Privacy Policy - Eduplore

This Privacy Policy explains how Eduplore collects, uses, stores, shares, protects and deletes personal data when you use the Eduplore learning management system, the Eduplore website at eduplore.in, the Eduplore mobile application available on Google Play Store (https://play.google.com/store/apps/details?id=com.eduplore.app), and any related services, features, video courses, interactive three dimensional STEM labs, quizzes, assessments, progress analytics tools, teacher dashboards, school dashboards, parent dashboards, support channels and communications that form part of Eduplore, which are together called the Services in this Policy.

Eduplore is an Indian learning platform designed for students in Classes 8, 9 and 10 in Karnataka, and for the parents, guardians, teachers and schools who support those students. The Services offer video courses, interactive three dimensional labs covering subjects such as the Human Body, Heart and ECG, Cell Biology, Periodic Table, Chemistry, Physics, Solar System, Universe and Space, Molecular Biology and Vector Calculus, together with quizzes, practice questions, revision material, progress tracking and learning analytics, in Kannada and in English. Because many users of the Services are children below the age of eighteen years, this Policy gives special attention to children's data, parental consent, school enrolment, and the limits that apply to the collection and use of a child's personal data.

Please read this Policy carefully before you create an account, enrol a student, use a three dimensional lab, watch a video course, attempt a quiz, make a purchase or subscription inside the application, contact support, or otherwise provide personal data to Eduplore. By using the Services, you confirm that you have read and understood this Policy. If you are a parent or legal guardian, please read this Policy together with your child where appropriate, and provide consent on behalf of your child where consent is required. If you are a teacher or a school administrator, please read this Policy before you create student accounts, upload class lists, or share student data with Eduplore.

This Policy is written to comply with Indian law, including the Information Technology Act 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011, which are called the SPDI Rules in this Policy, the Digital Personal Data Protection Act 2023, which is called the DPDP Act in this Policy, the Consumer Protection Act 2019, and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules 2021, which are called the Intermediary Guidelines in this Policy. Where a provision of this Policy refers to a legal requirement, that reference is a summary for information purposes and does not replace the text of the law itself. If any provision of this Policy conflicts with applicable Indian law, applicable law will prevail to the extent of the conflict.

This Policy applies to personal data collected through the website, the mobile application, in person demonstrations, school onboarding, customer support conversations, email, messaging, feedback forms, surveys, payment processing, and any other channel through which you interact with Eduplore. It does not apply to websites, applications or services operated by third parties that are linked from the Services, or to data collected by a school, a teacher, or a parent independently of Eduplore. Those third parties and institutions have their own privacy practices, and you should read their policies before you share personal data with them.

We may update this Policy from time to time. When we do, we will revise the last updated date at the top of this Policy, and where the change is material, we will notify you through the application, by email, or by a notice on the website, as described in Section 22 of this Policy. Continued use of the Services after an update takes effect means that you accept the updated Policy, subject to any consent requirement that applies under the DPDP Act.

1.1. In this Policy, the following words have the following meanings, unless the context requires otherwise.

1.2. "Personal Data" means any data about an individual who is identifiable by or in relation to such data, as defined under the DPDP Act. This includes a name, an email address, a phone number, a photograph, a date of birth, a school name, a class and section, a device identifier, an internet protocol address, and any other information that can identify a person directly or when combined with other information available to Eduplore.

1.3. "Sensitive Personal Data or Information" means the categories described under the SPDI Rules, including passwords, financial information such as bank account, credit card, debit card or other payment instrument details, physical, physiological and mental health condition, sexual orientation, medical records and history, and biometric information. Eduplore does not intentionally collect sensitive personal data about health, sexual orientation or biometric information from students, and you should not provide such information through the Services unless we specifically ask for it for a lawful and stated purpose.

1.4. "Child" means an individual below the age of eighteen years, as defined under the DPDP Act. A large part of the Eduplore user base consists of children in Classes 8, 9 and 10, and the special protections in Section 5 of this Policy apply to them.

1.5. "Parent" and "Legal Guardian" mean a parent of a child or a person who has been legally appointed as the guardian of a child and who is authorised to act on behalf of that child, including for the purpose of giving consent under the DPDP Act.

1.6. "Data Principal" means the individual to whom personal data relates, as defined under the DPDP Act. A student is a Data Principal in relation to his or her own personal data, even where a parent, teacher or school created the account or provided the data. A parent, teacher or school administrator is also a Data Principal in relation to his or her own personal data.

1.7. "Data Fiduciary" means the person who alone or in conjunction with other persons determines the purpose and means of processing personal data, as defined under the DPDP Act. Eduplore acts as a Data Fiduciary in relation to personal data it collects and processes to provide the Services.

1.8. "Data Processor" means a person who processes personal data on behalf of a Data Fiduciary, as defined under the DPDP Act. Eduplore may engage Data Processors, such as hosting providers, analytics providers, payment processors and customer support tool providers, to process personal data on its behalf and under its instructions.

1.19. If there is any difference between the English version of this Policy and a Kannada translation or summary that may be provided for convenience, the English version will prevail for legal purposes, unless applicable law requires otherwise.

2.1. Eduplore is operated by the legal entity named in the Contact Information section. That entity is the Data Fiduciary for personal data processed through the Services, except where this Policy states that Eduplore acts as a Data Processor on behalf of a school.

2.2. The registered address, contact email address, Grievance Officer details and Data Protection Officer details, where applicable, are listed in the Contact Information section. Please use the contact email address given there for privacy requests, and use the Grievance Officer contact details for complaints under the Intermediary Guidelines and the Consumer Protection Act 2019. If you are unsure which contact to use, you may write to the general contact email address and your message will be directed to the correct team.

