Privacy Policy

1. Who we are

Prashnottar Private Limited ("Prashnottar", "we", "us", "our") is a company incorporated in India that provides offline and online coaching for students preparing for NEET, JEE, CUET, CBSE/State Board Class 11 and 12, and related competitive examinations.

For the purposes of the Digital Personal Data Protection Act, 2023 ("DPDP Act"), Prashnottar Private Limited is the Data Fiduciary responsible for the personal data described in this policy. Students, parents, guardians, enquirers and website visitors are Data Principals.

2. Scope of this policy

This policy explains how we collect, use, store, share and protect personal data across all of the following:

• Our physical coaching centres, including admission counters, classrooms and premises under CCTV surveillance
• Our website and any enquiry, registration or contact forms on it
• Our mobile application available on Google Play Store
• Our marketing activities, including online advertising campaigns and telephone follow-up
• Any other interaction where we obtain personal data from you

This policy is published in compliance with the Digital Personal Data Protection Act, 2023; the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011; and the Consumer Protection Act, 2019, as applicable.

3. Personal data we collect

3.1 At our coaching centres and on enquiry

• Identity and contact details: name of student, name of parent or guardian, mobile number, alternate number, email address, residential address
• Academic details: current class, school or board, target examination, previous marks or scorecards, batch and course enrolled
• Identity documents: copies of documents such as Aadhaar, school ID card, birth certificate, marksheets or other proof submitted at the time of admission for verification of identity, age and eligibility
• Photographs: passport photographs for identity cards, attendance records and admission files
• Fee and payment records: amounts paid, dates, receipt numbers and payment method. Where payment is made online, card and bank details are handled directly by our payment gateway and are not stored by us
• Attendance, test performance and academic progress records

3.2 Through our website

• Details you enter into enquiry, callback, demo-class or registration forms: name, mobile number, email, class, target exam and city
• Technical data collected automatically: IP address, browser type, device type, operating system, pages visited, time spent, referring page and approximate location derived from IP address
• Cookie identifiers and advertising identifiers, as described in Section 9

3.3 Through our mobile application

• Account registration details: name, mobile number, email and password
• Learning activity: courses accessed, videos watched, tests attempted, scores and progress
• Device information: device model, operating system version, app version, crash logs and unique device identifiers
• Any permissions you grant within the app, which are requested only where required for a specific feature and which you may withdraw at any time through your device settings

3.4 Through advertising campaigns

When you respond to our advertisements on Google, Meta or other platforms — for example by submitting a lead form or clicking a call button — we receive the name, mobile number, email address and enquiry details you provide, together with information identifying which campaign generated the enquiry.

3.5 CCTV footage

Our coaching centres are under continuous video surveillance. Please see Section 7.

4. Children's data — parental consent

• At the time of admission, enquiry or app registration for a student under 18, we require the consent of a parent or lawful guardian. Consent is recorded on the admission form or through a verified parent mobile number, and is retained as a record.
• We verify the age of the student using the documents submitted at admission.
• We do not undertake behavioural or targeted advertising directed at children, and we do not track or profile children for advertising purposes.
• We do not process a child's personal data in any manner likely to cause a detrimental effect on the wellbeing of the child.
• Parents and guardians may at any time review, correct or request erasure of their child's data, and may withdraw consent, by contacting our Grievance Officer.

If we become aware that we have collected a child's personal data without valid parental consent, we will delete that data promptly.

5. Purposes for which we use personal data

We do not use your personal data for any purpose that is materially different from those listed above without informing you and, where required, obtaining fresh consent.

6. Legal basis and your consent

We process personal data on the following bases:

• Your consent, given freely, specifically and with clear notice — for example when you submit an enquiry form, enrol as a student, or agree to receive marketing communication. For students under 18, the consent of a parent or guardian is obtained.
• Performance of our contract with you — processing necessary to deliver the coaching services you have enrolled for.
• Certain legitimate uses permitted by law — including compliance with legal obligations and protection of safety on our premises.

You may withdraw your consent at any time. Withdrawal is as easy as giving consent: write to our Grievance Officer at the address in Section 15, or reply STOP to a marketing message. Withdrawal does not affect processing already carried out lawfully before withdrawal. Please note that if you withdraw consent necessary for delivering coaching services, we may be unable to continue providing those services, though we will retain records we are legally required to keep.

7. CCTV surveillance and photographs

• CCTV cameras operate in common areas of our coaching centres, including entrances, corridors, classrooms and reception areas, for the safety and security of students and staff and for the protection of property.
• Cameras are not installed in washrooms, changing areas or any other place where a person has a reasonable expectation of privacy.
• Signage is displayed at our premises indicating that the area is under CCTV surveillance.
• CCTV footage is retained for 30 days, after which it is automatically overwritten or deleted, unless it is required to be retained longer for an ongoing investigation, a complaint, a legal proceeding, or a lawful request from an authority.
• Access to footage is restricted to authorised personnel only. Footage is not published, shared on social media, or disclosed to any third party except law enforcement or authorities acting under lawful authority.
• Photographs collected at admission are used for identity cards, attendance and student records. We will use a student's photograph in publicity, advertising, social media or promotional material only with separate, specific written consent from the student and, where the student is under 18, from a parent or guardian. Such consent may be refused or withdrawn at any time without affecting the coaching services provided.

8. Telephone calls, SMS and WhatsApp communication

Where you have submitted an enquiry through our website, an advertisement, a lead form, or at one of our centres, we may contact you by telephone, SMS, WhatsApp or email to respond to that enquiry and to share information about our courses.

