PRIVACY POLICY

Last Updated On: 30-03-2023

This document is an electronic record in terms of the Information Technology Act, 2000 and rules thereunder as applicable and the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.

This document is published in accordance with the provisions of Rule 3 (1) of the Information Technology (Intermediaries Guidelines) Rules, 2011 that require publishing the rules and regulations, Privacy Policy and Terms of Use for access or usage of (i) https://www.iguroo.com (“Website”) and (ii) “iGuroo” mobile application (“Application”) (collectively referred to as “Platform”) owned and operated by iGuroo Digitech India Private Limited.

This Privacy Policy, along with our Terms of Use constitute the agreement (the “Agreement”) established by and between iGuroo Digitech India Private Limited, a company incorporated under the laws of India having its registered office at 403, 4th Floor, Elemental #337, Sy No 337 Partly, Puppalaguda Village, Financial District, Nanakaramguda, Telangana – 500032  (referred to as “iGuroo”, ‘We” or “Us” or “the Company”) and any person or entity registering to or using the Services supplied by Us (referred to as “User” and “You”). iGuroo and the User shall collectively be referred to as “Parties”, individually “Party”. For the purpose of this Privacy Policy, wherever the context so requires “You” or “User” shall mean any natural or legal person.

iGuroo is committed to protecting User’s privacy and data. We are taking many measures to protect the data at rest and in transit. This Privacy Policy (“Privacy Policy”) describes our information gathering and dissemination practices.

For the purpose of this Privacy Policy, all capitalized terms used herein, but have not been defined herein, shall have the meaning so assigned to them in the Terms of Use.

Accepting this Agreement is a condition of using the Services provided by iGuroo. BY COMPLETING THE REGISTRATION PROCESS, AND ACCESSING OR USING THE SERVICES, YOU ACKNOWLEDGE AND AGREE THAT (I) YOU EXPRESSLY CONSENT TO OUR COLLECTION, PROCESSING, USING, STORING, DISCLOSING, AND HANDLING OF YOUR INFORMATION AS SET FORTH IN THIS PRIVACY POLICY NOW AND AS AMENDED BY US (II) YOU HAVE READ, UNDERSTOOD AND ACCEPTED THIS AGREEMENT, (III) YOU HEREBY REPRESENT AND WARRANT THAT YOU ARE AUTHORIZED TO ENTER OR ACT ON BEHALF OF THE OWNER OF THE ACCOUNT, AND BIND TO THIS AGREEMENT AND (IV) YOUR USE OF THE SERVICES IS FOR NON-COMMERCIAL/NON-BUSINESS PURPOSES ONLY. If You do not have the legal authority to enter this Agreement, do not understand this Agreement, or do not agree to the Agreement, please do not register to, or use the Services. Please read carefully the entire Privacy Policy before using the Platform. If the User does not agree with the terms and conditions of this Privacy Policy, the User shall not proceed further to use the Platform.

The Platform and Services are only meant for use in the Indian territory. Please note that our Privacy Policy is designed to provide a globally consistent level of protection for the use, storage, process, and transfer of your information all over the world. This means that even in countries whose laws provide for less protection for your information, we will still handle your information in the manner described herein i.e., in accordance with the security measures prescribed under the Indian Data Protection Laws.

“Personal Information” shall mean and include any information that relates to a natural person, which either directly or indirectly, in combination with other information available or likely to be available by a body corporate, is capable of identifying such person. Sensitive personal data or information (“SPDI”) means personal information relating to a person’s passwords; financial information, including information relating to bank accounts, credit cards, debit cards, and other payment instrument details; physical, physiological, and mental health condition; sexual orientation; medical records and history; and biometric information.

The Parties agree and are bound by the following provisions: This Agreement is effective between iGuroo and You on the day of your registration, access to, or use of the Services (as further defined below) (the “Effective Date”).

