LEARN2READ PRIVACY POLICY
Effective Date: 1st September 2026
Version: 1.0
1. INTRODUCTION
This Privacy Policy ("Policy") forms an integral part of and shall be read in conjunction with the Platform’s Terms and Conditions available at https://www.learn2read.co/terms-and-conditions, and governs the collection, use, storage, processing, disclosure, and transfer of Personal Data by SchoolHome Educare Private Limited, (“LEARN2READ”, "we", "us", or "our") in connection with your access or use of our e-learning platform, mobile application and related services (collectively, the "Platform").
We understand the importance of protecting the Personal Data of the Parents/Guardians, children whose profiles are created and managed by Parents/Guardians, and instructors interacting with the Platform (hereinafter referred to as “you”, “User”, “Data Subject”, “Data Principal”). This Privacy Policy outlines how we process any Personal Data collected from you by accessing, browsing and/or using the Platform. This Privacy Policy applies to activities that a Data Subject engages in on this Platform and does not apply to LEARN2READ’s activities that are "offline" or unrelated to the Website.
LEARN2READ was established with the objective of supporting young learners at the early stages of their language development. Today, it serves a global community of users across multiple countries, delivering interactive and engaging learning experiences. The Platform is designed for children under the age of eighteen (18) years and is accessed and managed exclusively by parents or legal guardians (“Parent/Guardian”). For the purposes of this Policy, LEARN2READ acts as the Data Controller/ Data Fiduciary in respect of Personal Data collected through the Platform.
Any capitalised terms used in this Privacy Policy shall have the meanings ascribed to them under applicable Data Protection laws and regulations.
2. SCOPE OF APPLICATION
This Policy applies to:
1) All individuals who access or use the Platform, including Parents/Guardians registering on behalf of children on the Platform, Child/student profiles created and operated under parental control and Instructors engaged or applying for the position with LEARN2READ;
2) Personal Data collected through the Platform, including during account registration, browsing, registration form, payment processing, enquiry, marketing communications, educational updates, promotional offers and applying for a position;
3) Processing activities carried out by LEARN2READ in its capacity as Data Controller, and by its authorised Data Processors acting on its instructions.
3. LEGAL BASIS FOR PROCESSING
We will only process your Personal Data where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your Personal Data. Processing of Personal Data is conducted on one or more of the following recognised basis:
3.1 Explicit Consent
Where you have provided your free, specific, informed, unconditional and unambiguous consent to the processing of your Personal Data for one or more specified purposes. Where the Data Subject is a minor, consent shall be obtained from and exercised by the Parent/Guardian on behalf of the child, in accordance with the minimum age of consent applicable in the relevant jurisdiction.
You may withdraw consent at any time by contacting us or using the unsubscribe mechanisms provided on the Platform, without affecting the lawfulness of processing carried out prior to withdrawal. Where Sensitive Personal Data is processed, consent shall be obtained in accordance with applicable laws.
3.2 Performance of a Contract
Where processing is necessary for the conclusion, execution or performance of a contract to which you are a party, we process Personal Data strictly for purposes that are essential to deliver the services requested by you, including account creation and management, enrolment in courses offered through the Platform, scheduling and delivery of online learning sessions, interaction with instructors, payment processing, and provision of customer support services.
3.3 Legal Obligation
Where processing is necessary for compliance with a legal obligation imposed upon LEARN2READ under applicable privacy laws.
3.4 Vital Interests
Where processing is necessary to protect the vital interests of the Data Subject or of another natural person, including ensuring the safety, security, and well-being of users during participation in online learning sessions offered through the Platform, particularly in situations where consent cannot reasonably be obtained in a timely manner.
3.5 Legitimate Interests
LEARN2READ may process Personal Data based on its legitimate interests or those of a third party, provided such interests are not overridden by the interests, rights, or freedoms of the Data Subject. Where it is necessary for us to understand our Data Subject, promote our services, and effectively provide services, provided in each case that it is done in a legitimate way that does not duly affect your privacy and other rights. However, it shall not be relied upon as a lawful basis for processing Personal Data of children for analytics, profiling, or behavioural tracking, except where such processing is strictly necessary for the provision of core functionality of the service or platform security.
