Privacy Policy

 Educational Initiatives Private Limited (hereinafter to be referred as “Company” or “we” or “our”  or “us”), a company duly incorporated under the provisions of the Companies Act, 1956, operates  various internet and mobile application based platforms, namely, www.mindspark.in , www.ei.study and www.assettalentsearch.com etc. and all the microsites thereof and  applications associated thereto (collectively the “Platforms”).

By accessing the Platforms, or by seeking to avail of certain Products and Services (as defined in  the Terms and Conditions), or by otherwise providing or accessing any information through the  Platforms, you are required to agree to our Terms and Conditions (“Terms”) and acknowledge  that your information will be stored, used and accessed in accordance with this Privacy Policy.  For the purposes of this privacy policy, unless defined hereunder, all capitalized terms shall have  the meaning ascribed to them under the Terms of the Use.

This Privacy Policy (“Privacy Policy”) is published in compliance with inter alia:

1. Section 43A of the Information Technology Act, 2000 (“IT Act”);
2. Regulation 4 of the Information Technology (Reasonable Security Practices and  Procedures and Sensitive Personal Information) Rules, 2011 (“SPDI Rules”); and 3. Regulation  3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011 (“Intermediaries  Guidelines”).

Our Privacy Policy explains: (a) what information we receive from you; (b) how we collect and use  that information; (c) how you can provide information selectively, access and update the  information; and (d) how we process, share and protect your information.

This Privacy policy is applicable to all Users accessing or using our Platforms.

1. GENERAL 

BY ACCESSING OR USING OUR PLATFORMS OR BY OTHERWISE GIVING US YOUR  INFORMATION, YOU CONFIRM THAT YOU HAVE THE CAPACITY TO ENTER INTO A LEGALLY  BINDING CONTRACT UNDER INDIAN LAW, IN PARTICULAR, THE INDIAN CONTRACT ACT, 1872,  AND HAVE READ,

UNDERSTOOD AND AGREED TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY  POLICY AND AGREE TO BE BOUND BY THE PRIVACY POLICY.

IN THE EVENT THAT YOU ARE A MINOR UTILIZING THE PLATFORMS, IT IS ASSUMED THAT YOU  HAVE OBTAINED THE CONSENT OF YOUR LEGAL GUARDIAN OR PARENTS AND SUCH USE IS  MADE AVAILABLE BY YOUR LEGAL GUARDIAN OR PARENTS. WE WILL NOT BE RESPONSIBLE  FOR ANY CONSEQUENCE THAT ARISES AS A RESULT OF MISUSE OF ANY KIND OF OUR  PLATFORMS OR ANY OF OUR SERVICES OR PRODUCTS THAT MAY OCCUR BY VIRTUE OF ANY  PERSON INCLUDING A MINOR REGISTERING FOR THE SERVICES/PRODUCTS PROVIDED. BY  USING THE SERVICES OR PRODUCTS, YOU WARRANT THAT ALL THE DATA PROVIDED BY YOU  IS ACCURATE AND COMPLETE AND THAT STUDENT USING THE PLATFORMS HAS OBTAINED  THE CONSENT OF PARENT/LEGAL GUARDIAN (IN CASE OF MINORS).

YOU HEREBY CONSENT TO OUR COLLECTION, USE, SHARING, AND DISCLOSURE OF YOUR  INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. WE RESERVE THE RIGHT TO CHANGE,  MODIFY, ADD OR DELETE PORTIONS OF THE TERMS OF THIS PRIVACY POLICY, AT OUR SOLE  DISCRETION, AT ANY TIME, AND ANY CONTINUED USE OF THE PLATFORMS BY YOU OR USE  OF THE PLATFORMS, FOLLOWING ANY SUCH AMENDMENTS TO THE PRIVACY POLICY, WILL  BE DEEMED AS AN IMPLICIT ACCEPTANCE OF THE PRIVACY POLICY IN ITS AMENDED FORM. IF  YOU ARE ACCESSING OR USING THE PLATFORMS FROM AN OVERSEAS LOCATION, YOU DO SO  AT YOUR OWN RISK, AND SHALL BE SOLELY LIABLE FOR COMPLIANCE WITH ANY APPLICABLE  LOCAL LAWS.

IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AT ANY TIME, IN PART OR AS A WHOLE,  WRITE TO US ON time2timeeducation@gmail.com DO NOT USE THE PLATFORMS OR SERVICES  PROVIDED ON THE PLATFORMS, OR PROVIDE US WITH ANY OF YOUR INFORMATION.

2. INFORMATION COLLECTED AND MEANS OF COLLECTION 

We collect the following information about you:

1. Registration Information: When you register to use our Platform, we collect your  registration details including name, age, gender, phone number and email address, details  of your educational institution and your educational details.