  1. Absolute Confidentiality
  1. iGuroo is committed to protecting User’s privacy and ensuring the privacy and security of any Personal Information provided by or received from the User. iGuroo strictly adheres to the requirements of the applicable data protection law(s) enacted in India.
  2. The purpose of this Privacy Policy statement is to explain to the User what Personal Information iGuroo collects or receives from the User’s visit(s) to the Platform, and how iGuroo protects such information that the User provides to iGuroo when the User accesses, browses or uses the Platform and/or Services. iGuroo shall use such information in a prudent manner, and only in accordance with this Privacy Policy. iGuroo is committed to complying with the highest standards of Platform privacy, to ensure Users can securely access and use the Platform and Services.
  3. This Privacy Policy is effective from 30-03-2023. Any information that the User provides to iGuroo is subject to this Privacy Policy.
  1. User’s Consent
  1. By accessing the Platform and whenever the User submits any information to iGuroo or uses the Services offered by the Platform, the User agrees to be bound by the terms of this Privacy Policy.
  2. This Privacy Policy is subject to change at any time without notice. iGuroo may, at its sole discretion, change, modify, add, or remove portions of this Privacy Policy at any time without any prior written notice to the User. iGuroo may reasonably endeavor to notify the User of the changes. However, it shall be the responsibility of the User to review the Privacy Policy periodically for updates/changes. The User’s continued use of our Services/Platform, following the posting of changes will mean that the User accepts and agrees to the changes.
  3. As part of providing our Services to the User, iGuroo may need to send routine communications to the User, such as order transactions, payment confirmations, updates, results and reports, emails, and other administrative messages through email and notifications posted on the Platform or through other means available, including text, email and other forms of messaging. Further, the User agrees to receive our phone calls, related to the User’s request(s) on the Platform.
  4. When the User signs up on the Platform, the User may consent to iGuroo periodically sending emails about new services, special offers, payment-related updates, or other information. If the User does not wish to receive promotional information from iGuroo, the User can, at any time, choose to opt out of receiving such promotional communications. To unsubscribe from the same, the User can follow the directions included in the Platform.
  5. The User must ensure that the Personal Information provided to iGuroo is correct or up-to-date. This will enable iGuroo to contact the User for further correspondence with respect to Services availed on the Platform. iGuroo shall not be responsible for any inaccurate information provided to iGuroo by the User, which may affect the User’s experience on or usage of the Platform and/or Services.
  6. If, at any time, the User wishes to access, review, update, modify, correct, or eliminate any of the User’s account information on the Platform, the User may do so by going to Edit Account->My Profile and editing the information.
  7. iGuroo may, at any point in the future, request other optional information from the User in order to process requests, to deliver personalised Service(s), etc.
  1. What information iGuroo collects about the User
  1. When the User accesses, uses, or browses the Platform or uses the Services, the User may provide, or iGuroo may collect information that can be used to directly or indirectly identify the User. iGuroo shall receive and store any information the User enters on the Platform or the User gives in any other way. The following Personal Information, SPDI, and other information pertaining to the User may be provided by the User and/or received by iGuroo from other sources (including without limitation):
  1. Personal Information – Name, age, mobile number, transaction information, email address, residential address, etc, and any other such information that iGuroo required to fulfil its legal obligations which require iGuroo to confirm the User’s identity.
  2. Information pertaining to education – Student’s educational/edutainment interests, student’s class, marks cards, progress reports, syllabus, curriculum, etc.
  3. Device Information – Information such as device ID, time-zone, browser type and browser plug-in details, pages accessed, IP address, mobile network, operating system, or a unique identifier.
  4. Location information: In the event the User, has authorized location tracking on the Platform and geolocation data, such as mobile device location.
  5. Information from other sources: Cookies, tracking technologies, third-party tools and software, pixels, and automatic information from other sites.
  6. Financial information: Details of bank account, UPI, credit card or debit card, or any other payment instrument.
  7. Any other information that is required to be collected as per specific mandate from any regulatory authorities or as a legal requirement in India.
  1. Further, if You are a mentor, teacher, or counselor engaged by iGuroo, in addition to the aforementioned information iGuroo may collect information, including but not limited to PAN card details, bank account details, proof of educational qualifications, experience certificates, and proof qualification. Further, such information pertaining to qualification, education background, experience, areas of expertise, etc will be published on the Platform and made visible to Users to enable them to get to know a mentor, teacher, or counselor and accordingly choose which mentor, teacher or counselor they wish to proceed with.
  2. The User may choose not to provide certain information in which case the User may not be able to use or access some of the Platform’s features. iGuroo uses the information that the User provides for such purposes as responding to the User’s requests, processing the User’s orders, improving the Platform, and communicating with the User.
  3. When the User uses or accesses the Platform, iGuroo may also collect information regarding the pages the User viewed, the web addresses from which the User arrived or clicked through, time spent on certain pages, download errors, and page response times. All this information helps us analyze Users’ trends and preferences and thus assists iGuroo in improving its Services.
  4. iGuroo shall use its best endeavors to protect and secure the information it possesses, however, iGuroo shall not be responsible for any third-party interference causing such information to be destroyed, replicated, or transferred.
  5. The recording, storage, usage, and disclosure of SPDI shall be in accordance with the Information Technology Act, 2000 and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011, or any statutory modification or re-enactment thereof and the rules made thereunder, for the time being in force.
  6. Any information relating to an individual that is available or accessible in the public domain or furnished under the Right to Information Act, 2005, or any other law shall not qualify as Personal Information or SPDI.
  1. How iGuroo uses the information collected from the User