Where reliance is placed on legitimate interests:
A documented balancing assessment shall be conducted;
Processing shall be proportionate and limited to what is necessary;
Data Subjects retain the right to object to such processing where applicable.
Legitimate interests may include platform safety and child protection during online sessions, fraud prevention, network security, internal analytics, and enhancing the effectiveness of educational content and delivery.
4. CATEGORIES OF PERSONAL DATA COLLECTED
LEARN2READ collects the following categories of Personal Data through the Platform:
4.1 Identity and Contact Data
Child/Student Information:
1) Full name
2) Date of Birth
3) Age
4) School Name
5) Residential address (country, state, city, pin/zip code)
Parent/ Guardian Information:
1) Full name
2) Email ID
3) Mobile No.
4) Residential address (country, state, city, pin/zip code)
5) Government-issued identity documents such as Aadhaar Card, PAN Card, Passport, Driving Licence, Voter ID or any other identity document submitted for verification purposes.
Instructor Information:
1) Full Name
2) Email ID
3) Mobile No.
4) CV/Resume
5) Residential address (country, state, city, pin/zip code)
4.2 Account Data
1) Student ID
2) Username and hashed password
3) Account preferences and settings
4) Course Enrolment details
5) Scheduling preferences (preferred days, time slots, session type)
4.3 Payment and Financial Data
1) Payment card details are processed exclusively by authorised third-party payment gateways. LEARN2READ does not store full payment card information on its systems and only retains limited transaction references necessary for reconciliation and support purposes.
2) Transaction identifiers and confirmation numbers
3) Country from which payment is made
4) Mode of payment (credit card, debit card, net banking, UPI, wallet, etc.)
5) Currency of payment
4.4 Technical and Device Data
1) IP address (Where Technical and Device Data is collected during sessions accessed by or on behalf of a child/student, such collection shall be limited to what is strictly necessary for platform security and session delivery, and shall not be used for behavioural profiling or targeted advertising)
2) Browser type and version
3) Operating system and device type
4) Session data and access logs
5) Cookie identifiers (refer to Clause 9 of this Policy)
4.5 Usage and Behavioural Data
1) Course preferences and selected subjects
2) Participation in sessions and learning activities
3) Interaction with instructors and platform features
4) Platform navigation and usage patterns
5) Search queries submitted on the Platform
4.6 Communications Data
1) Customer support queries and correspondence
2) Feedback, reviews, and survey responses submitted voluntarily
3) Communication preferences (educational updates, notifications, promotional messages, WhatsApp communication)
4) Records of complaints or dispute resolution interactions
5. METHODS OF COLLECTION
LEARN2READ collects Personal Data through lawful and transparent means and only to the extent necessary for the purposes described in this Policy. Personal Data may be collected through the following methods:
5.1 Direct Collection
Information you voluntarily provide when you register or create an account, place an order, fill out the student registration form, book or schedule trial classes or regular learning sessions, complete a payment transaction, subscribe to marketing communications, contact customer support, submit reviews and feedback, respond to surveys, apply for instructor position, assessments, or onboarding interactions, participate or otherwise interact with the Platform or through social networking Websites, Third-Party applications including but not limited to video conferencing tools, payment gateways, analytics tools, educational gaming tools, YouTube/social media, CRM tools, WhatsApp Cloud API or similar technologies.
5.2 Automated Collection
Certain technical data and usage data are collected automatically when you access or interact with the Platform using cookies, web beacons, pixel tags, analytics tools and similar tracking technologies.
Such data may include IP address, device identifiers, browsing behaviour, session data, and interaction metrics.
Automated Collection is used for platform functionality and secure access to sessions, fraud prevention, performance analytics, monitoring class participation and system performance, service improvement, personalisation based on your consent where permitted by law.
Further details are provided in Clause 9 (Cookies and Tracking Technologies). Where legally required, cookie-based tracking for marketing purposes is implemented only after obtaining appropriate consent.
5.3 Third-Party Sources
LEARN2READ may receive Personal Data from authorised third-party payment processors, video conferencing platforms used to conduct live classes and marketing service providers to the extent necessary to fulfil operational and contractual obligations. Such third parties are required to share Personal Data with LEARN2READ only in accordance with applicable laws and their own data protection obligations.
LEARN2READ does not acquire Personal Data from third-party data brokers for unrelated marketing purposes.