• Consent to receive promotional communication is obtained separately from consent to enrol, and is not a condition of admission.
• Before making promotional calls or sending promotional messages, we screen numbers against the National Customer Preference Register (DND registry) maintained under the Telecom Commercial Communications Customer Preference Regulations issued by TRAI, and we comply with applicable regulations on commercial communication.
• Calls may be recorded for quality and training purposes. Where a call is recorded, you will be informed at the start of the call.
• To stop receiving promotional communication, tell the caller, reply STOP to any promotional SMS or WhatsApp message, or write to our Grievance Officer. We will act on your request without undue delay. You will continue to receive essential service messages relating to your enrolment, such as fee receipts and schedule changes.
• We maintain records of the consent obtained from each person we contact, including the date, time and source of that consent.

9. Website cookies and Google advertising

9.1 Cookies

Our website uses cookies — small files stored on your device — to keep the site functioning, remember your preferences, measure traffic and, where you consent, support advertising. You may block or delete cookies through your browser settings. If you block essential cookies, parts of the website may not work correctly.

9.2 Google Analytics

We use Google Analytics to understand, in aggregate, how visitors use our website. This helps us improve our content and page performance. You may opt out using the Google Analytics Opt-out Browser Add-on.

9.3 Google Ads and third-party advertising

• Google's use of advertising cookies enables Google and its partners to serve advertisements to you based on your visit to our site and other sites on the internet.
• We use Google Ads conversion tracking and remarketing tags to measure the effectiveness of our campaigns. This may involve sharing limited data with Google as described in Google's own policies.
• You may opt out of personalised advertising by visiting Google Ads Settings, or opt out of some third-party vendors' use of cookies at www.aboutads.info/choices.
• For details of how Google handles data from sites that use its services, see Google's policy on partner sites.
• We do not direct personalised or behavioural advertising at users we know to be under 18.

Third-party advertisers operate under their own privacy policies, which we do not control. We encourage you to review them.

10. Our mobile application

• The Prashnottar application is distributed through the Google Play Store and is governed by this policy in addition to Google Play's own terms.
• The app collects the account, learning-activity and device information described in Section 3.3.
• Any device permission — such as storage, camera or notifications — is requested only where a specific feature requires it, with an explanation at the time of the request. You may decline or later revoke any permission through your device settings, though the related feature may then not function.
• You may request deletion of your app account and associated data at any time by writing to our Grievance Officer. We will delete the data except where retention is required by law.

11. Sharing and disclosure of personal data

We do not sell your personal data to anyone. We share personal data only in the following circumstances:

• Service providers acting on our instructions — such as payment gateways for online fee collection, SMS and communication service providers, cloud hosting providers, and analytics and advertising platforms. These providers are permitted to use the data only for the purpose of providing the service to us, and are bound by confidentiality and data protection obligations.
• Parents and lawful guardians — academic, attendance and fee information of a student is shared with the parent or guardian associated with that student's record.
• Legal and regulatory disclosure — where required by law, by a court order, or by a lawful request from a government or law enforcement authority, and to establish, exercise or defend legal claims.
• Business transfer — in the event of a merger, acquisition or restructuring, data may transfer to the successor entity, which will remain bound by this policy or a policy offering equivalent protection. You will be notified of any such change.

Some of our service providers may process or store data on servers located outside India. Where this occurs, we ensure that transfers are made in accordance with the DPDP Act and any restrictions notified by the Central Government.

12. Data retention

When personal data is no longer required for the purpose for which it was collected and retention is not required by law, we erase it or anonymise it so that it can no longer identify you.

13. How we protect your data

We implement reasonable security safeguards appropriate to the nature of the data we hold, including:

• Restricting access to student records and CCTV footage to authorised personnel on a need-to-know basis
• Password protection and access controls on our systems and databases
• Secure storage of physical admission files and documents at our centres
• Confidentiality obligations imposed on employees, counsellors and telecalling staff
• Use of reputed third-party payment gateways so that card and banking details are not stored on our systems

In the event of a personal data breach, we will notify the Data Protection Board of India and affected Data Principals as required under the DPDP Act.

While we take these measures seriously, no method of electronic storage or transmission is entirely secure, and we cannot guarantee absolute security.

14. Your rights as a Data Principal

Under the DPDP Act, 2023, you have the following rights in relation to your personal data:

• Right to access — to obtain a summary of the personal data we hold about you, how it is processed, and the identities of parties with whom it has been shared
• Right to correction and erasure — to have inaccurate or misleading data corrected, incomplete data completed, data updated, and data erased where it is no longer required and retention is not legally mandated
• Right to withdraw consent — at any time, as easily as it was given
• Right to grievance redressal — to raise a complaint with our Grievance Officer, as set out below
• Right to nominate — to nominate another individual to exercise these rights on your behalf in the event of your death or incapacity

Parents and guardians may exercise these rights on behalf of a student under 18. To exercise any right, write to our Grievance Officer with sufficient detail for us to identify your record. We will respond within the timelines prescribed by law.

Please note that you are expected to furnish only authentic information and not to impersonate another person or suppress material information when exercising these rights.

15. Grievance redressal

If you have any question, concern or complaint about how we handle your personal data, please contact our Grievance Officer. We take every complaint seriously and will respond promptly.

We will acknowledge your complaint on receipt and aim to resolve it within the period prescribed under applicable law. If you are not satisfied with our response, you may escalate the matter to the Data Protection Board of India established under the Digital Personal Data Protection Act, 2023.

16. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices, our services, or the law. The revised policy will be posted on this page with an updated effective date. Where changes are significant, we will notify you through the app, by email, or by a notice at our centres. We encourage you to review this page periodically.

17. Governing law and jurisdiction

This Privacy Policy is governed by and construed in accordance with the laws of India. Any dispute arising out of or in connection with this policy shall be subject to the exclusive jurisdiction of the competent courts at Lucknow, Uttar Pradesh.