Privacy Policy

We at Spardha are committed to the privacy of our customers and take every measure that We believe would help in safeguarding the data. When you provide us with your information, you trust us with it. This Privacy Policy is meant to help you understand what data we collect, why we collect it, and what we do with it when you’re using Spardha services, including the Spardha mobile application or TV applications and Spardha website. It is also compliant with GDPR, COPPA, Cyber and Privacy laws of other nations and is safe for users who are data-subjects of European Union, U.S.A., U.K., U.A.E., Singapore, Australia, New Zealand, Malaysia, Thailand or any other country where we operate including India.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, if the changes are significant, e will provide you with additional notice (such as adding a statement to our homepage or sending you an email notification). We encourage you to review the Privacy Policy whenever you access the Services to stay informed about our information practices and the choices available to you.

This Privacy Policy outlines Spardha Learnings Private Limited’s approach to privacy to fulfill its obligations under the applicable privacy laws of that jurisdiction.

Throughout this document, the terms “we”, “us”, “our” & “ours” refer to Spardha Learnings Private Limited, and the terms “you”, “your” “yours” & “you and/or your child“refer to YOU (as the User).

This Privacy Policy applies to all your PERSONAL DATA processed by us, whether in physical or electronic mode. This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information and shall be read with the Terms and Conditions found on T&C, Cookie Policy and Direct Notice to Parents (COPPA).

Please note that this Privacy Policy is applicable to all instances where we play the role of a DATA CONTROLLER of your Personal Data, when we collect and process personal data about you for offering our products or services.

We are committed to keeping your and your child's Personal Data private and secure. We process any Personal Data we collect from you and your child in accordance with the applicable laws and regulations and the provisions of this Privacy Policy. Please read the following carefully to understand our practices regarding your and your child's Personal Data and how we treat it.

By choosing to visit and/or avail any Services provided by us, you agree to this Privacy Policy (as may be amended from time to time). Please read the following information carefully. You must be at least 18 years old to register on our site. If you are under 18 years old, you are not permitted to register unless such registration is completed by a parent or legal guardian. By your continued access or use of the Platform, you signify your agreement to be legally bound by the Privacy Policy set forth herein. If you do not agree to the Privacy Policy of this agreement, promptly exit this page and stop accessing the Services.

1. Consent

Spardha Learnings Private Limited (“Company” or “We” and their connotations) operates a website - (URL: https://www.spardhaschoolofmusic.com ) (together called as "Platform") which is engaged in the service of online tutoring to users.

Our Platform is primarily for teachers who are enlisted on our Platform, children below the age of 18 years ("Child"), their parents & other adult users across various age groups (“Adult”). By registering on the platform the parent gives their consent for the use of the platform by the child & the adult gives their consent for the use of the platform by themselves. The teachers, parents of the Child or Adult hereinafter are referred to as You. The term "Users" for the purposes of these Terms shall be read as You and/or the Child.

Our User’s privacy is extremely important to us. We recognize the privacy concerns of the Users and the visitors and hence as a commitment to provide a safe and secure experience on our Platform, we have formulated this privacy policy to help Users make an informed decision. We provide online performing arts education to users on the Platform (hereinafter referred to as “Services”).

Scope:

This Privacy Policy applies to Information, data / any hard copy/ electronic record that may be collected /shared/ analyzed and/or stored by Us.

This Privacy Policy shall also be applicable irrespective of whether Our platform has been accessed/availed through a Third-Party source or directly.

Permitted Disclosure:

User/s agree and consents that We may, in order to comply with Applicable Laws, share Your Personally Identifiable Information/PII with government authorities in the following cases:

1. If a government authority requests for Information and We think disclosure is required or appropriate in order to comply with Applicable Laws, regulations, or a legal process

2. To comply with a legal requirement or process, including but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures; User/s further agree that any liability arising out of misuse/loss/breach of Your Personally Identifiable Information/PII through the aforementioned disclosure or by the government authorities, neither We nor any of Our administrators, sister concerns, subsidiaries, representatives, associates, affiliates or assigns shall be held liable.

What kinds of information do we collect?

To provide the Spardha services, we must process information about you. The type of information that we collect depends on how you use our service. You can learn how to access, change and delete information we collect by visiting the Spardha settings.

Personal Data:

‘Personal Data’ means any information that may be used to identify an individual, directly or indirectly, in particular by reference to an identifier, including but not limited to, a first and last name, physical address, email address, online identifier or other contact information and/or identity proof documents.

Children’s Privacy:

We need to collect your and your child's Personal Data to provide our services to you and your child. We are committed to protecting the privacy of children who use our sites and applications. Whenever we refer to a “child” in this privacy policy, we mean a child under the age of 13 for U.S., U.K. and Singapore users, under the age of 16 for EU users, under the age of 15 for Australia and New Zealand users, under the age of 21 Hijri years for UAE users, and under the age of 18 for Malaysian users.