2.3. Where a school enrols students on Eduplore under a separate written agreement, that agreement may allocate responsibilities between the school and Eduplore. In that case, the school may be a Data Fiduciary for the data it collects directly from students and parents, and Eduplore may act as a Data Processor for data processed on the instructions of the school, or as a joint Data Fiduciary where both parties determine purposes and means together. The allocation in the school agreement will prevail for that enrolment, and this Policy will still explain to students and parents what Eduplore does with the data it receives.

3.1. This Policy covers personal data processed in connection with the Eduplore website at eduplore.in, the Eduplore mobile application on Google Play Store, video courses hosted or linked through the Services, interactive three dimensional labs, quizzes and assessments, progress analytics and reports, teacher and school dashboards, parent dashboards, demo accounts and trial access, in app purchases and subscriptions, customer support, feedback and surveys, marketing communications where you have consented to receive them, and any offline collection connected with school onboarding, demonstrations, workshops or events.

3.2. This Policy covers personal data of students, including children below the age of eighteen years, parents and legal guardians, teachers, school administrators, school owners and staff, visitors to the website, persons who contact Eduplore for a demonstration or a trial, and persons who subscribe to a newsletter or a notification list.

3.3. This Policy does not cover personal data processed by a school on its own systems, by a teacher on a personal device outside the Services, or by a third party service that you access through a link from the Services. For example, if you click a link to a third party video hosting service, a payment gateway, a social media platform, or an external learning resource, that third party will process your data under its own privacy policy. We encourage you to read those policies before you use those services.

4.1. Eduplore collects personal data that is necessary to create and manage accounts, to deliver video courses and three dimensional labs, to assess learning, to provide progress analytics, to process purchases and subscriptions, to provide support, to keep the Services secure, and to comply with legal obligations. We collect only the data that is needed for a stated purpose, and we do not collect data that is irrelevant to the Services.

4.2. Account and identity data. When you create an account, or when a parent, teacher or school creates an account on your behalf, we may collect your full name, your date of birth or age, your gender where you choose to provide it, your class and section, your school name, your medium of instruction, your preferred language, Kannada or English, your email address, your mobile phone number, your username, your password in encrypted form, your profile photograph where you choose to upload one, and your role, whether student, parent, teacher or school administrator. For a demo account, we may collect only a name and a contact detail sufficient to provide the demo.

4.3. Contact data. We collect contact details that you provide when you register, when you contact support, when you request a demo, when you subscribe to updates, or when you provide feedback. This includes your email address, your mobile phone number, and, where you provide it, an alternate contact number or a postal address. We use contact data to send account verification messages, password reset links, service notices, learning reminders, and, where you have consented, marketing and informational messages.

4.4. Student enrolment data. Where a school enrols students, we may receive a class list containing student names, class, section, roll number, date of birth, gender, parent name, parent contact details, and a school assigned student identifier. The school is responsible for ensuring that it has the lawful basis to share that data with Eduplore, including parental consent where required. Eduplore will process enrolment data only to create accounts, to assign courses and labs, and to provide progress reports to the school and to parents.

4.5. Learning data. We collect learning data generated by your use of the Services. This includes the courses you enrol in, the videos you watch and how much of each video you watch, the three dimensional labs you open, the parts and systems you explore inside a lab, the use of features such as rotate, explode, isolate and inspect, the heart rate and ECG settings you select inside the Heart and ECG Lab where that feature is used, the quizzes and assessments you attempt, the questions you answer, the answers you give, the scores you obtain, the time you take, the number of attempts you make, the topics you bookmark, the notes you save, the search terms you enter, and the feedback or rating you give to a lesson. Learning data is used to show you your progress, to recommend the next lesson, to allow teachers and parents to see progress where they are authorised to do so, and to improve the content of the Services.

4.6. Payment and subscription data. When you make an in app purchase or subscribe to a paid plan through Google Play Store or through another payment method offered by Eduplore, we collect data necessary to process and record that transaction. This may include your name, your billing contact details, the plan or product purchased, the purchase date, the subscription start and end date, the transaction identifier provided by the payment processor or by Google Play Store, the payment status, and whether a subscription is active, expired, cancelled or renewed. We do not store full card numbers, full bank account numbers, card verification values, or passwords for payment instruments on Eduplore servers. Payment processing is carried out by a third party payment processor or by Google Play Store, and that processor will collect and handle your payment instrument details under its own privacy policy and under applicable payment security standards.

4.7. Device data and technical data. When you access the Services, we automatically collect device data and technical data. This includes the type of device, the device manufacturer and model, the operating system and its version, the application version, the device language and time zone, the screen resolution, the internet protocol address, the mobile network operator where available, the type of internet connection, and unique device identifiers that are used for security, for keeping you signed in, and for diagnosing technical problems. We also collect crash logs, error logs and performance logs that help us fix faults and improve stability.

4.8. Usage data. We collect usage data about how you use the Services, including the screens you visit, the features you use, the order in which you use them, the duration of your sessions, the frequency of your visits, the links you click inside the Services, and the notifications you open. Usage data helps us understand which lessons and labs are most useful, where students find a topic difficult, and how to improve navigation and content.

4.9. Communications data. When you contact Eduplore by email, by phone, by messaging, through a support form, or in person, we collect the content of your communication, your name, your contact details, the date and time of the communication, and any attachments you send. We keep a record of support conversations so that we can respond to your query, follow up on a complaint, and improve support quality. If you participate in a survey, a feedback form, or a user research interview, we collect your responses and, where you consent, your contact details for follow up.

