Privacy Policy

Introduction

At our Platform, we provide an online learning platform that enables users to register, explore, and enroll in various educational courses designed to enhance their skills. Our Platform offers a structured learning experience with features such as course recommendations, interactive lessons, assessments, discussions, and progress tracking (the "Services"). By using our App, users can discover and engage with learning materials tailored to their interests and skill levels. By reviewing this Policy, you will gain a comprehensive understanding of your privacy rights and choices.

Your access to and/or utilization of our Platform and/or Services signifies your agreement to be governed by this Policy. By providing us with your Personal Information, you expressly consent to the use and disclosure of your Personal Information as outlined in this Policy. This Policy, along with the Terms of Service, and User Data Deletion Policy, is applicable to your use of the Services, and you explicitly agree and acknowledge to read the Privacy Policy in conjunction with the aforementioned policies.

The term "Personal Information" shall mean any information that relates to an identified or identifiable individual, and can include information that you provide to us and that we collect about you, such as when you engage with our Platform (e.g. device information, IP address, location etc.).

By utilizing the Platform and/or Services, or furnishing your Personal Information, you explicitly agree and acknowledge that you accept the terms delineated in this Policy. The terms 'you', 'your', or 'User' in the context of this Policy collectively pertain to any individual utilizing our Platform, whether for personal use or on behalf of others.

By visiting the Platform or providing your information, you expressly agree to be bound by this Privacy Policy and agree to be governed by the data protection and privacy laws of India including but not limited to the Information Technology Act, 2000, Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (IT Rules), and the Digital Personal Data Protection Act (DPDPA), 2023, and other relevant regulations governing data protection and privacy.

1. To Whom Does This Policy Apply?

This Policy is inclusive and applies to all Users of our Platform and/or Services, irrespective of their browsing intent or their extent of utilizing the Services offered on our Platform.

The applicability of this Policy extends to users regardless of the device type used for accessing our Platform and/or Services, whether it be a laptop/desktop or a mobile/tablet device.

1.1 Minors and Parental Consent

We recognize that students under the age of eighteen (18) may use our Platform for educational purposes. If you are under the age of eighteen (18), you may only access and use our Services with the consent and supervision of a parent or legal guardian. By permitting a minor to use our Platform, the parent or legal guardian acknowledges and agrees to be bound by this Privacy Policy and to take full responsibility for the minor's activities on the Platform.

We do not knowingly collect Personal Information from children under the age of thirteen (13) without verifiable parental consent, in compliance with applicable data protection laws. If we discover that we have unintentionally collected Personal Information from a child under 13 without appropriate consent, we will take steps to delete such information as soon as possible.

2. What Information Do We Collect From You?

To use our Platform, you need to create an account and register with us ("Account") and for this purpose, we collect certain Personal Information. This may include but is not limited to the following:

2.1 Categories of Information

• Basic Information: You are required to provide basic information such as name
• Contact Information: such as email address and mobile number
• Verification Data: We may collect information relevant to your use of our Platform and Services, such as a One-Time Password (OTP) sent at the time of account creation, and/or log-in
• Learning Preferences & Usage Data: This includes details about selected courses, learning progress, interactions with course content, quizzes, and discussions
• Communication with us: This can include any communication that you send to us, including communications for courses, account support, technical issues, general feedback, etc
• Device Identification data: This includes information that may assist us in identifying your device, including login information, browser type, and version, your operating system, etc

2.2 Other Data

This can include the following, based on your interaction with the Platform:

• Number of times you logged into your Account
• The length of time you spent on the Platform
• The period from which you became and have continued to be active on the Platform
• Other similar statistics we may collect with the intention to improve the User experience of the Platform

2.3 How You Provide Information

You agree to provide us with your Personal Information whenever you use our Services by performing any of the following functions:

• Accessing our Platform by means of any web browser or any device
• Creating an Account and registering for our Services on the Platform
• Inquiring about our Services through our Platform
• Initiating and maintaining correspondence with us

We take extra precautions to ensure that such Personal Information is kept secure and confidential, and we will only retain this data for as long as necessary for the purposes for which we collect it as per the permissible laws of the land.