iGuroo will collect and retain the User’s Personal Information and SPDI only to the extent that it is necessary to fulfil our Services to the User. Any Personal information submitted by the User to the Platform or collected by iGuroo will be used ONLY for the purposes mentioned below:

  1. To carry out our obligations arising from the User’s requests for our Services;
  2. To provide customized and curated content and Services to the User;
  3. To provide additional services including customer support;
  4. To improve the Platform’s functionality, and to customize the User’s future experience with us;
  5. To make sure that the Platform’s content is presented in the manner that is most effective for the User;
  6. To communicate with the User about any changes to our Services;
  7. To identify as the author of content you submit to the Platform;
  8. To conduct research, analyze trends, and gather usage behavior and learning patterns of users;
  9. To maintain records and comply with our legal obligations;
  10. To process transactions of Users on the Platform; and
  11. Verifying User’s identity (including during account creation and password reset processes) and performing checks to prevent fraud, prohibited or illegal activities, and detecting/preventing violations of policies or applicable User agreements.
  1. With whom iGuroo shares the User’s information
  1. iGuroo may only share the information as described below after ensuring that such third party has implemented measures to assure data protection measures and that are either subject to this Privacy Policy or follow practices at least as protective as those described in this Privacy Policy. iGuroo does not sell, rent, or exchange any Personal Information or SPDI that the User provides to iGuroo through this Platform with any third party for commercial reasons.
  2. iGuroo has arrangements with third parties such as payment gateways, who may have access to the SPDI but shall not disclose such SPDI further to any other individual/entity. iGuroo engages trusted online payment service partners to perform payment processing and authorization services (for net banking or credit/debit card validation). Through the User’s use of iGuroo’s Services, the User consents to our collection and transfer of User’s information to our payment service partner websites.
  3. iGuroo may release account and other personal information when iGuroo believes such release is necessary to comply with applicable law; enforce or apply our Terms of Use and other Agreements; or protect the rights, property, or safety of iGuroo and the Platform, Users, or others. This includes exchanging information with other companies, organisations, governments, or regulatory authorities for fraud protection and credit risk reduction.
  4. iGuroo may also disclose information to meet its legal obligations and when iGuroo believes in good faith that such disclosure is necessary to comply with applicable laws (i) conform with legal requirements or comply with legal process; (ii) protect rights or property or affiliated companies; (iii) prevent a crime or in the interest of national security; or (iv) protect the personal safety of the Users or the public. iGuroo may also disclose User’s Personal Information or SPDI to enforce or apply our Terms of Use and other agreements; or protect the rights, property, or iGuroo’s safety, safety of our Users or others.
  5. As with any business, it is possible that as iGuroo’s business develops, iGuroo may sell or buy other businesses or assets. In such transactions, User information is typically one of the transferred business assets. Accordingly, if and when iGuroo, or substantially all of its assets, is acquired by a third party, such information may be one of the assets that is transferred or acquired by a third party. Under such circumstances, iGuroo would, to the extent possible, require the acquiring party to follow the practices described in this Privacy Policy. The User acknowledges that such transfers may occur and that any acquirer of iGuroo may or may not continue to process the User’s Personal Information or SPDI as set forth in this Privacy Policy and iGuroo shall not be responsible or liable to the Users in this regard.