5.1. Eduplore is designed for students in Classes 8, 9 and 10, and many of those students are below the age of eighteen years. Under the DPDP Act, a Data Fiduciary must not process personal data of a child without the verifiable consent of a parent or legal guardian, and must not undertake tracking or behavioural monitoring of children, or targeted advertising directed at children. Eduplore complies with these requirements, and this Section explains how parental consent is obtained, verified, and managed.

5.2. Age declaration. When an account is created for a person below the age of eighteen years, the person creating the account must declare the age or date of birth of the student, and must confirm whether the account is being created by a parent or legal guardian, by a teacher or school on behalf of the student, or by the student with parental consent. Eduplore may ask for the parent or legal guardian contact details at the time of registration, so that consent can be sought and verified.

5.3. Verifiable parental consent. Where a child account is created, Eduplore will seek verifiable consent from a parent or legal guardian before processing the child's personal data beyond what is strictly necessary to seek that consent and to create the account in a limited form. Verifiable consent may be obtained by sending a verification link, a one time password, or a consent request to the parent's email address or mobile phone number, and asking the parent to confirm that he or she is the parent or legal guardian of the child and that he or she consents to the processing described in this Policy. In a school enrolment, verifiable consent may be obtained through the school, where the school confirms that it has obtained parental consent for the enrolment and for sharing the student's data with Eduplore, and provides Eduplore with a record of that consent. Eduplore may also accept a signed consent form, whether on paper or in electronic form, provided by a parent or by a school on behalf of a parent.

5.4. What parental consent covers. Parental consent covers the processing of the child's personal data for the purposes described in this Policy, including creating and managing the child's account, providing video courses and three dimensional labs, recording learning data and progress, providing quizzes and assessments, showing progress to the parent, to the teacher and to the school where authorised, providing customer support, sending service notices, and processing a purchase or subscription where the parent has authorised it. Parental consent does not cover processing for a purpose that is not described in this Policy, and Eduplore will seek fresh consent if it proposes to use a child's data for a new purpose that is materially different.

5.5. Limits on children's data. Eduplore will not use a child's personal data for targeted advertising, will not undertake tracking or behavioural monitoring of a child for advertising purposes, and will not sell a child's personal data. Eduplore will not collect more data from a child than is necessary to provide the learning services, and will not ask a child to provide data that is not needed, such as a parent's financial information, a home address in detail, or a government identity number, unless that information is specifically required for a lawful purpose and parental consent has been obtained.

5.6. Parent access and control. A parent or legal guardian may, at any time, ask Eduplore what personal data is held about his or her child, ask for a copy of that data, ask for correction of inaccurate data, ask for deletion of the child's account and data where deletion is permitted by law, and withdraw consent for further processing. To make such a request, the parent should contact Eduplore using the contact details in the Contact Information section, and should provide sufficient information to verify that he or she is the parent or legal guardian of the child. Eduplore may ask for a document or other proof of guardianship where that is necessary to protect the child's data from unauthorised access.

5.7. Withdrawal of parental consent. If a parent withdraws consent, Eduplore will stop processing the child's personal data for the purposes covered by that consent, except where processing is required by law, or is necessary to complete a transaction that has already begun, or is necessary to protect the safety of the child or another person. Withdrawal of consent may mean that the child can no longer use certain features of the Services, and Eduplore will explain the consequences at the time the withdrawal is received. Withdrawal of consent does not affect the lawfulness of processing that took place before the withdrawal.

5.8. School enrolment and parental consent. Where a school enrols a student, the school is responsible for informing parents about the enrolment, about the data that will be shared with Eduplore, and about the purposes for which Eduplore will use that data, and for obtaining parental consent where required. Eduplore will provide the school with a summary of this Policy and with a consent form template that the school may use. If a parent contacts Eduplore and states that consent was not obtained, Eduplore will suspend processing of that child's data, contact the school, and resolve the matter before resuming processing, except where processing is required to protect the child or to comply with law.

6.1. Eduplore collects personal data in the following ways. First, data that you provide directly, when you register, when you fill in a profile, when you enrol in a course, when you attempt a quiz, when you save a note or a bookmark, when you contact support, when you provide feedback, when you make a purchase, or when you respond to a survey. Second, data that a parent, teacher or school provides on your behalf, such as a class list, a parent contact detail, or a consent form. Third, data that is collected automatically when you use the Services, such as device data, usage data, and learning data generated by your interactions with videos and three dimensional labs. Fourth, data that is provided by third parties, such as a payment processor that confirms a transaction, Google Play Store that confirms a subscription, or a school that provides enrolment data.

7.1. Under the DPDP Act, Eduplore may process personal data only with the consent of the Data Principal, or in accordance with a legitimate use recognised by the Act. The lawful basis for each purpose is described in this Section and in Section 8.

7.2. Consent. For most purposes, Eduplore relies on your consent, given at the time you create an account, enrol in a course, or use a feature, and confirmed by you when you accept the Terms of Use and this Policy. For a child, consent is given by a parent or legal guardian as described in Section 5. Consent must be free, specific, informed, unconditional and unambiguous, and must be given by a clear affirmative action. You may withdraw consent at any time as described in Section 19, and withdrawal will be as easy as giving consent.

7.3. Performance of a contract. Eduplore processes personal data where that processing is necessary to provide the Services you have requested, such as creating your account, delivering a video course you have enrolled in, recording your quiz score so that you can see your progress, processing a subscription you have purchased, and providing customer support in relation to that subscription. Without that processing, Eduplore could not provide the Services.