If your child is a resident of the United Kingdom, we will treat their Personal Data as a child’s Personal Data if they are under 13 years of age, and receive consent of the holder of parental responsibility as required for the processing of Personal Data. All residents of the United Kingdom further have certain specific rights granted by the General Data Protection Regulation (“UK-GDPR”) and Data Protection Act, 2018 (“DPA”).

If your child is located in the United States of America, we handle their Personal Data in compliance with the Children's Online Privacy Protection Act (“COPPA”). COPPA applies to child users who are under the age of 13. COPPA requires that we receive verifiable parental consent from the child's parent or legal guardian before the collection, use, or disclosure of the child's Personal Data. To learn more about how we receive this parental consent, what personal data we collect from children, how we use this data, including when we disclose it, go to COPPA Direct Notice to Parents. We display this notice to all parents and guardians when soliciting and obtaining verifiable parental consent.

If you are a parent or guardian and you believe that your child has provided us with Personal Data without your consent, you may contact us through the details provided as below. We will dispose of that data in accordance with applicable laws and regulations. Parents can always refuse to permit us to collect further Personal Data, request to review their child's Personal Data, or request that we delete from our records the personal data collected from or about their child. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service, as the nature of our services requires collection of Personal Data. To exercise any of these options, please contact us through our contact details given as below. Please be aware that to protect children’s privacy and security, we will take reasonable steps to verify a parent or legal guardian’s identity before granting access to any personal data.

If your child is a resident of Singapore, we will treat their Personal Data as a minor’s Personal Data if they are under 13 years of age, and require consent of the holder of parental responsibility as required for the processing of Personal Data. Parents can always refuse to permit us to collect further Personal Data, request to review their child's Personal Data, or request that we delete from our records the personal data collected from or about their child. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service, as the nature of our services requires collection of Personal Data. Please be aware that to protect children’s privacy and security, we will take reasonable steps to verify a parent or legal guardian’s identity before granting access to any personal data.

If your child is resident in the UAE, we will receive consent of the holder of parental responsibility for obtaining, receiving, collecting, using, sharing, processing and storing the Personal Data of both the individual with parental responsibility and the child in accordance with this privacy policy as amended from time to time.

If your child is a resident of Malaysia, we will treat their Personal Data as a child’s Personal Data if they are under 18 years of age, and receive consent of the holder of parental responsibility as required for the processing of Personal Data. Persons whose personal data are processed in Malaysia have certain specific rights granted by the Personal Data Protection Act 2010.

The Privacy Act applies to all Australian and New Zealand residents, regardless of age. For users who are under 15 years of age, parental consent is required for children to sign up to and use our services.

Collection Notice:

When Singapore residents want to sign up for our services, you will be asked to provide your consent (or parental consent if you are under 13 years of age) to our collection, use and disclosure of your Personal Data as described in this Privacy Policy If you do not provide such consent, we may not be able to provide you with our services.

When Malaysia residents want to sign up for our services, you will be asked to provide your consent (or parental consent if you are under 18 years of age) to our collection, use and disclosure of your personal data as described in this Privacy Policy.

When Australian or New Zealand residents want to sign up for our services, you will be asked to provide your consent (or parental consent if you are under 15 years of age) to our collection, use and disclosure of your Personal Information as described in this Privacy Policy If you do not provide such consent, we may not be able to provide you with our services.

2. Information We Collect and use

In order to provide Services, we require certain user information and may obtain the same through user-provided data or automatic data collection.