2. Order Information: We collect information necessary for us to process your order or  subscription on the Platform including, Services and/or Products requested by you, your  postal address and specific payment information such as payment transaction details.

(Registration Information and Order Information to be collectively referred to as  “Personal Information”)

3. Financial Information: We collect information in relation to your financial details including  bank account information, payment card details such as credit card / debit card details,  other payment instrument details or any other information required to complete the  payment process on the Platforms.

(Financial Information is referred to as “SPDI”)

The IT Act and the SPDI Rules regulate the collection, usage, retention and disclosure of  personal information, which is defined under the SPDI Rules as any information that  relates to a natural person, which, either directly or indirectly, in combination with other  information available or likely to be available to a body corporate, is capable of identifying  such person. The SPDI Rules further define sensitive personal data or information of a  person as personal information about that person relating to:

1. passwords;
2. financial information such as bank accounts, credit and debit card details or other  payment instrument details;
3. physical, physiological and mental health condition;
4. sexual orientation;
5. medical records and history;
6. biometric information;
7. any detail relating to the above clauses as provided to the body corporate for providing  services; and
8. any of the information received under above clauses by body corporate for processing,  stored or processed under lawful contract or otherwise.

You provide all information to us voluntarily. Collection, use and disclosure of Personal  Information and SPDI requires your express consent. You are providing us with your  consent to our use, collection, and disclosure of the Personal Information and SPDI. You  may choose to not provide us with Personal Information and SPDI, but in the event that  you do so, we will be unable to provide you access to our Platforms or purchase  Products or provide Services through our Platforms.

3. USE OF INFORMATION 

We use your information for the following purposes:

1. To manage, operate and improve the Platforms in order to foster a positive User  experience and to improve our business as a whole;
2. To process and deliver Products and Services including collection of payments on our  behalf;
3. To collect the payments from you;
4. To enable your access to our Platforms to purchase Products and provide you Services;  5. Analysing data, tracking trends, building algorithms, creating databases,  recommendations engines, etc.;
5. For any research or statistical purposes or to generally improve learning experience;
6. For non-targeting reasons such as frequency capping, compliance, billing, ad reporting or  delivery, market research or Product and Service development purposes;  8. To comply with applicable law;
7. To conduct audits and quality assessment procedures;

10.To analyse the use of our resources, troubleshooting problems and improving our Products  and Services, by using the information regarding your mobile device and software.  11.To investigate, prevent, or take action regarding illegal activities, suspected fraud or  situations involving potential threats to the safety of any person, violations of our Terms,  misuse of the Platform or as otherwise required by law;

12. To respond to any queries that you may have, and to communicate information to you,  including notifications of any promotions or alerts, any changes/updates to the Platforms,  or the introduction of any future fees or charges that we may collect at the time for  purchasing Products or provision of our Services to you;
13. To communicate other information about us, the Platforms, our other websites,  promotions, our newsletters, anything relating to other companies in our group or our  business partners;

14.To contact you, by way of SMS, email and phone calls, from time to time to record your  valuable feedback on our Products and Services, as they currently stand, and/or any  potential Products and Services that may be offered in the future.

(Collectively, the above constitute “thePurposes”).

If you wish to opt out of receiving non-essential communications such as promotional and  marketing-related information regarding our Products and Services, click unsubscribe link in  any email that we send to you or send an email to us at the details provided below in the  contact section.

4. DISCLOSURE OF INFORMATION 

We may disclose your Personal Information and SPDI, as the case may be, to third parties in  the manner and for the purposes specified below.

1. We may disclose your Personal Information and SPDI to third parties or to otherwise track  or improve our Products, Services or our business;
2. We may disclose your Personal Information to our logistics partners for processing of  orders placed by you on the Platform;
3. We may disclose information to our partners, affiliates, investors, stakeholders or  potential associates in an anonymized and aggregate manner, so that they too may  understand how Users use our Platforms and enable us to create a better overall  experience for you;
4. We also share aggregated anonymous information about Users with our clients, partners,  other Users, and other third parties so that they may be aware of the nature and number  of Users, in order for them to be able to serve advertisements and other kinds of  marketing information that may be relevant for you on our Platforms;
5. We may disclose and transfer your Personal Information and SPDI to a third party who  acquires, or may potentially acquire, our business, whether such acquisition is by way of a merger, consolidation or purchase of all or a substantial portion of our assets or  investment in us;

6. We may disclose Personal Information or SPDI to our group companies;  7. We may disclose Personal Information or SPDI to third parties such as our agents and  subcontractors to help us with any of our uses of your Personal Information or SPDI as set  out in our Privacy Policy. For example, we may use third parties to assist us with service  delivery to you, or to help us to collect payments from you, or to analyse Personal  Information and SPDI and to provide us with marketing or customer service assistance;  8. We may disclose Personal Information and SPDI with third parties for the purposes of  fraud protection and credit risk reduction;
7. We may transfer Personal Information and SPDI to a third party, including persons outside  India, to improve our Products and Services or purposes related to the provision of  Services and Products; and

10.We will disclose your Personal Information and SPDI if legally required to do so, pursuant  to an order from a governmental entity or in good faith. We will disclose the Information  to: (i) conform to legal requirements or comply with legal process; (ii) protect our rights  or property or our affiliated companies; (iii) prevent a crime or national security; or (iv)  protect personal safety of our Users or the public.