7.4. Legal obligation. Eduplore processes personal data where that processing is necessary to comply with a legal obligation, such as maintaining records for tax purposes, responding to a lawful request from a court or a government authority, complying with the Intermediary Guidelines, or handling a grievance under the Consumer Protection Act 2019.

7.5. Legitimate use. Where the DPDP Act recognises a legitimate use, such as processing that is necessary to protect the safety of a person, to prevent fraud, to ensure the security of the Services, or to respond to a medical emergency, Eduplore may process personal data without consent to the extent permitted by the Act, and will limit that processing to what is necessary for that legitimate use.

8.1. Eduplore uses personal data for the purposes listed in this Section. Each purpose is limited to what is necessary to achieve it, and personal data is not used for a purpose that is incompatible with the purpose for which it was collected.

8.2. To provide the Services. We use account data, enrolment data and learning data to create and manage your account, to verify your identity when you sign in, to enrol you in video courses and three dimensional labs, to deliver video content, to load three dimensional models, to record your progress, to save your bookmarks and notes, and to allow you to resume a lesson where you left it.

8.3. To assess learning and to provide feedback. We use quiz and assessment data to calculate scores, to show you correct and incorrect answers, to provide explanations, to track your improvement over time, to identify topics where you may need more practice, and to generate progress reports for you, for your parent, for your teacher and for your school, where each of those persons is authorised to receive that report.

8.4. To provide progress analytics. We use learning data and usage data to generate analytics, such as the number of lessons completed, the average quiz score, the time spent on a subject, the topics mastered, and the topics that need revision. Analytics are shown to the student, to the parent, to the teacher and to the school in accordance with Section 11. Aggregated and anonymised analytics may be used to improve content and to understand how the Services are used across a class, a school, or a region, without identifying an individual student.

8.5. To personalise learning. We use learning data to recommend the next video, the next three dimensional lab, or the next quiz that is relevant to your class, subject and progress. Personalisation is limited to learning recommendations inside the Services, and does not involve targeted advertising. You may turn off personalised recommendations in your account settings, although that may mean you see a general list of lessons rather than a list tailored to your progress.

8.6. To process purchases and subscriptions. We use payment and subscription data to process an in app purchase or a subscription, to confirm that a payment has been received, to activate access to paid content, to manage renewal, cancellation and refund requests, to send receipts and payment confirmations, and to keep records required for tax and accounting purposes.

8.7. To provide customer support. We use contact data and communications data to respond to your queries, to resolve technical problems, to help you recover access to your account, to handle complaints and grievances, and to follow up on feedback. Support staff may access your account data and learning data where that access is necessary to resolve your query, and will limit that access to what is needed.

8.8. To send service notices. We use contact data to send notices that are necessary for the Services, such as account verification messages, password reset links, changes to the Terms of Use or to this Policy, notices about maintenance or downtime, notices about a subscription renewal or expiry, and notices about a security incident that affects your data. Service notices are not marketing messages, and you cannot opt out of receiving notices that are necessary for the security of your account or for the provision of the Services.

8.9. To send learning reminders and updates. Where you have consented, or where a parent has consented on behalf of a child, we use contact data to send reminders about a lesson, a quiz, an assessment, or a new lab or course that is relevant to your class. You may opt out of learning reminders at any time through your account settings or by following the unsubscribe instruction in the message.

8.10. To send marketing communications. Where you have given separate consent to receive marketing communications, we may use your contact data to send information about new courses, new three dimensional labs, new features, offers, or events. Marketing consent is separate from consent to use the Services, and you may withdraw marketing consent at any time without affecting your access to the Services. Eduplore does not send marketing communications to children directly, and any marketing communication relating to a child's account will be sent to the parent.

9.1. Video courses. When you watch a video course, Eduplore records the course, the lesson, the duration watched, the point at which you paused or stopped, whether you completed the lesson, and any bookmark or note you save in relation to that lesson. That information is used to show you your progress, to allow you to resume a lesson, and to provide a progress report to your parent, teacher or school where authorised. Video courses may be streamed or downloaded for offline viewing where that feature is offered, and download data may be recorded to manage storage and to enforce access controls for paid content.

9.2. Three dimensional labs. When you use a three dimensional lab, Eduplore records the lab you opened, the system or part you explored, the use of features such as rotate, explode, isolate, inspect, zoom, and label display, the language selected, Kannada or English, and, in the Heart and ECG Lab, the heart rate setting and ECG display setting you selected. That information is used to show you your progress, to recommend related lessons, and to improve the design of the lab. Eduplore does not use three dimensional lab data to infer a health condition, and the Human Body Atlas and Heart and ECG Lab are educational tools, not medical devices, and are not intended to diagnose, treat or monitor a health condition.

9.3. Quizzes and assessments. When you attempt a quiz or an assessment, Eduplore records the questions presented, the answers you gave, the score obtained, the time taken, the number of attempts, and the date and time of the attempt. That information is used to provide immediate feedback, to calculate your progress, and to generate reports. Where a quiz or assessment is set by a teacher or a school as a formal assessment, the teacher or school may set rules about the number of attempts, the time limit, and whether answers are shown immediately, and Eduplore will apply those rules as instructed by the teacher or school.

9.4. Practice questions and revision. When you use practice questions, revision cards, or other practice features, Eduplore records your attempts and your performance so that it can show you which topics you have mastered and which topics need further practice, and so that it can recommend revision material.

10.1. Progress analytics are a core part of the Services. Eduplore generates analytics from learning data, including lesson completion, quiz scores, time spent, topics mastered, and areas for improvement. Those analytics are presented in a student dashboard, in a parent dashboard, in a teacher dashboard, and in a school dashboard, as described in this Section.