This Policy will not apply to any unsolicited information provided by you through the Platform or through any other means. This includes but is not limited to, information posted on any public areas of the Platform. All such unsolicited information shall be deemed to be non-confidential and we will be free to use and disclose such unsolicited information without limitation.

We shall not be liable for any loss or damage sustained by you as a result of any disclosure (inadvertent or otherwise) of any Personal Information concerning your Account.

Access to your Personal Information is limited to employees, agents, partners, and third parties, who we reasonably believe will need that information to enable us to provide Services to you. However, we are not responsible for the confidentiality, security, or distribution of your own Personal Information by our partners and third parties (who have their own privacy policies) outside the scope of our agreement with such partners and third parties.

When you use our Platform, we collect and store your information which is provided by you from time to time. In general, you can browse the Platform without telling us who you are or revealing any Personal Information about yourself. Once you give us your Personal Information, you are not anonymous to us. Where possible, we indicate which fields are required and which fields are optional. You always have the option to not provide information by choosing not to use a particular service, product, or feature on the Platform.

3. How Do We Collect the Information?

We employ various methods to gather information, ensuring a comprehensive understanding of user interactions and preferences. The collection of Personal Information is facilitated through the following processes:

3.1 Direct Collection

Information you give us: When you provide us with the information referred to in the previous section through the methods outlined.

3.2 Session Management

We study session metrics to understand how users interact with the Platform. This helps us learn the average time users spend on the Platform and when they prefer to engage. We use tools like Google Analytics (or alternatives) to collect anonymous data, including the number of views, how long users stay, and where they're visiting from. This data allows us to optimize the user experience, making informed enhancements to cater to user preferences and behaviors.

3.3 User Analytics

We analyze user behavior and preferences, by collecting and analyzing Personal Information and maintaining transaction history within the Platform to track and ensure accuracy, promptly identify any unauthorized transactions, and detect fraudulent activities, allowing us to take immediate corrective action.

3.4 Cookies and Similar Technologies

In addition to direct user interactions, we leverage cookies and similar technologies to enhance the functionality and user experience on the Platform. These allow us to collect and process additional information for various purposes:

Types of Cookies:

• Strictly Necessary Cookies: These cookies are needed to run our Platform, to keep it secure if you are logged in, and to obey regulations that apply to us. They also help us keep your details safe and private
• Functional Cookies: These cookies are used for remembering things such as your region or country, your preferred language, accessibility options like large font or high-contrast pages
• Performance Cookies: These cookies tell us how you and our other users use our Platform. We combine all this data together and study it. This helps us to improve the performance of our Services and/or the Platform

3.5 Other Tracking Technologies

• Web Beacons, Pixel Tags, and Trackers: We may employ Web Beacons, Pixel tags, and tracking URLs which are tiny graphic images and/or small blocks of code placed on App pages, ads, or in our emails that allow us to determine whether you performed a specific action
• Log Files: Our servers automatically collect information sent by users' devices, known as log files. This data may include IP addresses, device information, browser type, and timestamps
• Third-Party Analytics: We may integrate third-party analytics services to further understand user behavior. These services utilize their own tracking technologies to compile reports on Platform activity
• Location Data: As part of our Services we may also collect precise geolocation data, including GPS signals, device sensors, Wi-Fi access points, and cell tower IDs. We collect this type of data if you grant us access to your location. You can withdraw your consent at any time by disabling the GPS or other location-tracking functions on your device

3.6 Information from Other Sources

We may collect Personal Information from other sources, including but not limited to:

