Privacy Policy

Last updated: July 6, 2025

1. SCOPE AND APPLICATION

1.1

The terms “We/Us/Our” shall refer to Educator Labs Pvt Ltd, and the terms “You/Your” shall refer to the users, and any other persons accessing or seeking to use the Platform and/ or availing our Services. For the purposes of this Privacy Policy, the terms “Platform” and “Services” shall have the meanings attributed to them in our Terms of Use.

1.2

We have created this privacy statement in order to demonstrate our firm commitment to privacy. This Privacy Policy is a legally binding document between you and us which governs the usage, collection, protection and sharing of any Information (defined hereinafter) that you provide us, when you access our Platform and/ or use our Services through any media or devices.

1.3

This Privacy Policy is an electronic document and does not require any physical, electronic or digital signature. By accessing or using the Platform and/ or availing our Services, you indicate that you understand, agree and consent to the terms and conditions contained in the Privacy Policy. If you do not agree with the terms and conditions of this Privacy Policy, please do not use the Platform or avail our Services.

1.4

This Privacy Policy shall be read together with the other policies published by us on the Platform, including without limitation the Terms of Use.

2. COMMITMENT

2.1

We are committed to ensure that your privacy is protected to all possible, reasonable and commercial extent, as your privacy and data protection is of the utmost importance to us.

2.2

We gather certain types of Information in order to provide, maintain and improve the Platform and the Services rendered to you; and hence, we strongly urge you to fully understand the terms and conditions of the Privacy Policy surrounding the collection and use of such Information.

2.3

Please refer to our Privacy Notice for information on the specifics of data we collect from you and the specified purpose of processing. The Privacy Notice also explains, inter alia, your rights as someone who may provide your PII (defined hereafter) to us.

3. UPDATES TO THE PRIVACY POLICY

3.1

We reserve the right to modify, amend, suspend, terminate or replace this Privacy Policy from time to time within our sole discretion. We will post any changes made to the Privacy Policy on the Platform without prior notice to you. Such changes will take effect immediately upon their posting on the Platform. However, if we make any material changes to this Privacy Policy — particularly those involving new or additional data collection, or any reduction in previously stated protections for student data — we will provide advance written notice to the relevant schools, separate from any notice presented through a "click-wrap" or general update mechanism, to allow for their review and response.

3.2

We encourage you to review the Privacy Policy frequently. By your continued use of the Platform and availing of our Services, you consent to the terms of the revised/ updated Privacy Policy.

4. COLLECTION OF INFORMATION

4.1

For the purposes of rendering the Services and/ or use of the Platform, we may collect certain Information from various channels, including, but not limited to, voluntary submission of information from your end in furtherance of the access or usage of the Services and/ or the Platform, through requests initiated by you towards the Services and through communications. Notwithstanding any provision to the contrary, where we provide Services to our business customers, we collect and process Information on behalf of such customer, on terms and conditions of our agreement(s) with them.

4.2

Please note that we are based in the Republic of India. We are governed by the (Indian) Information Technology Act, 2000 (as amended from time to time); Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and once fully in effect, the Digital Personal Data Protection Act, 2023 (and the rules thereunder). Our collection, storage and usage of Information will be governed by this Privacy Policy and/ or our agreement(s) with our business customers (as the case may be). We will always endeavour to protect your Information.

5. TYPES OF INFORMATION COLLECTED BY THE US (“INFORMATION”)

5.1.

Personally Identifiable Information (PII):

(a)

PII, as used in information security and privacy laws, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context.

(b)

We may collect and retain certain PII including without limitation your name, telephone number, mailing address, email address, history of your transactions with us, etc.

(c)

These PII are essential for rendering our Services to you and for our communications with you. We may also use this Information to customize our Services based on such Information as provided by you.

(d)

Any information exchanged by you with us in the form of written communication, responses to emails, feedback provided, participation in discussions, etc. is handled with confidentiality and will be available for our exclusive use.

(e)

You have the right to request to discontinue our use of your PII, and other rights prescribed under the applicable law. To withdraw your consent to our collection and processing of your information in future, you may do so by specifically informing us that you are withdrawing your consent towards our use of your PII. However, please note that you will need to provide us with alternate means of communicating with you, if the Services are on-going in nature. If we do not have requisite consents in place (or if consents are withdrawn), our Services to you will be hampered, and we disclaim any liability or responsibility in this regard.

5.2.

Non-Personal Information (NPI):

(a)

We also collect information in a form that does not permit direct association with any specific individual (“NPI”). We request you to note that when you access the Platform or receive emails or any communication from us, we along with our affiliated companies and permitted agents, may use various technologies (including without limitation, cookies, web beacons, and/or pixel tags) to collect NPI (such as browser you use, referring/ exit pages, anonymous usage data, number of clicks, etc) and store your online preferences.