Transfer to third parties and outside India 

Subject to applicable law, we may at our sole discretion, transfer Personal Information and  SPDI to any other body corporate (as defined under the Information Technology Act, 2000)  that ensures at least the same level of data protection as is provided by us under the terms  hereof, located in India or any other country.

By using the Platforms, you accept the terms hereof and hereby consent to the storage and  processing of Personal Information and SPDI by third parties and in any of location within or  outside India. The Company will make best efforts to ensure that the third party or the  location to which the SPDI is transferred affords same level of data protection as would be  afforded under Indian law.

By continuing to use the Platforms, you provide your consent for transfer, sharing and  disclosure of such Personal Information or SPDI by us in accordance with this Privacy Policy.

Any third party to which we transfer or sell our assets, merge or consolidate with, will have  the right to continue to use the Personal Information or SPDI provided to us by you, in  accordance with the Terms and this Privacy Policy.

5. THIRD-PARTY LINKS 

The Platforms may include hyperlinks to various external websites, and may also include  advertisements, and hyperlinks to applications, content, or resources (“Third Party Links”).  We have no control over such Third Party Links present on the Platforms, which are provided  by persons or companies other than us. You acknowledge and agree that we are not  responsible for any collection or disclosure of your information by any external sites,  applications, companies or persons thereof. The presence of any Third Party Links on our  Platforms, cannot be construed as a recommendation, endorsement or solicitation for the  same, or any other material on or available via such Third Party Links.

You further acknowledge and agree that we are not liable for any loss or damage which may  be incurred by you as a result of the collection and/or disclosure of your information via Third  Party Links, as a result of any reliance placed by you on the completeness, accuracy or  existence of any advertising, products services, or other materials on, or available via such  Third Party Links. This will include all transactions, and information transmitted therein,  between you and any such third party sites or applications or resources, such transactions are  strictly bi-partite. We shall not be liable for any disputes arising from or in connection with  such transactions between you and the aforementioned third parties.

Such third party websites, and external applications or resources, accessible via the Third  Party Links may have their own privacy policies governing the collection, storage, retention  and disclosure of your information that you may be subject to. We recommend that you  exercise reasonable diligence, as you would in traditional offline channels and practice  judgment and common sense before committing to any transaction or exchange of  information, including but not limited to reviewing the third party website or application’s  privacy policy.

6. CHANGES TO YOUR INFORMATION 

You may review, correct, update, change or delete your Personal Information relating to  Registration Information and Order Information on the Platforms by writing to us at the

contact details specified below. You can delete any part of the Personal Information or  request us to delete the same, and we will comply with such requests within a reasonable  time, unless we are required to keep certain information for legal purposes. You may update  your SPDI at any point by writing to us at the details indicated below in the contact section.

Should you choose to delete your Personal Information or SPDI or modify it in a way that is  not verifiable by us, or leads to such information being incorrect, we will be unable to provide  you with access to our Platforms or our Services, as described under the Terms, and such a  deletion or modification may be regarded as the User seeking to discontinue his or her access  to our Platforms and Services.

We reserve the right to verify and authenticate your identity and your Personal Information  in order to ensure accurate delivery of Products and Services. Access to or correction,  updating or deletion of your Personal Information or SPDI may be denied or limited by us if it  would violate another person’s rights and/or is not otherwise permitted by applicable law.

7. SECURITY AND RETENTION OF INFORMATION 

Security of your information 

We endeavour to maintain physical, technical and procedural safeguards that are appropriate  to protect your information against loss, misuse, copying, damage or modification and  unauthorized access or disclosure. Our security management standards are in compliance  with ISO 27001. Some of the security measures adopted by us are:  We review our information collection, storage and processing practices, including physical  security measures, to guard against unauthorized access to systems; and