• If a user or any third party submits a complaint about you, we may receive information relating to the specific complaint made in order to understand and, where relevant, address the complaint
• To the extent permitted by applicable law, we may receive additional information about you, such as references, demographic data, and information to help detect fraud and safety issues from third-party service providers, other third parties, and/or partners, or users and any other individuals, entities, and authorities, and combine it with information we have about you

4. Why Do We Collect Your Information?

You agree and acknowledge that we shall collect your information only for lawful and legally permissible purposes which are as follows:

In the course of operating the Platform and/or Services, we collect and utilize Personal Information in accordance with our Privacy Policy. You consent and recognize that your Personal Information may be disclosed on our Platform authorized by you for the purpose of utilizing our Services. Additionally, you agree and acknowledge that we are permitted to communicate with you through messaging, calls, emails, or other means, to facilitate the performance of our services wherever necessary.

5. Who Do We Share Your Personal Information With and Why?

To facilitate our Services and enhance user experience, we may share Personal Information with the following entities:

5.1 Third-party Service Providers

We engage the services of third parties to carry out various functions on our behalf such as data analysis, postal and email communications, hosting services, storage, customer service, and marketing assistance. These third-party service providers have access to the necessary Personal Information to fulfill their functions. However, they are strictly prohibited from using it for any other purposes. Moreover, they are obligated to process the Personal Information in compliance with applicable laws. While we do not own or control these third parties, when you interact with them and choose to use their services, you are providing your information to them. Your use of these services is subject to the privacy policies of those providers.

5.2 Affiliates

We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates may include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

5.3 Business Transfers

If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline to honor commitments we made in this Privacy Policy.

5.4 Legal Compliance

We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, authorized third parties, or other users, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary to: (i) comply with our legal obligations, (ii) comply with a valid legal request, such as a subpoena or court order, or to respond to claims asserted against Company, (iii) respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our users to legal or regulatory liability, (iv) enforce and administer our agreements with users, including our Terms, additional legal terms, and policies, (v) respond to requests for or in connection with current or prospective legal claims or legal proceedings concerning the Company and/or third parties, in accordance with applicable law, or (vi) protect the rights, property or personal safety of the Company, its employees, its user, or users of the public.

Where legally required or permissible according to applicable law, we may disclose user information to relevant tax authorities or other governmental agencies, depending on where you are based, for the purpose of the tax authorities' determination of proper compliance with relevant tax obligations.

Where appropriate and/or legally required, we may notify the user about legal requests, unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon or harm to us, our users, or expose the Company to a claim of obstruction of justice.

5.5 Service Improvement

We may share certain aggregated, anonymized information with third parties (for example, for Google Analytics) in order to assess the Platform usage and information pertaining to the ease of navigation.

5.6 Advertisements

We use third-party advertising companies to serve ads when you visit our Platform. These companies may use information (not including your name, address, email address, or telephone number) about your visits to the Platform and other websites in order to provide personalized advertisements about goods and services of interest to you.

5.7 Collaborations & Growth

We may share your Personal Information with reputable partners to facilitate joint initiatives, promotions, or integrated services. As our Platform evolves and expands, there may be instances where sharing Personal Information with new entities or parties becomes necessary for the enhancement of our Services. Any such sharing will be carried out with the utmost consideration for user privacy and in accordance with relevant legal frameworks.

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

6. How Long Do We Keep Your Personal Information?

In compliance with applicable laws, we retain your Personal Information for a duration no longer than necessary for the purpose for which it was collected or as mandated by relevant laws. In some cases, where immediate deletion is not feasible due to technical or legal constraints, we may instead anonymize your data to ensure it can no longer be linked to you, effectively removing all personal identifiers. The anonymized data may be retained solely for analytical and research purposes. However, certain data related to you may be retained beyond this period if we reasonably believe it is necessary to prevent fraud, mitigate potential abuse, allow us to exercise our legal rights, defend against legal claims, or fulfill other legitimate purposes required by law or for analytical and research purposes.