10.2. Student dashboard. A student can see his or her own progress, including courses completed, lessons watched, labs explored, quiz scores, and recommendations for further study. A student cannot see the progress of another student, unless a teacher has set a class leaderboard or a similar feature and the student has been informed that his or her name and score will be visible to classmates. Where a leaderboard is used, only the name and score necessary for that leaderboard will be shown, and a parent may ask for the child's name to be removed from a leaderboard.

10.3. Parent dashboard. A parent or legal guardian who is linked to a child account can see that child's progress, including courses enrolled, lessons completed, quiz scores, time spent, and any teacher feedback. A parent cannot see the progress of another child, and cannot see the personal data of another parent, teacher or student, except for the name of the teacher and the school where that is necessary for the parent to understand the child's learning.

10.4. Teacher dashboard. A teacher who is assigned to a class can see the progress of students in that class, including lesson completion, quiz scores, and time spent, so that the teacher can support learning, identify students who need help, and set further work. A teacher cannot see the progress of students in a class to which he or she is not assigned, and cannot see a student's payment data, password, or private notes, unless the student has shared a note with the teacher.

10.5. School dashboard. A school administrator who is authorised by the school can see aggregated progress for the school, including the number of students enrolled, the number of lessons completed, average quiz scores by class, and usage by subject. A school administrator can also see individual student progress for students enrolled through that school, where that access is necessary for the school to manage learning and to report to parents. A school administrator cannot see a student's payment instrument details or password.

11.1. Individual accounts. An individual student, parent or teacher may create an account directly through the website or the application. The person creating the account is responsible for providing accurate information, for keeping the password confidential, and for not sharing account credentials with another person. If you believe your account has been accessed without your permission, you should change your password immediately and contact Eduplore.

11.2. School accounts. A school may create accounts for its students and teachers, either by providing a class list to Eduplore, by using a school code or a classroom link, or by using a bulk enrolment tool. The school is responsible for ensuring that the data it provides is accurate, that it has obtained parental consent where required, and that it informs parents and students about the enrolment. Eduplore will provide the school with instructions and with a consent template, but the school remains responsible for its own communication with parents.

11.3. Teacher accounts. A teacher account is created by the teacher, or by the school on behalf of the teacher. A teacher must use his or her own account and must not share account credentials with students or with another teacher. A teacher who leaves a school should inform Eduplore or the school administrator so that access can be removed promptly.

11.4. Demo accounts. A demo account may be created for a trial or a demonstration, with limited access and for a limited period. Demo account data may be deleted at the end of the trial period, and demo accounts must not be used to store real student data unless the demo account is converted to a full account with parental consent.

11.5. Account security. You are responsible for keeping your password confidential, for choosing a strong password, for not using the same password that you use for another service, and for signing out when you use a shared device. Eduplore will never ask you for your password by email, by phone, or by messaging, and you should not share your password with anyone, including a person who claims to be from Eduplore.

12.1. Eduplore uses cookies and similar technologies on the website, and uses local storage and software development kit identifiers in the mobile application, to provide the Services, to remember your preferences, to keep you signed in, to measure usage, and to improve performance.

12.2. Strictly necessary technologies. These technologies are essential for the website and application to function, such as keeping you signed in, remembering your language preference, Kannada or English, remembering your progress in a lesson, and protecting the Services from fraud and abuse. Without these technologies, core features such as signing in, resuming a lesson, and completing a quiz may not work. You cannot opt out of strictly necessary technologies, but you can delete cookies from your browser, although that may sign you out and reset your preferences.

12.3. Preference technologies. These technologies remember choices you have made, such as your preferred language, your preferred text size, your notification preferences, and your display settings for a three dimensional lab. Preference technologies improve your experience, but are not essential, and you may clear them at any time.

12.4. Analytics technologies. These technologies collect usage data and learning data in aggregated form, to help Eduplore understand how the Services are used, which lessons are most popular, and where users encounter difficulties. Analytics technologies do not collect your name, your email address, or your payment data, and are used only in aggregated or pseudonymised form. You may opt out of analytics where the application or website provides an opt out control, although that may limit Eduplore's ability to improve the Services for you.

13.1. Eduplore uses third party services to provide parts of the Services, including hosting, content delivery, analytics, crash reporting, customer support, email and messaging delivery, and payment processing. Those third parties act as Data Processors on behalf of Eduplore, and process personal data only on Eduplore's instructions, under a written contract that requires them to protect personal data, to use it only for the purpose for which it was provided, and to delete or return it at the end of the contract.

13.2. Hosting and content delivery. Eduplore uses hosting and content delivery services to store and deliver video courses, three dimensional models, and other content, and to store account data and learning data. Those providers may store data on servers in India or in another country, subject to the transfer rules in Section 17.

13.3. Google Play Store. If you download the Eduplore application from Google Play Store, or make an in app purchase or subscribe through Google Play Store, Google will collect and process personal data in accordance with its own privacy policy, including your Google account information, your device information, and your payment information. Eduplore receives only the information that Google provides to confirm a purchase or a subscription, such as a transaction identifier, a subscription status, and a purchase date, and does not receive your full payment instrument details from Google.

13.4. Payment processors. If you make a payment through a payment gateway or a payment processor, that processor will collect your payment instrument details, your name, and your billing contact details, and will process that data under its own privacy policy and under applicable payment security standards. Eduplore does not store full payment instrument details on its own servers, and receives only a confirmation that a payment was made, together with a transaction identifier and a payment status.