1. We restrict access to Personal Information, to our employees and agents who need to  know that information in order to process it for Us, and who are subject to strict  contractual confidentiality obligations, and may be disciplined or whose relationship with  us may terminate if they fail to meet these obligations.
2. No employee or administrator of the Company will have knowledge of your password of  your account on the Platforms.
3. Our security controls may occasionally request for proof of identity before disclosing any  Personal Information or SPDI to you. We recommend that you to not send full credit or  debit card details in unencrypted electronic communications with us.
4. It is important for you to protect against unauthorized access to your password and your  mobile phone. You must be sure to log off from the Platforms when you have finished use  thereof. We do not undertake any liability for any unauthorised use of your account and  password.
5. If you suspect any unauthorized use of your account, you must immediately notify us by  sending an email to the contact details indicated in the contact section. You shall be liable  to indemnify us due to any loss suffered by us due to such unauthorized use of your  account or password.
6. We shall not be liable for any misuse of your password. Further, we shall not be  responsible for any breach of security or for any actions of any third parties or events that  are beyond our reasonable control including but not limited to acts of government,  computer hacking, unauthorised access to computer data and storage device, computer  crashes, breach of security and encryption, poor quality of internet service or telephone  service of the User, etc.

Retention of Information 

1. We also have measures in place such that your SPDI which is in our possession or under  our control, is destroyed and/or anonymized as soon as it is reasonable to assume that: (i)  the Purposes for which your SPDI has been collected have been fulfilled; and (ii) retention  is no longer necessary for any other reason.

2. We may, however, reserve the right to retain and store your Personal Information for our  business purposes, whether such Personal Information has been deleted or not. After a  period of time, your data may be anonymized and aggregated and then may be held by us  as long as necessary, to enable purchases of Products and provision of Services or for any  other lawful purposes.

If you wish to withdraw your consent for processing your Personal Information and SPDI,  cancel your account, or request that we no longer use your Personal Information and SPDI to  deliver our Products or provide you Services, please contact us at details indicated in the  contact section below. Please note, however, that your withdrawal of consent or cancellation  of account may result in us not being able to deliver you Products or provide you with our  Services, or terminate any existing relationship that we may have with you.

Please note that uninstalling our mobile application will not result in deletion of your Personal Information or SPDI.

8. Cookies and other Tracking Technologies 

We utilize “cookies” and other tracking technologies, having session or local variables. A  “cookie” is a small text file that may be used, for example, to collect information about activity  on the Platforms. Some cookies and other technologies may serve to recall information  previously indicated by a User. Most browsers/mobile settings allow you to control cookies,  including whether or not to accept them and how to remove them. You may set most  browsers/mobile application to notify you if you receive a cookie, or you may choose to block  cookies with your browser/mobile applications.

Tracking technologies may record information such as internet domain and host names,  internet protocol (IP) addresses, browser software and operating system types, stream  patterns, and dates and times that our Platforms are accessed. Our use of cookies and other  tracking technologies allows us to improve our Platforms and your experience.

At all times, you may refuse all cookies on your browser or mobile application by changing  your settings to the extent permissible on your device. However, by doing so, you may not be  able to use certain features on the Platforms or take full advantage of all the offerings and  interest-based advertising. You can remove cookies by following directions provided in your  mobile’s “help” file or the browser.

9. CHANGES TO THE POLICY 

We reserve the right to update, change or modify this Privacy Policy at any time. The Privacy  Policy shall come to effect from the date of such update, change or modification. If you

continue to access or use the Platforms even after any such changes have been made, it would  be deemed to be your implied consent to the changed Privacy Policy.

10.Miscellaneous  

1. Disclaimer: We cannot ensure that all of your Personal Information and SPDI will never be  disclosed in ways not otherwise described in this Privacy Policy.Therefore, although we are committed to protecting your privacy, we do not promise,  and you should not expect, that your information or private communications will always  remain private. As a User of the Platforms, you understand and agree that you assume all  responsibility and risk for your use of the Platforms, the internet generally, and the  information you post or access and for your conduct on and off the Platforms.

2. Indemnity: You agree and undertake to indemnify us in any suit or dispute by any third  party arising out of disclosure of information by you to third parties either through our  Platforms or otherwise and your use and access of websites, applications and resources  of third parties. We assume no liability for any actions of third parties with regard to your  Personal Information or SPDI which you may have disclosed to such third parties.

3. Severability: Each clause of this Privacy Policy shall be and remain separate from and  independent of and severable from all and any other clauses herein except where  otherwise expressly indicated or indicated by the context of the Privacy Policy. The  decision or declaration that one or more clauses are null and void shall have no effect on  remaining clauses of this Privacy Policy.

4. Copyright: We own the copyright of this Privacy Policy. You are not permitted to use, even  by way of extract, this Privacy Policy for any commercial purposes.

11.CONTACT

Email: time2timeeducation@gmail.com

Any feedback or comments about this Privacy Policy will be welcome, and can be sent to  time2timeeducation@gmail.com. We will employ all commercially reasonable efforts to address the  same.