Privacy Policy

The mobile application [School of Meaningful Experiences] (“Platform”) is owned and operated by School of Meaningful Experiences Private Limited (“Company”), a company incorporated under the laws of India, and having its registered office at No. 681, 10 th Main, 4^th B Cross, Koramangala, 4^th Block, Bengaluru – 560 034. The Company, through the Platform, provides the services set out in [https://www.some.education.] (“Services”)

For the purposes of this Privacy Policy (“Policy”), “we”, “our” and “us” shall mean the Company and “you” and “your” shall mean you as a Registered User (as defined below) of the Platform. The capitalized terms that are used in this Policy but not defined herein shall have the same meaning as defined in the Terms of Use of the website https://some.education/ (“Website”) owned and operated by us

This Policy covers our policies and practices regarding collection, use and disclosure of personal information we receive about you when you use our Services, or otherwise interact with us on the Platform. This Policy does not apply to websites or the practices of companies that the Company does not own or control, or to individuals that the Company does not employ or manage, such as the third party links on the Platform and third parties who publish their content via the Services provided to the Registered Users.

We hold the sincere belief that you should always know what data we collect from you, the purposes for which such data is used, and that you should have the ability to make informed decisions about what data you want to share with us. This is why we want to be fully transparent about: (i) how and why we collect, store, share and use your personal data through the various capacities in which you interact with us; and (ii) the rights that you have to determine the parameters of this interaction.

While we would strongly advise you to read the Policy in full, the following summary will give you a snapshot of the salient points covered herein:

• Your personal data relationship with the Company varies based on the capacity in which you interact with us/avail our Services. You are most likely to be a person who has an account on the Platform to avail our Services (“Registered User”).
• Based on you being a Registered User, the type of data we collect and the purpose for which we use is detailed in this Policy.
• This Policy is a part of and should be read in conjunction with Terms of Use of our Website. This Policy will clarify the rights available to you vis-à-vis the personal data you share with us.

If you have any queries or concerns with this Policy, please contact our Grievance Officer.
Please use our Services or visit the Platform, only if the terms of this Policy are acceptable to you.

• 1. REGISTERED USER INFORMATION AND HOW WE USE IT
• 1.1 We will collect the following information from a Registered User of the Platform:
• 1.1.1 Your IP Address;
• 1.1.2 Your location unless you deactivate location services in the relevant section of the Platform;
• 1.1.3 The device you use to access the Platform and its details (model, operating system etc.);
• 1.1.4 Cookies and web beacon data through a webview;
• 1.1.5 Your name, age, gender, phone number and e-mail address;
• 1.1.6 Your school / college details;
• 1.1.7 Your photo display name, job title and other details to be displayed on the Platform;
• 1.1.8 Information submitted to our customer support, such as contact information, problem summary, and any other documentation, screenshots or information that would be helpful in resolving an issue submitted;
• 1.1.9 Your username or other relevant unique identifier; and
• 1.1.10 Your payment information to facilitate payments for goods and Services sold on the Platform.
• 1.2 The above information we collect from a Registered User of the Platform is used in order to help you register for and facilitate provision of our Services. We do not sell your personal information to any Registered User or third party. We may use this data to show age appropriate content and advertisements.
• 1.3 We use the data from the device you access our Platform to identify the login information of multiple Users from the same device. We also use the data provided by the Registered User for the following purposes: (i) to enable you to make payments for our Services; We use a third-party service provider to manage payment processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of payment processing on our behalf; (ii) to process your requests, enquiries and complaints, customer services and related activities; (iii) for invitations and communications promoting membership and network growth, engagement and our Services, such as by showing your connections that you have used a feature on our Services; (iii) to communicate existing or new offers, content, advertisements, surveys, key policies or other administrative information; (iv) to provide you with informative features and services that are developed by us from time to time; (v) for providing, testing, improving, or recommending the Services; (vi) for analytics and reviews to improve the Services; and/or (vii) to provide support to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law or anti-fraud activities/systems.
• 1.4 If you give us your consent, we may send you newsletters and emails to market other products and services that we may provide from time to time. You may opt out of our marketing emails by clicking on the ‘opt-out’ link provided in the emails. However, we may still send you non-marketing transactional emails about your account with us.
• 1.5 We collect personal data from you when you provide, post or upload it on the Platform, such as when you fill out a form, (e.g., with demographic data or educational details), respond to a survey regarding our Services. If you opt to import your address book, we receive your contacts, including contact information of your service provider(s) that have been automatically added to your address book prior to using the Platform.
• 1.6 If you sync your contacts or calendars with our Services, we will collect your address book and calendar meeting information to keep growing your network by suggesting connections for you and others, and by providing information about events, for example, times, places, attendees and contacts.
• 1.7 You don’t have to post or upload personal data. In case you decide against it, we will continue to provide Services; however, their scope may be limited and your ability to make full use of our Services may be limited.
• 2. COMPLIANCE WITH MINORS’ RIGHTS
• 2.1 For rendering the Services, we will need to collect personal data of minors i.e. individuals under the age of 18. We will comply with applicable laws, rules and regulations regarding protection of personal data of minors; however, we strongly advise that minors should seek the consent of their parents before providing any information about themselves, their parents, or other family members on our Platform.
• 3. WHAT ARE THE COOKIES AND WEB BEACONS REFERRED TO ABOVE?