6. PURPOSE LIMITATION AND DATA MINIMISATION
LEARN2READ shall collect and process Personal Data for the specific, explicit, and legitimate purposes described in this Policy and in accordance with the lawful bases set out in Clause 3.
Personal Data shall be collected and processed only to the extent that it is necessary, relevant, and proportionate to the specific purpose for which it is obtained, and shall not be further processed in any manner that is incompatible with such original purpose.
6.1 Provision of Educational Services
To enrol students in courses, schedule and conduct online learning sessions, facilitate interaction with instructors, and deliver structured educational content through the Platform.
6.2 Account Management
To create, maintain, and manage Parent/Guardian-controlled accounts, including login credentials, student profiles, course preferences, and session scheduling.
6.3 Payment Processing
To process payments for courses and services through authorised third-party payment gateways and to maintain transaction records for verification and support purposes.
6.4 Communication and Customer Support
To communicate with Parents/Guardians regarding enrolments, schedules, updates, and respond to queries, feedback, or support requests.
6.5 Safety, Monitoring, and Child Protection
To ensure a safe and secure learning environment, including monitoring sessions, maintaining recordings (as required under applicable law), and preventing misuse of the Platform.
Where online sessions are recorded:
(a) such recording shall be carried out only where necessary for quality control, safety, educational research, marketing and promotional activities;
(b) parental consent shall be obtained prior to any recording of sessions involving children, in accordance with applicable data protection laws;
(c) access to recordings shall be restricted to authorised personnel; and
(d) recordings shall be retained only for the period specified in Clause 12.
6.6 Platform Security and Fraud Prevention
To monitor, detect, investigate, and prevent fraudulent transactions, payment misuse, unauthorised access, cyber threats, and other activities that may compromise the security of the Platform or its users.
6.7 Service Improvement and Analytics
To analyse usage patterns, evaluate learning outcomes, improve course delivery, improve the Platform's functionality, and develop new features, subject to applicable consent requirements.
6.8 Marketing Communications [Subject to Consent]
LEARN2READ may send promotional communications, educational updates, newsletters, offers, and other marketing communications relating to its services only where the Parent/Guardian has provided prior consent.
For new accounts, marketing consent may be obtained at the time of registration or account creation. For existing accounts, LEARN2READ shall seek fresh marketing consent through a re-permission communication requiring an action to opt in. Parent/Guardian who do not provide such consent shall not receive marketing communications.
Parent/Guardians may withdraw their consent to marketing communications at any time by contacting LEARN2READ through the contact details provided in this Policy.
6.9 Legal Compliance
To comply with applicable laws, regulatory requirements, court orders, and governmental or law enforcement directives applicable across relevant jurisdictions.
7. SENSITIVE PERSONAL DATA
Applicable data protection laws impose heightened obligations in respect of Sensitive Personal Data, which includes Personal Data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, biometric data, health or medical data, sexual orientation, and criminal records or any other information that may be considered sensitive under applicable data protection principles.
LEARN2READ does not intentionally collect Sensitive Personal Data through the ordinary operation of the Platform. In the event that any such data is incidentally collected, it will be processed only on the basis of explicit consent of the Parent/Guardian or where necessary to ensure the safety, well-being, or protection of the child/student, or as otherwise permitted under generally accepted data protection principles.
Payment and financial-related information, whilst subject to enhanced security measures, is processed exclusively by third-party payment gateways. Learn2Read does not store or process full payment card details on its own systems, and such processing is carried out in accordance with applicable security standards.
8. CHILDREN'S DATA
The Platform is directed at and is intended for use by individuals under the age of eighteen (18) years. However, all access to and use of the Platform shall be strictly controlled, supervised, managed, and authorised by a Parent/Guardian.
The minimum age of digital consent shall be determined in accordance with applicable laws of the relevant jurisdiction from which the Platform is accessed, and where a higher threshold is prescribed, such threshold shall apply.
LEARN2READ does not permit children to independently create accounts or provide Personal Data. All Personal Data relating to a child/student is collected, submitted, and managed solely by the Parent/Guardian.
Personal Data of children/students shall be processed strictly for the provision of educational services, ensuring platform safety and functionality, and improving educational delivery, and shall not be used for behavioural profiling or targeted advertising.
