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Privacy Policy

Effective Date: Feb 2, 2022

Smavy Private Limited is an online tutoring company (“The Company/We/Us”), which imparts education through the digital medium. The Platform (Smavy Classroom) through which such online tutoring services are imparted, is operated by the Company.

Any person who accesses or uses the Platform shall be referred to as a “User”/You/Yours”.

Your access and/or usage of the Platform indicates that you have read, understood and agreed in full to this Privacy Policy.

In the pursuance of our legal commitments, we have drafted and displayed this Privacy Policy and You agree that any information You share with us, is only after voluntarily consenting to this Privacy Policy.

If You do not agree with this Privacy Policy, then please do not access or use the Platform.

This Privacy Policy governs the privacy practices adopted and implemented by the Company.

The Privacy Policy and the Terms of Use, as displayed on the Platform, are to be read together and constitute a legally binding agreement between You and the Company.

Definitions

“Personal Information” means and includes information to which the Privacy Act, 1988 (“Privacy Act”) applies or information to which any other Privacy Legislations apply.

Privacy Legislations” include all laws that deal with privacy and confidentiality of information relating to individuals. Privacy Legislations include but are not limited to:

  1. The Privacy Act including the National Privacy Principles.
  2. The Privacy and Data Protection Act, 2014 (Vic) and the Information Privacy Principles contained therein.
  3. The GDPR Regulations
  4. Sensitive Data and Personal Information Rules, 2011
  5. The California Consumer Privacy Act.

Services” includes the provision of online tutoring services through the Platform owned and operated by the Company.

What Personal Information May Be Collected

In the course of providing services, the Company may have to collect certain Personal Information from you. This information would, inter alia, include the following:

  1. Personal Details: The Company may collect personal details including but not limited to name, age, gender and educational credentials.
  2. Contact information:The Company may collect any contact information from You including but not limited to your phone number and e-mail address.
  3. Information to provide the services:The Company may collect information regarding the queries You may have or the solutions You require, in order to deliver You seamless services.
  4. Financial Information: Payment details including but not limited to credit card information or bank-account details and transaction history may be collected.
  5. Background/Authorization Information: including relevant information including but not limited valid Working with Children Checks, accreditations, qualifications and other similar verification documents/information.
  6. Photographs and Recordings: We may record lessons for future purposes, collect a photograph of Yours to be used in association with Our marketing services, capture still images of the lessons and use the same to further the promotion of Our services.
  7. Geographical Location: We may collect information regarding Your geographical location.
  8. Other information:We may also collect information about your IP address and the browser you are using.

You agree and voluntarily consent to provide correct and accurate information. We shall not be liable for any inaccuracies in the information provided by You or any direct or indirect consequences of such inaccurate information. If we find out, either on our own or through any other means that You have provided false information, we shall be at liberty to restrict your access to the Platform and our services.

Please note that We collect the Personal Information solely for the purposes of providing Services as outlined under this Privacy Policy. You may choose to remain unidentified or anonymous, if You wish so. However, in such circumstances, We may not be able to provide You seamless Services.

 

How does the Company collect the Personal Information

  1. Personal Information provided to the Company

You willingly consent to provide the Company your Personal Information when you provide Your Personal Information on the Platform.

      2. Personal Information collected automatically

Some data such as your browser type, internet protocol address used, your usage patterns may be automatically collected by the Company using cookies. Cookies are tiny pieces of information which a website sends to Your computer. We use Cookies to provide you with a more personalized experience on the Platform. You can change Your browser settings and choose to disable sharing of information through cookies. Sometimes, tracking pixels including but not limited to browser HTML pixels may be used to collect information about user behaviour on the Platform. Pixels are tiny units which measure the digital images and graphics you see on a website. You agree that Cookies and Pixels are used to improve your experience as an end-user and consent to the use of the same.

      3. Lessons Recording

We may use third-party tools or software to record the audio and/or video from a lesson through a User’s computer/mobile camera and/or microphone to collect information regarding the User’s interaction during a lesson and the User experience. We may also record troubleshooting instances and issues that a User faced. We use the aforementioned information to improve Our Services, quality assurance purposes, debugging, enhancement of user experience and user optimization.

What Purposes is the Personal Information Collected Used For?

The purposes for which the Company uses the data collected are:

  • Verifying your identity: The contact details collected may be used to verify your identity. You agree that such verification is essential for the Company to run the Platform smoothly and to comply with its legal and other obligations.
  • Offering You Services in a smooth and effective manner. Your information may be used by our tutors and administrative staff to contact you. You consent to such communications.
  • Personalizing your experience on the Platform: The information collected from you would help the Company in personalizing your experience and providing you a better and more efficient service.
  • Improving the design and style of the Platform.
  • Developing new products, features, services and functionality.
  • Communication regarding ongoing and upcoming courses and the schedule of online classes.
  • Scheduling communication, test, interview or any such communication related to admission or marketing

You agree that the aforementioned purposes are valid and give Your informed consent to the collection of Your Personal Information for such purposes.

Log Files

We follow a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services’ analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users’ movement on the Platform, and gathering demographic information.

How long will the Personal Information collected be retained by the Company?

The Company shall not retain Your Personal Information longer than is required for it to fulfill the purposes as outlined under this Privacy Policy and the terms and conditions.