(b)

We may use your internet protocol (“IP”) address to help diagnose any problems (including with our servers), as well as to administer our Services and the Platform. Your IP address is used to help identify you and to gather broad information. We may use your IP address to help protect ourselves, and our partners and customers from any adverse acts. For system administration purposes, we may also log IP server addresses and catalogue traffic patterns through our Platform. However, we do not link this information to any users’ PII.

(c)

If we do combine NPI with PII, then the combined information will be treated as PII for as long as it remains combined.

(d)

We may also collect other non-specific information to provide you better access to the Services each time such preferences and interests and other non-personal details are shared via the Platform or e-mail or any other medium. We may also store and publish such information to assist us in making the Platform and Services better and easier to use.

6. INFORMATION USAGE AND SHARING

6.1.

Our primary goal in collecting the Information is for us to facilitate better access to the Platform and render the Services to you, and to ensure quality and efficiency in the Services provided to you. Additionally, we will also be using the Information for our internal operational purposes, such as providing, maintaining, evaluating, and improving the Platform and the Services, and also for providing customer support. Specifically, please note that we collect, analyse, and anonymize the data we collect to create aggregated data to use and perform the Services and to develop and use related systems and technologies, including the for training of machine learning algorithms.

6.2.

We would also be sharing the information with others in the manner provided in this Privacy Policy. We may share Your PII with third parties in the following limited circumstances

(a)

For the purpose of processing PII on our behalf in connection with the Services or providing you with additional services related to our business and Services. We will require that these third parties are subject to appropriate confidentiality and security measures;

(b)

We have a good faith belief that access, use, preservation or disclosure of such PII is reasonably necessary to: (i) satisfy any applicable law, regulation, legal process or enforceable governmental request including to law enforcement and in response to a court order, (ii) detect, prevent, or otherwise address fraud, technical or security issues, (iii) enforce applicable policies of the Platform, which may be further extended to investigation of potential violations thereof, or (iv) protect against harm to our rights, safety or property, our users or the public as required or permitted by law;

(c)

To protect ourselves against third-party claims;

(d)

We may disclose/ share Information to those third-parties who support our business, such as our consultants, service providers and contractors, or those providing technical infrastructure services, analysing how our Services are used, measuring the effectiveness of the Platform, providing customer support and business support services, facilitating payments, or conducting research and surveys, and such information will be used for the limited purposes of such services received by us.

6.3.

Please note that we do not and will not trade or sell your PII in any manner.

6.4.

We may share NPI with interested third parties to help them understand the usage patterns and analyses for certain Services. Any NPI and data and analyses arising therefrom may be shared by us to our existing and potential partners, investors, service providers and others.

7. INFORMATION SECURITY & RETENTION

7.1

We take precautions including without limitation administrative, technical and physical measures to safeguard your personal information against loss, misuse or theft, as well as against destruction, alteration, disclosure and unauthorized access. Specifically, while we will ensure our best efforts to protect your Information in line with commercially reasonable efforts and general industry standards; however, we do not represent, warrant, or guarantee that your Information will be protected against unauthorized access, loss, misuse, or alterations beyond our reasonable control.

7.2

You understand and agree that the we may continue to store your Information after you cease use of the Services or disable your use of, access to, or otherwise of the Services or the Platform. Please note that we shall not use, share or/ and disclose your PII with our affiliates, vendors, third parties etc., after you cease use of the Services or disable your use of, access to, or otherwise of the Services or the Platform, unless required by law to do so. NPI will be retained indefinitely, and we may however continue to use, share and/ or disclose your NPI in furtherance of our policies.

7.3

We conduct vulnerability assessments and penetration testing (VAPT) to identify and address security risks in our systems. We are committed to conducting such tests on an annual basis and to remedying identified vulnerabilities within a reasonable time frame. Additionally, on a case-by-case basis, we will provide schools or their designated third parties with access to the results of such audits or allow them to conduct their own audits of our data protection and security practices, subject to mutual agreement and reasonable notice.

7.4

We have implemented internal processes to enable secure deletion of personally identifiable information (PII) upon a school's written request. Schools may request the deletion of specific PII via written communication. Upon receipt of such a request — including in cases where a school terminates its contract with us — we will ensure the requested PII is permanently deleted from our systems within 30 (thirty) days, unless retention is required by applicable law.

7.5

We have instituted an inactivity-based data retention policy. If a user remains inactive for a period exceeding twelve (12) consecutive months, we will initiate a process to permanently delete the user's account and all associated data, unless otherwise required to retain such data by applicable law or contractual obligations. Prior to such deletion, we will notify the relevant school and/or user in advance, providing them with an opportunity to take appropriate action, including downloading their data or requesting continued retention. We also provide mechanisms for schools and parents to download all data associated with a child (subject to the school's discretion on what is shared) at any time through the Platform.