13.5. Analytics and crash reporting. Eduplore may use analytics and crash reporting services to understand usage and to fix faults. Those services may collect device data, usage data, and crash logs, in pseudonymised form, and may store that data on servers in India or in another country. Eduplore does not share your name, email address, or learning data that identifies a child with an analytics provider for advertising purposes.

13.6. Customer support and communication. Eduplore may use customer support tools, email delivery services, and messaging services to respond to your queries, to send service notices, and, where you have consented, to send learning reminders and marketing communications. Those providers will process your contact data and the content of your communications only to deliver those messages on behalf of Eduplore.

13.7. Video hosting. Video courses may be hosted on a third party video hosting service or on Eduplore's own servers. Where a third party hosts video content, that provider may collect device data and usage data, such as the video watched and the duration watched, to deliver the video and to report viewing statistics to Eduplore. That provider's privacy policy will apply to its own collection.

13.8. Links to third party websites. The Services may contain links to third party websites, resources, or learning materials. Clicking such a link will take you to a third party website, and Eduplore is not responsible for the privacy practices of that website. You should read the privacy policy of any third party website before you provide personal data to it.

13.9. No sale of personal data. Eduplore does not sell personal data to third parties, does not share personal data with third parties for their own marketing purposes without your consent, and does not share a child's personal data with a third party for advertising purposes.

14.1. Eduplore shares personal data only as described in this Policy, and only to the extent necessary for a stated purpose. Eduplore does not share personal data with a third party for that third party's own purposes without your consent, except where disclosure is required by law.

14.2. Sharing with parents, teachers and schools. Eduplore shares learning data and progress analytics with a parent or legal guardian, with a teacher assigned to the student's class, and with a school administrator authorised by the school, as described in Section 10. That sharing is necessary to provide the Services and to support learning, and is limited to the data that each recipient needs to see. A parent can see his or her own child's data, a teacher can see data for students in his or her class, and a school administrator can see data for students enrolled through that school.

14.3. Sharing with Data Processors. Eduplore shares personal data with Data Processors described in Section 13, including hosting providers, content delivery providers, analytics providers, crash reporting providers, customer support providers, email and messaging providers, and payment processors. Those Processors process data only on Eduplore's instructions, and are bound by contract to protect it.

14.4. Sharing with a new school. If a student moves to a new school that uses Eduplore, and the parent consents, Eduplore may transfer the student's learning data and progress history to the new school account, so that the student's learning is not lost. If the parent does not consent, Eduplore will not transfer that data, and the student may start with a new account.

14.5. Business transfers. If Eduplore is involved in a merger, acquisition, restructuring, or sale of assets, personal data may be transferred to the successor entity as part of that transaction, subject to the successor being bound by this Policy or by a policy that provides at least the same level of protection, and subject to notice being given to you where required by law. Eduplore will not transfer a child's personal data to a successor for a purpose that is incompatible with the purpose for which it was collected, without obtaining fresh parental consent where required.

14.6. Disclosure required by law. Eduplore may disclose personal data where disclosure is required by applicable Indian law, by a lawful order of a court, tribunal, or government authority, or by a lawful request from law enforcement, where Eduplore is satisfied that the request is lawful, is specific, and is limited to the data that is necessary. Where permitted by law, Eduplore will inform you of such a disclosure, unless informing you would prejudice an investigation or would be prohibited by law.

14.7. Disclosure to protect safety. Eduplore may disclose personal data where disclosure is necessary to protect the safety of a child or another person, to prevent harm, to respond to a medical emergency, or to prevent fraud or other unlawful activity. Any such disclosure will be limited to the data that is necessary for that purpose, and will be recorded by Eduplore.

15.1. Eduplore retains personal data only for as long as it is necessary for the purposes for which it was collected, or for as long as retention is required by applicable law, or for as long as you maintain an account with Eduplore, whichever is longer, subject to the limits in this Section.

15.2. Account data. Account data is retained while your account is active, and for a reasonable period after your account is closed, to allow you to reactivate your account if you request it, to resolve a dispute, to process a refund, and to comply with legal obligations. If you ask for deletion of your account, Eduplore will delete or anonymise your account data within a reasonable time, subject to legal retention requirements described below.

15.3. Learning data. Learning data is retained while your account is active, so that you, your parent, your teacher and your school can see your progress over time. If your account is deleted, your learning data will be deleted or anonymised within a reasonable time, except for aggregated and anonymised analytics that do not identify you, which may be retained for improvement and reporting purposes.

15.4. Payment and subscription data. Payment and subscription records, including transaction identifiers, purchase dates, subscription status, and receipts, are retained for the period required by tax law and accounting law in India, and for the period necessary to handle refunds, disputes and chargebacks. Full payment instrument details are not stored by Eduplore, as described in Section 4.6, and are retained by the payment processor under its own retention policy.

15.5. Communications data. Support correspondence, grievance records, and feedback are retained for the period necessary to resolve the matter, to follow up, and to comply with the Intermediary Guidelines and the Consumer Protection Act 2019, which may require retention of grievance records for a specified period. After that period, communications data will be deleted or anonymised.

15.6. Device data and usage data. Device data, usage data, crash logs and performance logs are retained for a limited period, typically no longer than is necessary to diagnose a fault, to improve performance, and to detect fraud or abuse, after which they are deleted or anonymised. Aggregated usage statistics that do not identify an individual may be retained for longer.

15.7. Consent records. Records of consent, including the date, time, purpose and version of the Policy, are retained for as long as the consent is in force, and for a reasonable period after consent is withdrawn, to demonstrate that consent was obtained and managed in accordance with the DPDP Act.