TYPE OF FILE	COOKIES	WEB BEACON
WHAT THEY DO	They are useful because they allow us to recognize your device when you return. You can disable them through your browser should you so wish. We use cookies to see which parts of our Platform are used by Registered Users and to record the number of visits to our Platform. You can find more information about cookies at: www.allaboutcookies.org	We use web beacons to manage cookies, record visits, and to learn marketing metrics. We also use web beacons to track and monitor email opening rates as well as link clicks. You can find more information about web beacons at: http://www.allaboutcookies.org/faqs/ beacons.html
WHAT THEY WON’T DO	(i) Contain any executable software, malicious code or virus.

• 3.1 You can, at your option, choose to reject and remove cookies from our Platform by changing your browser settings, which might affect how our Platform works.
• 4. ANONYMISATION OF DATA
• 4.1 FOR THE AVOIDANCE OF ANY DOUBT, WE CLARIFY THAT IN THE EVENT WE ANONYMIZE AND AGGREGATE ANY DATA OR INFORMATION COLLECTED FROM YOU, WE WILL BE ENTITLED TO USE SUCH ANONYMIZED DATA OR INFORMATION FREELY, WITHOUT ANY RESTRICTIONS OTHER THAN THOSE SET OUT UNDER APPLICABLE LAW.
• 5. ACCESS, CORRECTION & DELETION
• 5.1 You may request access, correction or updation, and deletion of the data by contacting [[email protected]]. Kindly note that deletion of certain data or withdrawal of consent may lead to cancellation of your registration with us or your access to our Services.
• 5.2 Based on technical feasibility and subject to suitable identity verification, we will provide you with access to all your personal and sensitive personal data that we maintain about you.
• 6. RETENTION OF PERSONAL INFORMATION
• 6.1 Your personal data will primarily be stored in electronic form. We may enter into agreement with third parties to collect, store, process your personal data but under full compliance with applicable laws. In the event, you have any telephonic interactions with our customer/client representatives, the call data is recorded and stored on the [•] for training and quality purposes.
• 6.2 If you are a Registered User, after you terminate your usage of our Services, we will delete all data provided or collected by you from our servers. However, we may need to retain your personal data if it is needed to comply with our legal obligations, resolve disputes and/or enforce our agreements
• 7. SECURITY OF YOUR PERSONAL INFORMATION
• 7.1 We implement industry-standard technical and organizational measures by using a variety of security technologies and procedures to help protect your data from unauthorized access, use, loss, destruction or disclosure. When we collect particularly sensitive data (such as a credit card number or your geo-location), it shall be: (i) in compliance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and other applicable laws; and (ii) encrypted using industry-standard cryptographic techniques including but not limited to authentication, confidentiality and integrity.
• 8. TRANSFER OF INFORMATION
• 8.1 In the ordinary course of business, we may employ other companies and people to assist us in providing certain components of our Services in compliance with the provisions of this Policy. To do so, we may need to share your data with them.
• 8.2 Some of the examples of where we may subcontract processing activities to third parties include—record keeping, data analysis, marketing assistance, processing payments, and providing customer service.
• 9. REGISTERED USER CONTENT
• 9.1 Any success stories, comments, messages, blogs, scribbles etc. posted/ uploaded/ conveyed/ communicated by you on the public sections of the Platform becomes published content. We may publish such published content on our Platform so long as you consent. You may request that such published content be taken down at any time and we shall remove such published content. However, we are not responsible for any actions taken by third-parties with respect to such published content.
• 10. THIRD PARTY LINKS
• 10.1 We may display links to third-party websites or applications on our Platform for advertising or providing you with relevant content. We will not be responsible for such third-party websites or applications if you choose to access them. If you provide any data to such website/application, please ensure you read their policies given that you will no longer be bound by this Policy in doing so.
• 10.2 We may receive data whenever you visit a third-party link through our Platform which includes the date and time of your visit to the third-party website, the web address or URL, technical information about the IP address, browser and the operating system you use and, if you are logged into your account on the Platform, your username.
• 11. COMPELLED DISCLOSURE
• 11.1 In addition to the purposes set out in the Policy, we may disclose any data we collected or processed from you if it is required:
• 11.1.1 under applicable law or to respond to a legal process, such as a search warrant, court order, or subpoena;
• 11.1.2 to protect our safety, your safety or the safety of others or in the legitimate interest of any party in the context of national security, law enforcement, litigation, criminal investigation or to prevent death or imminent bodily harm;
• 11.1.3 in connection with legal proceedings brought against us, our officers, employees, affiliates, customers or vendors; or
• 11.1.4 when we enter into a business deal or negotiate a business deal, or our assets are merged or acquired by the other business entity, or during restructuring of business or re-organization, we may have to share information provided by you with the other business entities. However, the information shared will be protected by suitable confidentiality arrangements with such third parties.
• 12. YOUR RIGHTS & PREFERENCES AS A DATA SUBJECT IN THE EUROPEAN UNION
• 12.1 may collect and process ‘special categories of personal data’ such as ethnic origin, genetics, sexual orientation, which are considered sensitive. We use this special category of personal data, to offer specific certain services. We require your explicit consent to collect and process special categories of personal data. You may, at your sole discretion, refuse or revoke your consent at any time in accordance with the terms hereof. Access to special categories of personal data provided by you shall be restricted to specified personnel only.
• 12.2 If the entities to which transfer of data are effected are not situated in countries deemed ‘adequate’ by the European Commission or are not registered under the EU-US Privacy Shield framework, we shall enter into appropriate Data Protection Addendums with the transferee parties that comprehensively protect your data. We shall also put in place industry-standard technical and organizational measures (including robust data handling policies) to ensure that such transfers are completed in accordance with applicable laws.
• 12.3 In case you are a Registered User entitled to data protection under the European Union (EU) called the General Data Protection Regulation (GDPR), we would like to inform you that our processes are GDPR compliant. Your rights under the GDPR are listed hereunder.