In the event that a Parent/Guardian becomes aware that Personal Data of child has been provided to or collected by LEARN2READ without the required parental or guardian consent, the Parent/Guardian may promptly notify LEARN2READ’s Grievance Officer, whose details are set out in Clause 21 of this Policy. Similarly, if a child has independently provided Personal Data through the Platform without the involvement or authorisation of a Parent/Guardian, the Parent/Guardian may inform LEARN2READ of the same without delay. Upon receipt of such information and subject to verification of the identity and authority of the requesting person, LEARN2READ shall, in accordance with applicable law, take reasonable steps to address the request.
9. COOKIES AND TRACKING TECHNOLOGIES
The Platform uses cookies and similar tracking technologies, including web beacons and pixel tags, to enhance user experience, maintain session continuity, analyse Platform usage, and support security functions. A cookie is a small text file stored on your device upon your visit to the Platform. Cookies may be session-based (deleted when you close your browser) or persistent (remaining on your device for a defined period).
9.1 Use of Cookies
Cookies and similar technologies, including web beacons and pixel tags, are used to:
1) ## Ensure proper functioning of the Platform
2) ## Enable secure login and account authentication for Parents/Guardians
3) ## Maintain session continuity during classes and platform access
4) ## Ensure smooth functioning of course pages and scheduling systems
5) ## Protect against fraudulent or unauthorised activity
6) ## Analyse Platform usage and performance
7) ## Personalisation does not involve behavioural profiling of children.
8) ## Deliver marketing communications and updates (where permitted)
9.2 Categories of Cookies Used
1) Strictly Necessary Cookies: Essential to the operation of the Platform, including session management and security. These cookies do not require your consent as they are technically necessary for the Platform to function. For example, they enable secure log-in sessions or form submissions.
2) Functional Cookies: Used to remember your preferences and settings on the Platform (such as language preferences and account login state) and provide enhanced features.
3) Analytics Cookies: Used to collect aggregated, anonymised information about how users interact with the Platform, to enable LEARN2READ to improve Platform performance and usability.
4) Marketing and Targeting Cookies: Used to deliver relevant advertising and to track the effectiveness of marketing campaigns. Marketing and Targeting Cookies shall not be placed in any session attributable to or accessed by a child or student, regardless of consent. This prohibition applies whether the child accesses the Platform directly or through a shared device. For sessions attributable to a Parent or Guardian only, Marketing and Targeting Cookies may be placed upon explicit prior consent, obtained through the cookie consent mechanism described at Clause 9.3. Such consent may be withdrawn at any time without affecting the lawfulness of processing carried out prior to withdrawal. Where Marketing and Targeting Cookies are placed by third-party providers in Parent/Guardian sessions, those providers act as independent controllers in respect of such cookies. LEARN2READ does not control and accepts no responsibility for the data practices of such third parties. Please refer to Clause 9.4 and the relevant third party's privacy policy.
9.3 Cookie Consent and Management
Upon your first visit to the Platform, you will be presented with a cookie consent banner. It shall apply only to Parent/Guardian users and shall not be presented within child/student interfaces. Non-essential cookies shall be disabled by default for child sessions. You may accept or reject non-essential cookies at that time, and may update your cookie preferences at any time through the cookie banner and browser settings available on the Platform.
Please note that disabling certain cookies may affect the functionality of the Platform.
9.4 Third-Party Services
Some applications may integrate with third-party tools (such as payment gateways, video conferencing, or analytics providers). These third parties may also set cookies in accordance with their own privacy policies. We encourage you to review those policies where applicable.
10. DATA SHARING AND DISCLOSURE
LEARN2READ does not sell, license, rent, or trade Personal Data to third parties for any independent commercial or marketing purposes. Personal Data may be disclosed only where necessary, proportionate, and supported by a lawful basis under applicable law.
10.1 Service Providers and Data Processors
LEARN2READ engages authorised third-party service providers who act as Data Processors on our behalf, including:
1) Payment gateway operators for the processing of payment transactions;
2) Video conferencing platforms for conducting live online classes;
3) Cloud hosting and IT infrastructure providers;
4) Email and marketing communication service providers (subject to consent);
5) Analytics service providers.