16.1. Eduplore takes reasonable security practices and procedures to protect personal data, as required by the IT Act 2000 and the SPDI Rules 2011, and as required by the DPDP Act. Those practices include technical measures and organisational measures that are appropriate to the sensitivity of the data, to the risks of processing, and to the size and nature of Eduplore.

16.2. Technical measures. Technical measures include encryption of personal data in transit using secure protocols, encryption of passwords and of sensitive data at rest where appropriate, access controls that limit access to personal data to authorised staff and to authorised Data Processors, authentication controls, including password protection and, where offered, additional verification, firewalls and intrusion detection, regular security updates and patching, and secure backup procedures.

16.3. Organisational measures. Organisational measures include limiting access to personal data to staff who need it to perform their duties, providing training to staff on data protection and on the handling of children's data, requiring staff and Data Processors to agree to confidentiality obligations, maintaining an inventory of processing activities, and reviewing third party providers before engaging them.

16.4. Account security. You are responsible for keeping your password confidential, for choosing a strong password, and for signing out on a shared device. Eduplore may lock an account temporarily after repeated failed sign in attempts, may require you to reset your password if there is a suspicion of unauthorised access, and may send you a notification if a sign in is detected from an unfamiliar device or location.

16.5. Children's data security. Personal data of children is given additional protection, including limiting access to staff who need it, not disclosing it to third parties for advertising, and not displaying it publicly. A child's profile photograph, name, class and school will not be displayed publicly on the website or in a public forum, and will be visible only to the child, to the parent, to the teacher and to the school where authorised.

16.6. No absolute security. While Eduplore takes reasonable measures to protect personal data, no method of transmission over the internet, and no method of electronic storage, is completely secure. Eduplore cannot guarantee absolute security, and you should take care to protect your own account, to use a strong password, and to avoid sharing personal data through insecure channels.

17.1. Eduplore is based in India and primarily stores personal data in India. Some third party services used by Eduplore, such as hosting providers, content delivery providers, analytics providers, and payment processors, may store or process personal data on servers outside India.

17.2. Where personal data is transferred outside India, Eduplore will ensure that the transfer complies with the DPDP Act and with any rules or notifications issued under it, including any restriction on transfer to a country or territory notified by the Central Government. Eduplore will ensure that the recipient is bound by contractual obligations to protect personal data to a standard that is at least equivalent to the protection required by Indian law, and that the transfer is limited to what is necessary for the purpose for which the data was collected.

17.3. You consent to the transfer of your personal data outside India as described in this Section, where that transfer is necessary to provide the Services, for example to deliver video content through a content delivery network, to process a payment, or to provide customer support. If you do not consent to such a transfer, you should not use the Services, and you should contact Eduplore to discuss alternatives, although Eduplore may not be able to provide the Services without using those third party services.

18.1. Under the DPDP Act, you, as a Data Principal, have the rights described in this Section. A parent or legal guardian may exercise those rights on behalf of a child, as described in Section 5. A teacher or school administrator may exercise those rights in relation to his or her own personal data.

18.2. Right to access. You have the right to obtain a summary of the personal data that Eduplore processes about you, and to obtain a copy of that data, in a readable form. You also have the right to know the purposes for which your data is processed, the categories of data processed, and the third parties with whom your data has been shared.

18.3. Right to correction. You have the right to ask Eduplore to correct inaccurate personal data, to complete incomplete personal data, and to update personal data that is out of date, such as a change in your name, class, school, email address or phone number. You should keep your account information up to date, and you can correct many details yourself through your account settings.

18.4. Right to erasure. You have the right to ask Eduplore to erase your personal data, and to delete your account, where erasure is permitted by law. Erasure will be carried out within a reasonable time, subject to legal retention requirements described in Section 15, and subject to the need to retain data to complete a transaction, to resolve a dispute, or to comply with a legal obligation. Where erasure is not possible because of a legal requirement, Eduplore will explain the reason and will restrict processing of that data to what is required by law.

18.5. Right to withdraw consent. You have the right to withdraw consent at any time, where processing is based on consent. Withdrawal of consent will stop further processing for that purpose, and will be as easy as giving consent. Withdrawal does not affect the lawfulness of processing that took place before withdrawal, and may mean that you can no longer use certain features of the Services, as described in Section 5.7 for children and in Section 19.4 for adults.

18.6. Right to grievance redressal. You have the right to have your grievances redressed in a timely manner, as described in Section 20. You may raise a grievance with the Grievance Officer, and if you are not satisfied with the response, you may approach the Data Protection Board of India or another competent authority, as described in Section 20.5.

18.7. Right to nominate. Under the DPDP Act, you have the right to nominate another person to exercise your rights in the event of your death or incapacity, in accordance with the procedure prescribed under the Act and any rules made under it. If you wish to make such a nomination, please contact Eduplore using the details in the Contact Information section, and Eduplore will record your nomination.

19.1. How to make a request. To exercise a right described in Section 18, you should contact Eduplore using the contact email address in the Contact Information section, or through the in app support or privacy request form where that form is available. Your request should state your full name, your account email address or phone number, your role, whether student, parent, teacher or school administrator, the right you wish to exercise, and the data or account to which the request relates. If you are a parent making a request on behalf of a child, you should state the child's full name, class and school, and your relationship to the child.

19.2. Verification. Before Eduplore responds to a request, it may ask you to verify your identity, to ensure that personal data is not disclosed to an unauthorised person. Verification may include asking you to confirm your registered email address or phone number, to provide a one time password sent to that contact, or to provide proof of guardianship where you are acting on behalf of a child. Eduplore will not ask you for your password, and will not ask you to provide sensitive personal data that is not necessary to verify your identity.