1. By choosing to visit and/or avail any Services provided by Company, you agree to this Privacy Policy (as may be amended from time to time). Please read the following information carefully. If you are an Adult or parent / guardian and you provide your consent to your / your Child's use of the Platform, you agree to be bound by this Privacy Policy in respect to child’s use of the Platform. By your continued access or use of the Platform, you’re legally bound by Terms of The Agreement and Privacy Policy set forth herein. If you do not agree to the Privacy Policy of this agreement, promptly exit this page and stop accessing the Services.
2. We collect information that may be used to identify you or your Child (“Personal Information”) including, but not limited to, (i) name, e-mail ID, Govt. issued ID, mobile no., photograph, location and other contact information (ii) gender and other demographics (iii) birth date and year of the Child to validate their age.
3. We also collect certain information either when you provide it using the Platform or Services and/or automatically as you or the Child navigate through the Platform (which may include usage details, IP address, device ID and type, your browser type and language, the operating system used by the device, access times, and information collected through cookies, web beacons and other tracking technologies). You agree that we may use such information to do internal research on our Users' demographics to better understand, protect and serve our Users.
4. We also collect information from your user ID associated with any social media account (such as your Facebook and Google account) that users use to sign into the Platform or connect with or use of our Services. When you sign in with your social media account information, or otherwise connect to your social media account with the Platform, you consent to our collection, storage, and use, in accordance with this Privacy Policy, of the information that you make available to us through the social media interface. This includes, without limitation, any information that you have made public through your social media account, information that the social media service shares with us or information that is disclosed during the sign-up and sign-in processes. When signing in with social media accounts you’re bound by their Terms of Use, Privacy Policy related to the use of sign up and sharing of details.
5. If any of the Users allows us to collect information from his or her device phonebook—and you or the Child’s are one of that User’s contacts—we may combine the information we collect from that User’s phonebook with other information we have collected about you. We may also obtain information from other sources and combine that with the information we collect through the Platform.
6. We collect User Data by various ways such as by installing "cookies", Taking access of device storage, Media, Phone Directory, Location, etc. Data collected is used for analysis of several factors such as to help analyze our web page flow, improve user experience along with ease of use, measure promotional effectiveness, customizes web interface for every User, modify our working structure/strategies, and promote trust and safety. Cookies are small files placed on your device read only memory (ROM) that helps us in authorized data collection and assist us in providing our Services efficiently. We offer certain features that are only available using a cookie. Cookies can also help us provide information that is targeted to your interests.
7. Online training sessions are recorded and used for quality audits and teacher training.

3. Purpose of Collection

We collect personal information only for the following purposes and related matters:

1. To create and maintain account and know our customer base.
2. To enable you to avail our Services without encumbrances, smooth User experience and develop new features.
3. To determine the current age and interests of the User.
4. To send surveys or marketing communications to inform you of new services or Services or other information that may be of interest.
5. To maintain records and customize platform for User safety, friendliness and offer improvements from time to time enabling efficiency.
6. To dispatch transaction-related communications such as welcome letters, billing reminders, and purchase confirmations.
7. To notify the necessary information related to the Platform and Services and your or the Child’s account on the Platform from time to time;
8. To analyze overall trends to helps us improve the Platform and Services.
9. To perform quality audits and teacher training.
10. To furnish your information to service partners and providers only to the extent necessary for delivering the relevant services (e.g. scheduling service and maintenance, providing emergency assistance).
11. Verify your identity and prevent fraud and multiple access from same account, other unauthorized or illegal activity
12. To comply with applicable laws, rules, and regulations.
13. And In any other way consistent with this Privacy Policy.

Additionally,

1. We may use your email address to seek parental consent of Child for registration of and to explain what information we are collecting, how we plan to use it, and how the parent can revoke consent or request at any time that we remove the account and delete any Personal Information collected from the Child (including the parental contact information).
2. We may use your email address to seek your consent for registration of and to explain what information we are collecting, how we plan to use it, and how the parent can revoke consent or request at any time that we remove the account and delete any Personal Information collected from you.
3. We reserve the right to use or disclose your Personal Information in response to any statutory or legal requirements. We will use and disclose your Personal Information if we believe you will harm the property or rights of the Platform, its owners, or those of the Platform’s other users. We may use or disclose yours or the Child’s Personal Information if we believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person or property, violations of the Platform’s other policies, or as otherwise required by law when responding to subpoenas, court orders and other legal processes.
4. If we believe that disclosure is necessary or appropriate to protect our rights, property, or safety, our Users or others, we may in good faith share information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
5. You agree that we may use Personal Information about you to improve our marketing and promotional efforts, to analyze site usage, improve the Platform's content and Service offerings, and customize the Platform's content, layout, and Services. These uses improve the Platform and better tailor it to meet your needs, so as to provide you with an efficient, safe and customized experience while using the Platform.

You hereby consent that we may transfer your personal data to any country outside of the country of your residence for the purposes set out in this Privacy Policy. Where we transfer your personal data, we will take all reasonable precautions and exercise all due diligence to ensure that the personal data will be processed in accordance with this Privacy Policy and applicable data protection laws.

You fully understand and unambiguously consent that we may transfer your personal data to any country (including to third parties where necessary) for the purposes set out in this Privacy Policy or as notified to you. Where we transfer your personal data outside of the country of your residence, we will require foreign recipients of the personal data to protect your personal data in accordance with this policy and applicable data protection laws.

The below additional rights are available to you:

Correction: you may request that any incomplete or inaccurate personal data we hold about you is corrected.

Withdrawal: you may withdraw consent for our use of your personal data.

Portability: you may request the transfer of certain of your personal data to another party under certain conditions.