All Data Processors are contractually required to process Personal Data only on LEARN2READ's documented instructions, to implement appropriate technical and organisational security measures, and to comply with applicable data protection law. LEARN2READ remains responsible for the lawfulness of processing conducted by its Data Processors. Data Processors are not permitted to use Personal Data, including children’s data, for their own purposes, including profiling, analytics beyond instructed purposes, or targeted advertising.
10.2 Instructors and Academic Personnel
Personal Data may be shared with instructors solely for the purpose of delivering courses, conducting sessions, monitoring progress, and ensuring a safe and effective learning environment. It shall be subject to written confidentiality and data protection obligations no less stringent than those set out in this Policy.
10.3 Legal and Regulatory Disclosure
LEARN2READ may disclose Personal Data to competent governmental authorities, regulatory bodies, courts, or law enforcement agencies where required to do so by applicable law, lawful order, or governmental directive across relevant jurisdictions.
10.4 Business Transfers
In the event of a merger, acquisition, reorganisation, or sale of LEARN2READ's business or assets, Personal Data may be transferred to the relevant successor entity, provided that such transfer is subject to equivalent data protection safeguards and that Data Subjects are notified in advance where required across relevant jurisdictions.
10.5 Protection of Rights
LEARN2READ may disclose Personal Data where it reasonably believes disclosure is necessary to protect the rights, property, or safety of children/students, Parents/Guardians, or instructors, and third parties, or to prevent fraud or other illegal activity.
10.6 Independent Controllers
"LEARN2READ shall take reasonable steps to ensure that third parties processing Personal Data as independent controllers maintain data protection standards appropriate to the nature of the data processed, particularly in respect of children.
Where such processing occurs, it is governed by the respective third party’s privacy policy and legal obligations.
11. CROSS-BORDER TRANSFERS OF PERSONAL DATA
11.1 Transfer Framework
LEARN2READ operates as a global e-learning platform, and Personal Data may be transferred to, stored, and processed in multiple jurisdictions where LEARN2READ, its affiliates, or its authorised service providers are located.
Any such cross-border transfer of Personal Data is conducted in strict compliance with applicable data protection laws, and such transfers may occur in connection with account management, course delivery, customer support, payment processing, data storage, and platform operations.
11.2 Adequacy Determinations
As of the effective date of this Policy, LEARN2READ will conduct transfers to third countries only where the receiving jurisdiction has been determined to provide an adequate level of data protection, or where appropriate safeguards are in place as described below.
11.3 Appropriate Safeguards
Where Personal Data is transferred to a jurisdiction that has not been determined to provide an adequate level of data protection, LEARN2READ shall ensure that appropriate safeguards are implemented prior to the transfer, which may include:
1) Standard contractual clauses or data transfer agreements approved or recognised under applicable data protection laws;
2) Binding corporate rules (as required under applicable laws);
3) Explicit consent of the Data Subject to the proposed transfer, following disclosure of the risks involved; or
4) Other safeguards as may be recognised under applicable data protection laws and their implementing regulations.
12. DATA RETENTION
Personal Data is retained only for as long as is necessary to fulfil the purposes for which it was collected, as set out in Clause 6, or as required by applicable law. The following retention principles apply:
1) Account and student data will be retained for the duration of the active account of the children by the Parent/Guardian and for a period not exceeding three (3) years, following account deletion or deactivation;
2) Course and Session data, including recordings, will be retained for a period not exceeding two (2) years, unless required for legal or safeguarding purposes.
3) Payment and Transaction data will be retained for a minimum period of five (5) years following the completion of the relevant transaction, or such longer period as may be required for regulatory compliance;
4) Customer service and communications data will be retained for a period of two (2) years following the resolution of the relevant enquiry or matter;
5) Personal Data relating to child/student sessions, including session recordings, shall be retained only for the minimum period necessary for the specified purpose and, as required under applicable law, for safeguarding or dispute resolution, and shall be subject to shorter retention periods than general account data;
6) Personal Data relating to instructors shall be retained for the duration of their engagement and thereafter in accordance with applicable law. Personal Data of unsuccessful instructors shall be retained for a period not exceeding six (6) months from the date of the recruitment decision, unless a longer retention period is required for compliance with legal obligations;
7) Technical and device data collected for security and fraud prevention purposes will be retained for a period not exceeding two (2) years;
8) Marketing data, including consent records, will be retained for the period of active consent and for a reasonable period thereafter as evidence of compliance.