8. LINKS TO/FROM THIRD-PARTY WEBSITES

8.1

The Platform may contain links to third-party websites, products, and services. Information collected by third parties (which may include without limitation information such as contact details), is governed by the privacy practices undertaken by such third parties. We encourage you to learn about the privacy practices of those third parties. We expressly assert that we cannot be responsible for these practices.

8.2

We may have presence on social networking websites including but not limited to LinkedIn, Facebook, Twitter, Instagram, YouTube and blogs which are promotional and business initiatives to attract, engage and connect to a larger group of people. The domain links contained therein may either direct you to our Platform or request your participation by way of feedback, suggestions, etc. We, in this regard, fully disclaim any liability(ies) or claim(s), which may arise by use/misuse of your feedback, suggestions, views, etc. on any of the aforementioned networking websites or blogs, by any third party whether or not known to us.

9. BUSINESS TRANSFERS AND CONTINUITY

9.1

In the event of a merger, acquisition, reorganization, sale of assets, bankruptcy, or other business transfer involving Educator Labs Pvt Ltd (“Member Company”), your personal data—whether PII or NPI—may be transferred to the new owner or successor entity. In such a transfer, we will ensure that the receiving party agrees to uphold the data protection commitments in this Privacy Policy (or provide materially equivalent protections).

10. YOUR RIGHTS & PREFERENCES AS A DATA SUBJECT

10.1.

Subject to the GDPR and applicable law's limitations, the rights afforded to you as a data subject are:

(a)

RIGHT TO BE INFORMED: You have a right to be informed about the manner in which any of your personal data is collected or used which we have endeavored to do by way of this Policy.

(b)

RIGHT OF ACCESS: You have a right to access the personal data you have provided by requesting us to provide you with the same.

(c)

RIGHT TO RECTIFICATION: You have a right to request us to amend or update your personal data if it is inaccurate or incomplete.

(d)

RIGHT TO ERASURE: You have a right to request us to delete your personal data.

(e)

RIGHT TO RESTRICT: You have a right to request us to temporarily or permanently stop processing all or some of your personal data.

(f)

RIGHT TO OBJECT: You have a right, at any time, to object to our processing of your personal data under certain circumstances. You have an absolute right to object to us processing your personal data for the purposes of direct marketing.

(g)

RIGHT TO DATA PORTABILITY: You have a right to request us to provide you with a copy of your personal data in electronic format and you can transmit that personal data for using another third-party's product/service.

(h)

RIGHT NOT TO BE SUBJECT TO AUTOMATED DECISION-MAKING: You have a right to not be subject to a decision based solely on automated decision making, including profiling.

In case you want to exercise the rights set out above you can contact our Grievance Officer whose details are set out in Section 13 below.

10.2

The data provided by you as a Visitor, or when you sign up as a Customer / User or register for our Services will be processed by us for the purpose of rendering Services to you or in order to take steps prior to rendering such Services, at your request. Where such data is not being used by us to render Services to you, we shall explicitly seek your consent for using the same. You can choose to withdraw this consent at any time .

11. GOVERNING LAW

11.1

We are incorporated in, and based out of the Republic of India, and we are duty bound to abide by Indian laws. We may not have complied with some privacy laws of other countries and further represent to be unaware of such other legal requirements.

11.2

Further, any disputes regarding this Privacy Policy shall be subject to exclusive jurisdiction of the courts of Bengaluru, India.

12. GRIEVANCES

12.1

In case of breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed, we have the mechanisms and policies in place in order to identify it and assess it promptly. Depending on the outcome of our assessment, we will make the requisite notifications to the supervisory authorities and communications to the affected data subjects, which might include you.

12.2

In accordance with the legal requirements, the name and contact details of the Grievance Officer who can be contacted with respect to any complaints or concerns including those pertaining to breach of this Privacy Policy and other polices are published as under:

Data Privacy Officer/ Grievance Officer Name: Yuvraj Goyal

Email address: yuvraj@cuepil.com

Phone number: +91 82828 22525

Address: P-219, C.I.T. Scheme VII M, Kolkata 700054, West Bengal, India

The Data Privacy/ Grievance Officer can be contacted between 10am to 5pm (IST) from Monday to Friday except on public holidays.

13. QUESTIONS AND CONTACT INFORMATION

13.1

If you want to access, correct, amend, or delete any of your Information, have any questions about this Privacy Policy, or wish to register a complaint, you may contact us at the details provided at connect@myedlab.com. We are committed to responding to and addressing all reasonable concerns or inquiries in a timely manner

13.2

If you have questions or complaints specifically related to our privacy practices or this Privacy Policy — including concerns under the Children's Online Privacy Protection Act (COPPA) — you may also contact the iKeepSafe Safe Harbor Program directly at COPPAPrivacy@ikeepsafe.org.