4. Data Security

We always strive to keep your Personal Information safe, from time to time our safety measures are upgraded so that we stay ahead of time from any technical issues and ensure full-proof User safety, including:

1. The security of your Personal Information is important to us. While we strive to use commercially acceptable means to protect your Personal Information, still we cannot guarantee data and security protection.
2. Operating environment: All the accessible personal information is stored in highly secured atmosphere and can only be accessed by employees, representatives and service providers on a prior data protection team approval basis. The data so accessed cannot be copied or stored in any manner by the staff/service providers from the servers without any official necessity approval. The data so stored cannot be used beyond the policy parameters. We comply with industry standards and the law to protect your Personal Information.
3. The User owns their data and has consented to share it with the company to avail its services. User can anytime opt to not share their Personal details and request company to delete their account after payment of all the dues and fulfilling other obligation/necessities if any.
4. The payment information: We reveal only the last four digits of your credit card numbers when confirming an order. Your online transaction on Spardha is secure with the highest levels of transaction security currently available on the Internet. All payments on Spardha are processed through secure and trusted payment gateways which are managed by leading banks. Banks now use the 3D Secure password service for online transactions, providing an additional layer of security through identity verification.
5. A Child’s publicly accessible Personal Information is strictly regulated by the company. Any review or comment posted by the Child on the Platform will only bear the Child's age and name, along with the content of the Child's posting. No portion of the Child's profile other than the Child's age and name would be made publicly accessible. Separate parental consent would be sought for posting the child’s accomplishments (project work) on social media. The posting includes Name, Age, School, City, Picture and key project details.

5. Links to other Sites

Our Platform may contain links to other websites. Please note that when you click on one of these links, you are entering another website over which we have no control and for which we will bear no responsibility. Often these websites require you to enter your Personal Information. We encourage you to read the privacy policies of all such websites as their policies may differ from our Privacy Policy. You agree that we shall not be liable for any breach of your privacy of Personal Information or loss incurred by your use of such websites or services.

6. Compliance with Data Protection Regulations

The information we obtain from you may be processed and stored in India or on our other servers located across the globe, which may provide for different data protection rules than the country in which you reside but general data protection policies are similar everywhere which is that you own your data. We comply with generally accepted industry standards and regulations regarding the collection, use, and retention of data. By using the Platform and/or Services, you consent to the collection, transfer, use, storage and disclosure of your information as described in this Privacy Policy, including the storage and processing of your information beyond the perimeters of your country of residence.

Spardha Learnings Private Limited aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us on the details as given below.

7. Rights of the Data Subject

You have the following data protection rights.

1. The right to access, updates or delete the information we have on you: Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
2. The right of rectification: You have the right to have your information rectified if that information is inaccurate or incomplete.
3. The right to object: You have the right to object to our processing of your Personal Data.
4. The right of restriction: You have the right to request that we restrict the processing of your personal information.
5. The right to data portability: You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
6. The right to withdraw consent: You also have the right to withdraw your consent at any time where Spardha Learnings Private Limited relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

It is important for you to protect against unauthorized access to your password and to your device. Be sure to sign off when you finish using a shared device. Company is not liable for any data theft or changes in the account due to the fault and carelessness of User. User will be liable for any technical issues and glitches occurring on the company’s website because of unethical use of the account.

You have the right to report any breach or misuse of your data with Spardha Learnings and if you’re not satisfied with the resolution provided you may further proceed with reporting the issue to the designated Data Protection Authority under the legal provisions of your nation about our collection and use of your Personal Data.

8. Sharing of Personal Information

We may share your personal information with third party service providers (called 'processors') to perform certain processing activities on our behalf, such as Parties involved in hosting and enabling our Services. Please note that we will not share your Personal Information with third parties allowing them to use this information for their own purposes unless you have given explicit consent thereto.

Categories of third party processors are:

Categories	Legal Requirement
Usage Analytics	We may use third-party Service Providers to monitor and analyze the use of our Service
Online and Behavioral Marketing	We use remarketing services to advertise on third party websites to you after you visit our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service
Payment Processing and Discounting	We may provide paid services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors)
Collaboration and Location Service Providers	We collaborate with location service providers to send out emails, SMS’s and OTP’s to our customers, enable online live video classes for students and teachers and to also enable telephony across our students, teachers and support team.

9. Rights to Your Personal Information

1. You have the right to provide Personal Information to us and may change that decision at any time.
2. You have the right to check, update and adjust your Personal Information by logging into your account and editing personal information or asking us to do this.
3. You may also delete yours or your Child’s information at any time on the Platform. However, we may retain certain information as required by law or for reasonable business purposes.
4. To sum up, you have the right to access, update, delete, rectify, object or restrict the Personal Information we have on you.

10. Changes to this Privacy Policy

This Privacy Policy will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website

11. Contact Details

Please contact us by email or postal mail on the following address of the Grievance Officer:

Company Name: Spardha Learnings Private Limited

Contact Person Name: Mr. Saurabh Srivastav

E-mail ID: saurabh.srivastav@spardha.co

Address: Office number 502, Deron Hills, Sr. No. 6/1/1, Opposite Bata Showroom, Baner, Pune 411045