  6. iGuroo assumes no liability for any disclosure of information due to errors in transmission, unauthorized third-party access or other acts of third parties, or acts or omissions beyond our reasonable control and the User agrees that User will not hold iGuroo responsible for any breach of security unless such breach has been caused as a direct result of our gross negligence or wilful default.
  1. Who has access to the User’s information
  1. iGuroo maintains electronic, physical, and procedural safeguards in connection with the collection, storage, and disclosure of information (including Personal Information or SPDI).
  2. The User’s Personal Information or SPDI can be accessed only on a need-to-know basis by certain employees of iGuroo and/or such persons/entities and their respective employees including third parties who are designated to carry out the transaction, Service request, or requested activity, and all such individuals are bound to strict confidentiality obligations.
  3. All user data is encrypted and onlyauthorized persons will have access to it. The user password is managed in AWS Cognito and no one has access to it.
  1. How We Use Cookies
  1. “Cookies” are small pieces of information placed by a Platform onto the User’s device’s hard drive. Cookies do not collect any Personal Information or SPDI from the User. iGuroo uses cookies to analyze data about our web page traffic, which helps us save User’s preferences for the User’s future visits. This allows iGuroo to customize the Platform according to the User’s interests, which will enable iGuroo to deliver more personalized or curated content and Services. The User may choose to accept or decline cookies. The User must be aware that by declining cookies the User may be unable to use the Platform to its fullest capability. “Session cookies” shall be automatically deleted at the end of the session.
  2. Additionally, the User may encounter “cookies” or other similar devices on certain pages of the Platform that may be placed by third parties, not associated with iGuroo. iGuroo does not control the use of cookies by third parties nor shall be responsible in any manner for User’s acceptance of the same.
  1. Security Policy
  1. We use AWS Cognito to manage user credentials which is highly secure and allows strict security policy enforcement.
  2. Policies such as password rotations and password strength are strictly enforced by AWS Cognito.
  3. All APIs are on HTTPS and are SSL-protected.
  4. All APIs are also protected by AWS Cognito’s authorization framework which allows the invocation of APIs from authorized actors.
  5. To protect sensitive data, personal information such as date of birth and phone number are encrypted at the application level and can only be decrypted by the user who logged in.
  6. The application is also continuously monitored for security threats using AWS CloudTrail and Amazon CloudWatch, ensuring that any potential threats are quickly identified and addressed.
  7. Only authorized person has access to the production database.
  1. Minors
  1. The Use of the Platform is meant for persons above the age of 14. iGuroo requires a parent or guardian who can form a legally binding contract under the Indian Contract Act, of 1872 to consent/approve the registration and use of the Platform by a Minor. iGuroo advises that the User should not use the Platform without the consent and help/guidance of a parent or guardian.
  2. If the User is below the age of eighteen (18) (“Minor”), the User will be required to obtain consent from their parent or legal guardian to use the Services and any liability arising from the use of the Minor of such Services shall be on the legal guardian and iGuroo shall not, in any way, be held liable for any action on the part of the Minor.
  3. If a parent or guardian becomes aware that his or her child has provided his or her information on the Platform without their consent, he or she shall contact us for the deletion of such information.
  1. User’s rights