6.1 Reasons for Extended Retention

Additionally, we may continue to retain your Personal Information for the following purposes including but not limited to:

• Legitimate Business Interest: We may retain your Personal Information as necessary for our legitimate business interests, such as the prevention of money laundering, fraud detection and prevention, and enhancing safety
• Legal, Tax, Reporting, and Auditing Obligations: We may retain and use your Personal Information to the extent necessary to comply with our legal, tax, reporting, and auditing obligations
• Shared Information: Information you have shared with others, such as reviews and forum postings, may continue to be publicly visible on the App, even after your access/use is restricted
• Residual Copies: Residual copies of your Personal Information (either in the form of De-Identified Information, Non-Identifying Information, or identified information) may remain in our backup systems for a limited period of time, primarily to ensure compliance with legal obligations and to protect against accidental loss or destruction. We strive to anonymize your data to prevent any personal identifiers from being linked to you. However, in rare cases where legal or operational requirements are necessitated, identifiable information may be retained temporarily. Such retention is strictly limited and governed by applicable laws

7. How Do We Provide for the Security of Your Personal Information?

We prioritize the security of your data, utilizing secure cloud servers where your Personal Information is encrypted at rest, adding an extra layer of protection against unauthorized access. We take reasonable steps to ensure appropriate physical, technical, and managerial safeguards are in place to protect your Personal Information from unauthorized access, alteration, transmission, and deletion.

You understand and agree that despite the security measures in place, we cannot be held liable for any issues related to data security. Nevertheless, we implement reasonable physical, electronic, and procedural safeguards to maintain the confidentiality and integrity of your information. As part of this commitment, it is imperative that you also review and adhere to the terms of service and privacy policy of our third-party service providers.

While we take comprehensive measures to safeguard your information, Users acknowledge and accept the inherent security implications of data transmission over the Internet and the World Wide Web. Despite our efforts, complete security cannot be guaranteed, and inherent risks persist. Users bear the responsibility of safeguarding login credentials for their Accounts. Any transmission of Personal Information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Platform. While acknowledging these risks, we remain committed to continually enhancing our security protocols to address emerging threats and maintain the trust of our Users.

8. How Do We Handle Data Breaches and Security Incidents?

In the event of a data breach or security incident, we maintain a proactive approach to ensure swift resolution and mitigate potential risks. We have established a comprehensive incident response plan designed to address such occurrences promptly and effectively:

8.1 Our Response Process

• Identification: We promptly identify and acknowledge any signs of a data breach or security incident within our systems or infrastructure
• Containment: Immediate action is taken to contain the impact of the breach, preventing further unauthorized access or damage to data
• Notification: We prioritize transparency by promptly notifying affected parties, including Users and relevant stakeholders, about the breach and its potential impact on their data
• Collaboration: We collaborate with relevant authorities, such as regulatory bodies and law enforcement agencies, to report the incident and comply with any legal obligations or regulatory requirements
• Post-Incident Assessment: Following the resolution of the incident, we conduct thorough assessments to evaluate the effectiveness of our response measures and identify areas for improvement

9. What Are Your Rights as a Data Subject?

You, as a data subject, have certain rights to your Personal Information under the applicable laws, as outlined below:

9.1 Right to Access

You have the right to access any of the Personal Information we hold about you at any time. For security purposes, when you request access to your Personal Information, you will need to provide us with enough information to verify your identity. We will generally provide you with access to your Personal Information, subject to some exceptions permitted by law. If we are unable to provide you with all or any of the information we hold about you, we will inform you why your request has been denied or limited.

9.2 Right to Consent

Your explicit consent is required for the collection and processing of your Personal Information.

9.3 Right to Withdraw Consent

The consent that you provide for the collection, use, and disclosure of your Personal Information will remain valid until such time it is withdrawn by you in writing. You may withdraw your consent at any time by contacting us or in accordance with our User Data Deletion Policy. Upon withdrawal, we will cease processing the relevant personal information, except where other legal grounds for processing exist under applicable laws. We will respond to your request within a reasonable timeframe.