Upon expiry of the applicable retention period, Personal Data will be securely deleted or irreversibly anonymised in accordance with LEARN2READ's internal data disposal procedures.
13. DATA PROTECTION IMPACT ASSESSMENTS (DPIA)
LEARN2READ shall conduct Data Protection Impact Assessments (DPIAs) for processing activities involving Personal Data where such processing is likely to result in a high risk to the rights and freedoms of Data Subjects, including but not limited to large-scale processing, systematic monitoring, or use of new or emerging technologies.
14. DATA SECURITY
LEARN2READ implements appropriate technical and organisational security measures to protect Personal Data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Such measures include, but are not limited to:
1) Encryption of Personal Data in transit using industry-standard Transport Layer Security (TLS) protocols, including payment card data processed through third-party gateways;
2) Encryption of Personal Data stored on LEARN2READ servers, databases, or backup systems, including sensitive and financial data, using industry-standard encryption protocols;
3) Access controls restricting access to Personal Data to authorised personnel on a need-to-know basis;
4) Regular security assessments and vulnerability reviews of the Platform's infrastructure;
5) Use of compliant third-party payment processors to handle full payment card data;
6) Incident response procedures and breach notification protocols in accordance with the applicable data protection laws.
7) LEARN2READ shall implement additional safeguards appropriate for children’s data, including restricted access to session recordings, instructor-level access controls, and periodic review of access logs.
We restrict access to your Personal Data to our affiliates, employees, instructors, Third-Party service providers, partners, and agencies on a need-to-know basis and absolutely limited to the purposes as specified above in this Policy.
Notwithstanding the above, no method of electronic transmission or data storage is entirely secure, and LEARN2READ cannot guarantee the absolute security of Personal Data transmitted via the internet. Data Subjects are encouraged to take appropriate steps to protect their account credentials and to contact LEARN2READ immediately if they suspect any unauthorised access to their account.
15. DATA BREACH NOTIFICATION
In the event of a Personal Data breach, LEARN2READ shall:
(a) assess the nature and impact of the breach;
(b) notify the relevant supervisory authority within the timeframe required under applicable laws and relevant jurisdictions; and
(c) notify affected Parents/Guardians where the breach is likely to result in a risk to the rights of the child/student.
16. DATA SUBJECT/DATA PRINCIPAL RIGHTS
In accordance with applicable data protection laws, Data Subjects/Data Principals whose Personal Data is processed by LEARN2READ are entitled to exercise the following rights:
16.1 Right to Access Information
You have the right to obtain confirmation as to whether your Personal Data is being processed, and to access a copy of the Personal Data held about you, together with information regarding the purposes and nature of such processing.
16.2 Right to Correction
You have the right to request the correction of inaccurate or incomplete Personal Data held about you without undue delay.
16.3 Right to Erasure
You have the right to request the deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, where consent has been withdrawn, and there is no other lawful basis for processing, or where the processing is unlawful, subject to LEARN2READ's legal retention obligations.
16.4 Right to Restriction of Processing
You have the right to request that LEARN2READ restricts the processing of your Personal Data where:
(a) the accuracy of the Personal Data is contested;
(b) the processing is unlawful, and you oppose erasure;
(c) LEARN2READ no longer requires the data, but it is required for legal claims; or
(d) you have objected to processing pending verification of overriding grounds.
16.5 Right to Data Portability
To the extent recognised under applicable data protection laws and their implementing regulations, you may have the right to receive your Personal Data in a structured, commonly used, machine-readable and easy-to-read format and to request its transmission to another Data Controller where technically feasible.
16.6 Right to Object and Stop Processing
You have the right to object to the processing of your Personal Data where such processing is based on legitimate interests or is carried out for direct marketing purposes. Where you object to direct marketing, LEARN2READ will cease processing your Personal Data for such purposes.
16.7 Right to Withdraw Consent
Where processing of Personal Data is based on your consent, you have the right to withdraw such consent at any time without affecting the lawfulness of processing carried out prior to such withdrawal.
Parent/Guardians may withdraw consent from processing Personal Data (including marketing communications) through the consent withdrawal form available on the Platform or by submitting a request to LEARN2READ’s Grievance Officer, whose details are provided in Clause 21 of this Policy.