Subject to certain reasonable restrictions under applicable laws, the Users have the following rights under this Policy:

  1. Right to confirmation and access: Users have the right to be provided full information about whether User information is being processed or has been processed, a summary of such information which is being processed or has been processed including a summary of the processing activities performed by iGuroo.
  2. Right to data portability: Users have the right to receive their information/Personal Information in a structured and commonly used machine-readable format including the right to have such information be transferred to any other entity/data fiduciary in the format mentioned herein.
  3. Right to be forgotten: Users have the right to restrict or prevent iGuroo from continuing disclosure of Personal Information where such disclosure: (a) has served the purpose for which it was made or is no longer necessary; (b) was made on the basis of consent received from you and such consent has been duly withdrawn by you; or (c) was made contrary to the provisions of applicable law or any other law made by parliament or any state legislature. In this regard, Users also have the right to require iGuroo to delete/erase Personal Information.
  4. Right to object: Users have the right to object to the use/processing of User’s Personal Information by iGuroo, at any point in time including the right to opt-in and opt-out of any Services, promotional messages, offers, or advertisements made by iGuroo.
  1. Third-party websites and platforms
  1. The Platform may host hyperlinks to external or third-party websites, applications, resources, or advertisements. iGuroo does not take any responsibility for third-party or external sites, platforms, or services.
  2. iGuroo cannot be held liable for any collection, storage, or disclosure of User information by third-party sites, applications, resources, or platforms and any loss or damage incurred by the User as a result of the use of any such third-party websites or platforms. iGuroo does not recommend or endorse any third-party links.
  3. iGuroo shall not be liable for any actions of third parties with regard to User’s Personal Information or SPDI which the User may have disclosed to such third parties.
  1. Choice to Opt-Out
  1. iGuroo provides all Users with the opportunity to opt-out of receiving non-essential (promotional, marketing-related) communications from iGuroo on behalf of our partners, and from us in general, after setting up an account.
  1. Governing Law
  1. The terms of this Privacy Policy shall be governed and construed in accordance with the laws of India. Any dispute regarding or arising out of this Privacy Policy shall be subject to the exclusive jurisdiction of the courts in Bengaluru, Karnataka.
  1. Grievance Redressal

Any concern, grievance, or complaints about this Privacy Policy, or about the  Platform may be addressed to our grievance officer. The name and contact details of the Grievance Officer are provided below:

Name: Srinivas Pisipati

Address: 403, 4th Floor, Elemental #337, Sy No. 337 Partly, Puppalaguda Village, Financial District, Nanakaramguda, Telangana – 500032

Email Address: support@iguroo.com

Contact Number: +91 99891 84709

  1. Severability
  1. Each clause of this Privacy Policy is independent of and severable from all and any other clauses. If one or more clauses of this Privacy Policy are held to be unenforceable or invalid under applicable law, such clause shall be excluded from this Privacy Policy. The remainder of the Privacy Policy shall be interpreted as if such clause were so excluded and the balance of the Privacy Policy shall be enforceable in accordance with its terms.
  1. Changes to Our Privacy Policy
  1. iGuroo may revise this Privacy Policy from time to time by updating this page, and iGuroo urges Users to review it periodically to ensure that the User agrees with any such changes that are made by iGuroo. iGuroo will make its best efforts to inform Users of any important amendments by e-mail, message, or notification on the Platform. However, it is the User’s responsibility to check the Privacy Policy regularly to ensure that the User agrees with it and the User’s continued use of the Platform will be deemed to be the User’s acceptance of any changes that are made by iGuroo.

Privacy Policy