.

Our approach to cookies and similar technologies is described in Section 10.

3. How We Collect Information

We may receive personal information:

• Directly from you through online forms, consultations, messages, telephone calls, documents or correspondence.

• From parents or guardians acting on behalf of children or young people.

• Through appointment and customer management systems.

• Through social media and messaging platforms, including Instagram.

• From educational institutions, programme providers and authorised service partners, where relevant.

• Through essential website functions and security systems.

Where we receive information from third parties, we process it only where there is an appropriate lawful basis.

4. How and Why We Use Personal Information

Oxford Comma processes personal information for legitimate business, contractual and legal purposes.

The purposes and typical lawful bases are described below.

Purpose	Typical lawful basis
Responding to enquiries and arranging consultations	Legitimate interests or steps requested before entering a contract
Providing educational consultancy and related services	Performance of a contract
Coordinating educational applications and placements	Contract or legitimate interests, depending on the circumstances
Maintaining customer and enquiry records	Legitimate interests or contract
Managing appointments and service communications	Contract or legitimate interests
Processing payments and maintaining financial records	Contract or legal obligation
Maintaining website and information security	Legitimate interests or legal obligation
Improving internal operations and service quality	Legitimate interests
Sending optional marketing communications	Consent or another lawful basis where specifically permitted by law
Meeting applicable legal and regulatory requirements	Legal obligation

Our legitimate interests include operating an effective educational consultancy, responding to prospective customers, managing relationships, coordinating services and protecting our systems.

Where we rely on legitimate interests, we consider whether the processing is necessary and proportionate and whether individuals’ rights outweigh those interests.

Where consent is required, we request it separately and provide an appropriate means of withdrawal.

We do not treat consent to receive a consultation as consent to receive marketing.

Where special-category information is necessary for a particular service, we identify both an appropriate lawful basis and an additional condition for processing that information.

5. Appointments, Booking Forms and Customer Relationship Management

Oxford Comma uses digital systems to manage enquiries, appointments, consultations, customer relationships and service delivery.

These systems may include our internal Compass platform, website booking services, customer management tools and associated communications systems.

Information submitted through booking forms may be used to:

• Confirm and administer your appointment.

• Send meeting invitations, reminders and joining instructions.

• Prepare advisers for consultations.

• Understand your educational requirements.

• Respond to your enquiry.

• Coordinate agreed follow-up actions.

• Maintain appropriate customer and service records.

An appointment may be associated with an existing customer record or used to establish a new enquiry record.

Access to personal information is restricted according to staff roles and responsibilities.

Booking an appointment does not automatically subscribe you to marketing communications.

6. Children and Young People

Some Oxford Comma services relate to children and young people, including school placements, educational programmes and associated support.

We may receive information about a child from their parent, legal guardian, school or another appropriately authorised person.

This may include identity information, educational background, academic records, intended placements and information relevant to the child’s educational requirements.

We recognise the importance of protecting children’s privacy.

Where appropriate, we:

• Involve parents or legal guardians in enquiries and service arrangements.

• Limit information collection to what is reasonably necessary.

• Restrict access to authorised staff and relevant service providers.

• Apply appropriate confidentiality and security safeguards.

• Consider the child’s age, interests and data protection rights.

Where health information, safeguarding information or other sensitive personal information is necessary, we apply additional protections and process it only where the applicable legal conditions are satisfied.

We do not knowingly use children’s personal information for unrelated marketing activities.

7. Marketing Communications

We may provide information about Oxford Comma’s educational services, opportunities, articles, events and promotional offers where permitted by applicable law.

Where marketing consent is required, it is requested separately from the information needed to arrange consultations or deliver contracted services.

Marketing consent is optional and is not a condition of accessing ordinary consultancy services.

You may unsubscribe from marketing communications using the unsubscribe facility provided in a message, where available, or by contacting hello@oxfordcomma.uk.

Withdrawal of marketing consent does not prevent essential communications relating to appointments, existing contracts or legal obligations.

We may retain limited information about marketing preferences and opt-out requests to ensure those choices are respected.

8. Website Comments

Where commenting is enabled on our website, we collect the information submitted through the comment form, together with the visitor’s IP address and browser user-agent information, to assist with spam detection.

An anonymised string derived from an email address (a hash) may be provided to the Gravatar service to determine whether the visitor uses it.

