(a) Section 43A, Information Technology Act, 2000;
(b) Rule 4, Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”); and
(c) Rule 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.
1. PURPOSE OF THIS POLICY
1.1 The purpose of this Policy is to ensure that the information pertaining to and provided by You/Users is stored in accordance with the applicable laws. HT protects your personal information and complies with the highest standards of website privacy so that You/Users can safely use UnlearnKids to provide your children/Students a personalized learning experience.
1.2 This Policy explains the following:
(a) What types of information is collected by HT and the purpose behind the collection of such information;
(b) How such information is used by HT;
(c) How such information can be accessed, shared and updated.
2.2 The SPI Rules, in Rule 3, further define “sensitive personal data or information” of a person to mean personal information about that person relating to:
(b) financial information such as bank accounts, credit and debit card details or other payment instrument details,
(c) physical, physiological and mental health condition;
(d) sexual orientation;
(e) medical records and history;
(f) biometric information;
(g) information received by body corporate under lawful contract or otherwise;
3. WHAT INFORMATION IS COLLECTED
3.1 The information You provide to HT depends on the activity you undertake on UnlearnKids. You agree and acknowledge that any and all personal information collected by HT shall be furnished by You in a voluntary manner.
3.2 The Personal Information collected by HT may include your name, gender, age, contact details, mobile number, address, email address, corresponding and relevant details of your children/Students, details of their academic performance in school, and any other information that You agree to furnish.
3.3 Your use of UnlearnKids shall automatically provide us with certain technical non-personal information, including without limitation your IP address, operating system, time-zone, browser details and pixel tags. You consent to Unlearn children’s automatic collection and storage of such information upon your usage of UnlearnKids.
3.4 By signing up your child/Student for UnlearnKids, you represent and warrant that you are a Parent or Teacher who is legally authorized to register his or her child/Student for the Unlearn children’s services, and are also authorized to provide us with the child/Student’s Personal Information, Sensitive Personal Data and Information, or any other information that you provide to us.
4. HOW THE INFORMATION IS USED
4.1 HT shall, to the maximum extent possible, keep Your Personal Information completely confidential in accordance with applicable laws.
4.2 You agree and acknowledge that HT shall collect, store and retain your Personal Information to the limited extent necessary for the performance of HT’s services to You. You further agree that this Personal Information may be used for the following purposes:
(a) To fulfill HT’s obligations in relation to Your requests for our services;
(b) To improve the functionality of UnlearnKids and customize your future browsing experience with UnlearnKids;
(c) To ensure that the content on UnlearnKids is accessible in a user-friendly and efficient manner;
(d) To use with our algorithm in order to determine the learning gaps in the conceptual understanding of the child/Student, to measure learning outcomes objectively, to determine the child/Student’s performance or proficiency in any particular field, and to provide a customized, personalized learning path to each Student/child on the basis of their needs;
(e) To send you communications regarding our services and any change of terms; and
(f) To verify your identity and perform checks necessary to prevent fraud.
4.3 You agree and acknowledge that to fully perform the services requested by You, in certain situations, the collection, transfer, storage and processing of your Personal Information may be entrusted to agents of HT, third parties such as, credit card companies, web hosting providers, communication services, and web analytic providers etc. You consent to our collection, storage and transfer of your personal information with such persons in order to enable Unlearn children’s performance of its services.
5. HOW SUCH INFORMATION CAN BE USED, ACCESSED OR SHARED
5.1 Your Personal Information may be accessed by the employees, agents and representatives of HT on a strictly “need-to-know” basis, and all such persons are bound by confidentiality in their access to such information.
5.2 Any and all information provided by You to HT may be disclosed to relevant authorities or third parties, as and when necessary, when such disclosure is required:
(a) Under the applicable law;
(b) For compliance with any legal process, including without limitation, the order of any court, tribunal, or adjudicatory panel;
(c) To respond to requests from public and government authorities;
(e) To exercise our legal rights or pursue any available legal remedies;
(f) To detect the commission of acts such as fraud, identity theft or other illegal acts;
(g) To prevent any other abuse of UnlearnKids’s services.
6. SECURITY POLICY
6.1 HT states and declares that it takes all steps necessary and commercially reasonable to ensure that your Personal Information provided to us is secure from unauthorized access, disclosure, alteration, destruction or improper use of information. HT encrypts its services and your personal information using secure server software, in accordance with Rule 8 of the SPI Rules.
6.2 Although We do our best to protect your Personal Information, we cannot guarantee the security of your such information transmitted to us. Even under the best of circumstances, the transmission of information via the internet is not completely secure. Any transmission of Personal Information is done at your own risk. In the event of a data breach, we will comply with the guidelines required by the prescribed law.
7.1 HT shall not be liable for any loss or damage caused by reason of any disclosure of any information provided by a User. Further, HT shall also not be responsible for any loss caused due to errors, omissions or inaccuracies with respect to any information that may be disclosed.
9. GRIEVANCE OFFICER
We shall timely address and attempt to rectify any discrepancies and grievances from You pertaining to the Personal Information furnished by You. For this purpose, we have designated a ‘Grievance Officer’ whose details are as follows:
[Name], [Designation], [Address and Contact details].