Withdrawal requests shall be recorded and processed across applicable communication systems within twenty-four (24) hours of receipt of the request, wherever technically feasible.
16.8 Right in Relation to Automated Decision-Making
You have the right not to be subject to a decision solely based on Automated Processing, including profiling, which produces legal effects or otherwise significantly affects you.
16.9 Right of Grievance Redressal
You have the right to seek grievance redressal in relation to any concerns regarding the processing of your Personal Data, including refusal or inadequate response to the exercise of your rights under this Policy. Such grievances may be submitted in accordance with the grievance redressal mechanism set out in Clause 18 of this Policy.
16.10 Right to Nominate
Where applicable under Indian data protection laws, a Data Principal may nominate another individual to exercise their rights in the event of death or incapacity, in the manner prescribed under applicable laws.
17. HOW TO EXERCISE YOUR RIGHTS
To exercise any of the rights set out in Clause 16, Data Subjects may submit a written request to LEARN2READ using the contact details provided in Clause 21 of this Policy. Requests should clearly identify the Data Subject, the right being exercised, and the Personal Data to which the request relates.
LEARN2READ will acknowledge receipt of your request within 5 business days and will respond substantively within 30 days (extendable where permitted by law). LEARN2READ reserves the right to verify the identity of the requesting individual prior to responding to any rights request.
LEARN2READ will not ordinarily charge a fee for the handling of valid rights requests. However, where requests are manifestly unfounded or excessive, LEARN2READ reserves the right to charge a reasonable administrative fee or to refuse to respond, in accordance with the applicable data protection laws.
18. COMPLAINTS AND SUPERVISORY AUTHORITY
If you believe that LEARN2READ has processed your Personal Data in a manner inconsistent with the applicable data protection laws, you may submit a complaint to LEARN2READ using the details provided in Clause 21. LEARN2READ will acknowledge the complaint within 5 business days and provide a substantive response within 30 days of receipt of the grievance, unless a longer period is permitted under applicable law.
If you are not satisfied with LEARN2READ's response, or if you wish to escalate your complaint, you have the right to lodge a complaint with a relevant data protection authority or supervisory body in your country of residence, in accordance with applicable laws.
Given the global nature of the Platform, Personal Data may be processed across multiple jurisdictions. Accordingly, any complaints or disputes may be subject to the laws and regulatory frameworks applicable in the relevant jurisdiction.
19. THIRD-PARTY LINKS
The Platform may contain hyperlinks to third-party websites, applications, or services that are not operated by LEARN2READ. LEARN2READ has no control over, and accepts no responsibility for, the data protection practices or privacy policies of such third parties.
LEARN2READ encourages Data Subjects to review the privacy policies of any third-party platforms they visit via links on the Platform. The inclusion of a link to a third-party site does not constitute an endorsement by LEARN2READ of that site's data practices.
20. AMENDMENTS TO THIS POLICY
LEARN2READ reserves the right to amend or update this Policy at any time to reflect changes in its data processing activities, changes in applicable laws, or regulatory guidance issued by the competent authority under applicable data protection laws.
Material amendments to this Policy will be communicated to registered Data Subjects/Data Principals by email or by a prominent notice on the Platform at least 7 days prior to the amendment taking effect, where practicable. Where any amendment materially affects the processing of children’s Personal Data, LEARN2READ shall obtain fresh consent from Parents/Guardians prior to such changes taking effect.
The current version of this Policy is identified by the version number and effective date published at the top of this document.
21. CONTACT DETAILS FOR DATA PROTECTION INQUIRIES
For any questions, concerns, or requests relating to this Policy or to LEARN2READ's processing of your Personal Data, including the exercise of Data Subject rights, please contact:
Data Protection Contact
Data Protection/Grievance Officer: Sushmita Goswami
Email: sushmita.goswami@learn2read.co
Telephone number: +91 89059 97544
Working Hours: [[ INSERT WORKING HOURS ]]
All correspondence should be clearly marked: "Data Protection Inquiry – LEARN2READ" to facilitate prompt handling.
LEARN2READ will make reasonable efforts to respond to all data protection-related queries in a timely and transparent manner.
This Privacy Policy was prepared in accordance with applicable data protection laws.
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