Gravatar’s privacy policy is available at https://automattic.com/privacy/.

After a comment has been approved, the visitor’s profile picture may be publicly visible alongside their comment.

9. Media Uploads

If you upload images to our website, please avoid including embedded location information, such as EXIF GPS metadata, unless necessary.

Visitors may be able to download publicly accessible images and extract embedded location information.

Documents or images submitted confidentially in connection with our consultancy services are handled according to their intended purpose and are not automatically made publicly available.

10. Cookies and Similar Technologies

Oxford Comma is committed to minimising the use of cookies and similar technologies.

Our policy is to use only strictly necessary cookies required to operate our website securely and provide the functionality requested by visitors.

These may include cookies used for:

• Maintaining secure sessions and user authentication.

• Protecting website forms and preventing security threats.

• Supporting essential website and appointment booking functions.

• Remembering settings necessary to provide a service requested by the visitor.

10.1 WordPress Cookies

Where applicable, WordPress may use cookies for website comments, authentication and account functionality.

If you leave a comment, you may choose to save your name, email address and website in cookies. These normally last for one year.

When visiting the website login page, a temporary cookie may be set to determine whether your browser accepts cookies. It contains no personal information and is normally discarded when the browser closes.

When logging in, WordPress may set authentication and display-preference cookies.

Login cookies typically last two days, display-preference cookies may last one year, and selecting “Remember Me” may extend the login session to two weeks.

Logging out removes the relevant authentication cookies.

Where an authorised user edits or publishes an article, WordPress may store a temporary cookie identifying the relevant post. This normally expires after one day.

10.2 Advertising and Tracking

Oxford Comma’s intended website configuration does not use advertising, behavioural tracking or optional analytics cookies.

We do not intentionally use cookies to build advertising profiles of website visitors.

We periodically review our website configuration and third-party integrations to minimise unnecessary tracking.

10.3 Cookie Consent and Browser Settings

Under applicable UK rules, cookies that are strictly necessary to provide a service requested by the visitor generally do not require consent.

We nevertheless provide information about their use in this Privacy Policy.

You can restrict, delete or manage cookies through your browser settings. Disabling essential cookies may affect the operation of certain website features.

If our use of cookies changes materially, we will update this notice and implement additional consent controls where legally required.

11. Embedded Content from Other Websites

Some website pages may contain embedded content, including videos, images, maps or articles from third-party websites.

Embedded content may behave as though you had visited the external website directly.

Third-party providers may collect technical information, use cookies or monitor interactions with their content, depending on their systems and privacy practices.

Where consent is required for non-essential embedded technologies, we will seek it before those technologies are activated.

We encourage visitors to review the privacy policies of relevant third-party providers.

12. Who We Share Information With

We do not sell personal information to advertisers.

We may share relevant information with organisations involved in providing, administering or supporting our services, where necessary and lawful.

These may include:

• Schools, colleges, universities and educational programme providers.

• Accommodation and other organisations involved in agreed educational arrangements.

• Authorised consultants and service-delivery partners.

• Website hosting, cloud infrastructure and IT providers.

• Email, messaging, booking and video-conferencing providers.

• Payment processors and financial institutions.

• Accountants, legal advisers and other professional service providers.

• Regulators and public authorities where legally required.

We seek to share only information reasonably necessary for the relevant purpose and to apply appropriate confidentiality, contractual and security protections.

Some educational institutions and third-party organisations act as independent data controllers and may provide their own privacy information.

If you request a password reset through our website, your IP address may be included in the reset email.

13. International Transfers of Personal Information

Because Oxford Comma operates in international education, some personal information may need to be transferred or made accessible outside the United Kingdom.

Such transfers may arise when communicating with overseas educational institutions, coordinating placements or using internationally operated technology and communications services.

Where international transfers are subject to UK data protection restrictions, we use an appropriate lawful transfer mechanism, such as recognised adequacy arrangements or approved contractual safeguards, where required.

You may contact us at hello@oxfordcomma.uk for further information about relevant international transfers and safeguards.

14. How Long We Retain Information

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, including relevant legal, accounting, contractual and safeguarding requirements.

Retention arrangements vary according to the type of information.

14.1 Website Comments

Where comments are enabled, approved comments and their metadata may be retained indefinitely to assist with moderation and recognition of subsequent comments, subject to applicable data protection rights.