RIGHT TO BE INFORMED You have a right to be informed about the manner in which your personal data is collected or used as elucidated in this Policy.	RIGHT OF ACCESS You have a right to access your personal data provided to us by requesting us for the same.
RIGHT TO RECTIFICATION You have a right to request us to amend or update your personal data if it is inaccurate or incomplete.	RIGHT TO ERASURE You have a right to request us to delete your personal data.
RIGHT TO RESTRICT You have a right to request us to temporarily or permanently stop processing all or a part of your personal data for any reason whatsoever, including, without limitation for the purpose of direct marketing.	RIGHT TO OBJECT You have a right, at any time, to object to our processing of your personal data under certain circumstances.
RIGHT TO DATA PORTABILITY You have a right to request for a copy of your personal data in electronic format and to request for transmission of such personal data to third-parties for using such third-party products/services.	RIGHT NOT TO BE SUBJECT TO AUTOMATED DECISION-MAKING You have a right to ascribe explicit consent requirement for any decisions relating to your personal data. You shall not be subject to automated decision making, including profiling.

• 12.4 Additionally, we may process your data to serve legitimate interests as described under GDPR. Accordingly, the grounds on which we can engage in processing are as follows:

NATURE OF DATA	GROUNDS
Registered User Data	● Consent; ● Performance of a Contract; and ● Legitimate Interest
Account Registration Data	● Performance of a Contract; and ● Legitimate Interest.
Special Categories of Personal Data	● Consent; and ● Performance of a Contract;
Payment Data	● Performance of a Contract; ● Compliance with applicable laws; and; ● Legitimate Interest.
Service Usage Data	● Performance of a Contract; and ● Legitimate Interest.
Data for Marketing our Services	● Consent; and ● Legitimate Interest.
Personal Stories	● Consent.

• 12.5 In case you want to exercise the rights set out above, do feel free to contact our Grievance Officer whose details are set out below. If you believe we have used your personal data in violation of the rights above or have not responded to your objections, you may lodge a complaint with your local supervisory authority.
• 13. PRIVACY POLICY UPDATES
• 13.1 This Privacy Policy may be updated from time to time. Such changes shall be effective immediately upon posting on the Platform. We will notify you of any material changes required by law, but nevertheless, request you to periodically check the Platform for updates.
• 14. GRIEVANCE OFFICER
• 14.1 The name and contact details of our Grievance Officer, who you may contact if you have any concerns, complaints or feedback pertaining to this Policy or your personal data, are as follows:

NAME:	[●]
ADDRESS:	[●]
TELEPHONE:	[●]
EMAIL:	[email protected]

This Policy was last updated on [23rd June 2020].