19.3. Response time. Eduplore aims to acknowledge your request promptly, and to respond within the time limit required by applicable law. Where the DPDP Act or any rules made under it prescribe a specific time limit, Eduplore will comply with that limit. Where a request is complex, or where Eduplore needs to consult a school or a third party, Eduplore may need additional time, and will inform you of the reason for the delay and of the expected date of response.

19.4. Consequences of withdrawal or erasure. If you withdraw consent or ask for erasure, Eduplore will explain the consequences, including whether you will lose access to paid content, to progress history, or to a feature that depends on that data. If you have an active subscription, withdrawal or erasure may mean that the subscription cannot be used, and Eduplore will explain any refund position in accordance with the Terms of Use and the refund policy of Google Play Store or of the payment processor, as applicable.

19.5. Refusal of a request. Eduplore may refuse a request, or may limit its response, where the request is manifestly unfounded or excessive, where disclosure would reveal personal data of another person, where disclosure would prejudice an investigation, or where retention is required by law. Where Eduplore refuses a request, it will explain the reason, and will inform you of your right to raise a grievance as described in Section 20.

20.1. Grievance Officer. In accordance with the Intermediary Guidelines 2021 and the Consumer Protection Act 2019, Eduplore has appointed a Grievance Officer, whose name and contact details are listed in the Contact Information section. The Grievance Officer is responsible for receiving and addressing complaints and grievances relating to the Services, including complaints about personal data, about content, about a purchase or subscription, or about any other matter relating to the Services.

20.2. How to raise a grievance. You may raise a grievance by writing to the Grievance Officer at the email address given in the Contact Information section, or by using the grievance form in the application or on the website where that form is available. Your grievance should state your full name, your contact details, your account details where relevant, a clear description of the grievance, the date on which the issue arose, and any supporting information or documents. Please do not include your password or full payment instrument details in a grievance.

20.3. Acknowledgement and resolution. Eduplore will acknowledge a grievance within forty eight hours of receipt, and will endeavour to resolve it within fifteen days, or within such other period as may be required by applicable law. Where a grievance is complex, Eduplore will inform you of the progress and of the expected date of resolution. The Grievance Officer will keep a record of grievances received, of the action taken, and of the outcome, in accordance with the Intermediary Guidelines.

20.4. Data Protection Officer. If Eduplore appoints a Data Protection Officer under the DPDP Act, that officer's name and contact details will be listed in the Contact Information section. The Data Protection Officer will be responsible for overseeing compliance with the DPDP Act, for advising on data protection matters, and for acting as a point of contact for Data Principals and for the Data Protection Board of India. If no Data Protection Officer is appointed, the Grievance Officer will act as the point of contact for privacy matters, or you may contact Eduplore using the general privacy contact email address.

21.1. Eduplore may update this Policy from time to time, to reflect changes in the Services, in the law, or in Eduplore's data practices. When Eduplore updates this Policy, it will revise the last updated date, and will publish the updated Policy on the website and inside the application.

21.2. Material changes. Where a change is material, for example a change in the purposes for which personal data is used, a change in the categories of data collected, a change in the third parties with whom data is shared, or a change in your rights, Eduplore will notify you before the change takes effect, by email, by an in app notice, or by a notice on the website, and will, where required by the DPDP Act, seek fresh consent. A material change will not apply to a child's data without fresh parental consent where that is required.

21.3. Non material changes. Where a change is not material, for example a correction of a typographical error, a clarification of wording, or an update to contact details, Eduplore may update the Policy without prior notice, although the updated Policy will still be published on the website and in the application.

21.4. Continued use. Continued use of the Services after an updated Policy takes effect means that you accept the updated Policy, subject to any consent requirement that applies under the DPDP Act. If you do not accept an updated Policy, you should stop using the Services and contact Eduplore to discuss deletion of your account, as described in Section 19.

22.1. This Policy is governed by the laws of India, including the Information Technology Act 2000, the SPDI Rules 2011, the Digital Personal Data Protection Act 2023, the Consumer Protection Act 2019, and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules 2021.

22.2. Any dispute arising out of or in connection with this Policy, or with the processing of personal data by Eduplore, will be subject to the jurisdiction of the courts in Karnataka, India, unless a different jurisdiction is required by applicable law, or unless the parties agree otherwise in writing. This does not limit your right to file a complaint with the Data Protection Board of India, or to approach a consumer forum under the Consumer Protection Act 2019.

22.3. If any provision of this Policy is found to be invalid, illegal or unenforceable by a court or by a competent authority, the remaining provisions will continue in full force and effect, and the invalid provision will be read as narrowly as necessary to make it valid and enforceable, or will be severed if it cannot be so read.

22.4. This Policy, together with the Terms of Use, forms the basis on which Eduplore processes your personal data. Where there is a conflict between this Policy and the Terms of Use on a data protection matter, this Policy will prevail for that matter.

If you have any question about this Privacy Policy, about your personal data, or about how to exercise a right, please contact us using the details below.

• Legal entity name: Eduplore
• Registered address: 1st Floor, SLA Inn, 7, Hootagalli, Hutagalli, Mysuru, Karnataka 570018
• Contact email for privacy requests: venkatesh@eduplore.in
• Grievance Officer Name: Venkatesh C
• Grievance Officer email: venkatesh@eduplore.in
• Grievance Officer phone: +91 94802 88911
• Data Protection Officer Name, if appointed: Revant
• Data Protection Officer email: revanth@eduplore.in
• Website: eduplore.in

Please include your full name, your account email address or phone number, and a clear description of your query or request, so that we can respond promptly.