14.2 Website Accounts

Where individuals have registered website accounts, we retain relevant account information while the account is active and for any additional period required for legitimate administration or legal obligations.

Users may be able to view, edit or delete certain profile information, subject to system functionality and lawful retention requirements.

Authorised website administrators may also access and manage account information.

14.3 Enquiries and Prospective Customers

Enquiry information and relevant correspondence are retained for a period appropriate to responding to the enquiry, managing follow-up and maintaining necessary records.

Dormant records are reviewed and deleted or anonymised when no longer required.

14.4 Customer and Educational Records

Information relating to clients, educational applications, appointments and service delivery is retained throughout the relevant engagement and for an appropriate period afterwards, taking account of contractual requirements, potential disputes and legal obligations.

14.5 Financial Records

Invoices, accounting records and related financial information are retained for the periods required by applicable tax and accounting legislation.

14.6 Marketing Preferences and Security Records

Marketing preferences and suppression records may be retained as necessary to respect opt-out requests.

Technical and security logs are retained for limited periods appropriate to operational and security requirements.

Retention periods are determined according to the nature of the information, the purpose of processing, applicable legal obligations and the need to establish, exercise or defend legal claims.

15. Information Security

Oxford Comma uses appropriate technical and organisational measures designed to protect personal information against unauthorised access, loss, alteration, misuse and disclosure.

Measures may include:

• Role-based access restrictions.

• Secure authentication.

• Appropriate encryption and secure communication methods.

• Access controls for customer and educational records.

• Security monitoring and incident-response procedures.

• Confidentiality requirements for staff and service providers.

• Periodic reviews of relevant security practices.

We review these measures as our services and systems evolve.

No internet-based system can be guaranteed completely secure, but we take reasonable steps to reduce foreseeable risks.

16. Artificial Intelligence and Human Decision-Making

Oxford Comma may use artificial intelligence (AI) and automated software tools to support the administration and delivery of our services.

These tools may assist our staff with:

• Analysing and organising customer enquiries.

• Categorising information and identifying relevant requirements.

• Preparing draft communications and recommendations.

• Supporting educational research and analysis.

• Identifying potential follow-up actions.

• Improving operational efficiency and consistency.

AI supports our staff; it does not replace their professional judgement.

Decisions concerning a customer’s educational options, applications, placements, eligibility for services or other consequential matters remain subject to meaningful human review and oversight.

Our staff are responsible for final decisions and may accept, modify or reject AI-generated recommendations.

We do not use AI to make solely automated decisions about customers that produce legal or similarly significant effects without meaningful human involvement.

Where AI-enabled services process personal information, we apply relevant confidentiality, data protection and access-control requirements.

Customers may contact hello@oxfordcomma.uk with questions about AI-assisted processing of their information.

17. Your Data Protection Rights

Under applicable data protection legislation, you may have the right to:

• Access: Request a copy of personal information held about you.

• Rectification: Request correction of inaccurate or incomplete information.

• Erasure: Request deletion of information in certain circumstances.

• Restriction: Request that certain processing be restricted.

• Objection: Object to processing based on legitimate interests and to direct marketing.

• Data portability: Request transfer of eligible information where the legal conditions apply.

• Withdrawal of consent: Withdraw consent where consent is the lawful basis for processing.

• Automated decision-making protections: Exercise applicable rights relating to qualifying solely automated decisions.

These rights may be subject to legal conditions and exceptions.

To exercise your rights, contact:

hello@oxfordcomma.uk

We may request information reasonably necessary to verify your identity before responding.

We will respond within the time limits required by applicable law.

18. Complaints

If you have concerns about how Oxford Comma handles your personal information, please contact us first at hello@oxfordcomma.uk.

We will review your concern and respond appropriately.

You also have the right to complain to the Information Commissioner’s Office (ICO), the UK’s independent data protection regulator.

ICO website: https://ico.org.uk/

Depending on your location and circumstances, you may also have the right to contact another relevant data protection supervisory authority.

19. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our services, technology, business operations or legal obligations.

The latest version will be published at:

https://oxfordcomma.uk/privacy-policy/

Where significant changes affect how we use personal information, we will take appropriate steps to inform affected individuals where required.

20. Contact Us

For questions about this Privacy Policy, requests concerning personal information or other data protection enquiries, please contact:

Oxford Comma Advisory Ltd

Email: hello@oxfordcomma.uk
Website: https://oxfordcomma.uk/