9.4 Opting Out of Marketing Materials

You may object to our use of your Personal Information for marketing purposes. You can always opt out of this through the functionality provided in each marketing communication (e.g. by clicking "unsubscribe" at the bottom of an email).

9.5 Right to Review and Correction

You are responsible for maintaining the accuracy of the information you submit to us. You can review the information you have provided and ensure it is accurate and up-to-date. If you wish to make a request to correct or update any of the Personal Information that we hold about you, you may update your information by writing to us at flashapp@altlapps.com.

9.6 Right of Access and Portability

In some jurisdictions, applicable law may entitle you to request certain copies of your Personal Information or information about how we handle your Personal Information, request copies of Personal Information that you have provided to us in a structured, commonly used, and machine-readable format, and/or request that we transmit this information to another service provider, where technically feasible.

9.7 Right of Erasure

In some jurisdictions, you can request that your Personal Information be deleted. For more information, please refer to our User Data Deletion Policy.

9.8 Right to Grievance Redressal

You have the right to lodge a complaint regarding the processing of your Personal Data with our Data Protection Officer. You can submit your complaint in writing to our Data Protection Officer at flashapp@altlapps.com with the subject line "Appeal of Privacy Rights Request."

If you believe your rights have been violated or are dissatisfied with our response, you have the right to lodge a complaint with the Office of the Data Protection Commissioner of India (DPIC). The DPIC is responsible for handling complaints related to data protection and ensuring compliance with the DPDPA.

10. Are Children Allowed to Use Our Platform and/or Services?

Children under the age of 18 ("Minors") are allowed to use the Platform and/or Services. However, they must do so with the consent and supervision of a parent or legal guardian ("Guardian"). By allowing a Minor to access and use our Platform and Services, the Guardian acknowledges and agrees to be responsible for the Minor's use of the Platform, including compliance with our Terms of Service and Privacy Policy.

If you are a Guardian and believe your child has provided us with Personal Information, we urge you to promptly contact us at flashapp@altlapps.com. Upon verification of your Guardian status, we will promptly take all necessary steps to remove and delete such information from our records.

11. How Can You Express Your Complaints and Concerns?

User satisfaction is one of the key focus areas and an integral part of our Platform's founding principles and business policies. We strongly believe that user satisfaction is the most important factor in the growth and development of our business and hence, we have adopted user-centricity as a priority in developing our business processes. The terms below shall constitute our "User Grievance Redressal Policy" which outlines the framework for addressing user grievances:

11.1 User Grievance Redressal Policy

Objective:

The objective of this Grievance Policy is to provide a framework:

• To ensure the provision of timely and effective resolution of issues raised by users; and
• To keep users informed about the manner in which they can reach out to us to resolve their queries and grievances

Governing Principles:

The policy on grievance redressal is governed by the following principles:

• User shall be treated fairly at all times
• Issues raised by users are always attended to with courtesy and on time
• Users are provided with effective and satisfactory resolution within a reasonable time period; and
• Users are fully informed of avenues to escalate their issues/grievances if they are not fully satisfied with the response to their complaints

Grievance Redressal:

Any user can reach out to our Grievance Redressal Officer through electronic mode by way of email communication.

11.2 Must Know

12. How Are Changes Made to This Policy?

This Policy may be updated at our sole discretion or due to changes in the law. Such changes, unless otherwise stated, will be effective from the day and date of posting on the Platform. We reserve the right to update the Policy without obligation to notify users. It is recommended to regularly review this Policy for any changes, as your continued access and use of the Platform and/or Services will be considered your approval and acceptance of all modifications to this Policy. In cases where applicable law mandates, we may notify you of updates through email or on the Platform. If you do not agree with this Policy governing our Platform and/or Services, please refrain from using the Platform and/or Services provided by us.