Any information that is provided by you may be retained by the Company for:

  • Providing the Services; and/or
  • For meeting its obligations under the applicable law.
  • To intimate you about any ongoing or upcoming courses that we may have.

Even if you stop accessing or using the Platform, the Company may have to retain the information provided by you for a short period of time until the same can be erased from its servers, and for compliance with its obligations under applicable law (if any).

If you want to withdraw the consent granted to the Platform for collecting and processing Your Personal Information please notify the Company at hello@smavy.com. Once you discontinue the use of the Platform or withdraw your consent, the Company may choose to retain your personal information for such period of time, as is mandated by the law, solely for legal compliance purposes and shall thereafter delete the same.

Processing of the Personal Information collected by the Platform

All Personal Information that is shared by you on the Platform may be processed by the Company, solely for the purposes of providing You Services. You can choose at any point of time to cancel your consent for the processing of the Personal Information shared by You on the Platform, by sending an email to hello@smavy.com.

 

Whom does the Company share Your Personal Information with?

The Company may share Your Personal Information, with:

  1. Service Providers: The company may share your information with third parties who the company has contracted with for delivery of Services.
  2. Employees/Consultants: The Company may share your information with its employees and consultants.
  3. Parents/Legal Guardians: The Company may share Your information with Your parents/legal guardians, if You are less than 15 years old.
  4. Compliance with law: The Company can share your information when compelled by a government agency, law, regulation, a court or other legal process:
  • To enforce our Terms of Use or any other agreements we may have with you;
  • In order to investigate, respond to or resolve problems or inquiries or
  • defend our interests and when you otherwise consent.

Overseas Disclosure

We may share, disclose, store, process and/or transfer some or whole of Your Personal Information to overseas territories including but not limited to India solely for the purposes of providing Our Services as outlined under this Privacy Policy and the Terms of Use as displayed on Our Platform.

You consent to Us disclosing, storing, processing and/or transferring Your Personal Information to overseas territories in accordance with this Privacy Policy.

When Your Personal Information is transferred, stored or processed overseas, then it shall become subject to the laws applicable in such overseas territories. You shall not hold us liable for not subjecting such Personal Information to the Privacy Act.

Rights of the User

You shall have the following rights under this Privacy Policy:

  1. Right to Request access to Your Personal Information: You may, at any point of time, after You have consented to the collection of Your Personal Information, request the access to the same, by sending an email to hello@smavy.com. The Company shall provide you with a reasonable access to Your Personal Information within 7 working days or within such timeline as mandated under the applicable law.
  2. Right to Request correction of Your Personal Information: You may, during anytime, after You have consented to the collection of Your Personal Information, request us to correct or update the same, by sending an email to hello@smavy.com. You shall be solely responsible for the failure to get Your Personal Information corrected or updated.
  3. You may request us to delete Your Personal Information by sending us an e-mail on hello@smavy.com
  4. You may request us to restrict the processing of Your Personal Information or raise objections related to the processing of Your Personal Information.
  5. You may request that we transfer the Personal Information that We have collected to some other organization or directly to You.

 

California Consumer Privacy Act (CCPA)

If You are a California based User, among other rights, You also have the right to:

  1. Obtain disclosure regarding the specific categories and pieces of Personal Information collected in reference to You.
  2. Prohibit the selling of Your Personal Information, if such sale is happening.

  

How do we protect your information?

We protect Your information by employing the following measures:

  1. We have put in place various physical and technical security measures to protect the Personal Information we collect from you.
  2. We require those with whom we share Your Personal Information to enter into confidentiality arrangements with us so that they do not disclose Your personal information.
  3. By complying with all applicable legislations, including but not limited to the GDPR Regulations and the Australian Privacy Act, 1988.
  4. By obtaining SSL and other such appropriate security certificates.

 You acknowledge and agree, that the Company cannot possibly guarantee absolute protection against loss of information. As internet is susceptible to unforeseen security issues, we can only make reasonable efforts to protect Your Personal Information, but cannot give an absolute guarantee regarding the same.  We shall not be liable in the event, Your Personal Information is unauthorizedly disclosed on account of improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss of information, or any security breach which is beyond the reasonable control of the Company.

Third Party Websites

Some content on the Platform may contain links to third-party websites or applications.  If You choose to click on such links, You would be re-directed to a third-party website. Please note that, Our terms of use and privacy policy cease to apply as and when You are redirected to a third party website. You are advised to read the privacy policy of such third-party website before You submit any Personal Information on such a website. We shall not be responsible for any loss of information which may occur on such third-party websites.

Children’s Information

We do not knowingly collect personal information of children below the age of 13. We take extra-precautions to prevent the unauthorized disclosure of any information we collect from the parents/guardians of the children, which may lead to a personal identification of the child. The parents should monitor/supervise the online activity of the children and make sure that our admission form is filled only under the supervision of parents/guardians. We hereby clarify that this Privacy Policy forms a legally binding agreement between the parents/guardians and the Company. We do not assume any liability for any untoward or improper online activity of the children. Any false information entered into by the child, shall be the parents’ liability and responsibility.

Changes to Privacy Policy

There may be changes to this Privacy Policy from time to time. The last effective date shall be highlighted at the top of policy information.

Redressal of Grievances

If you have any questions or grievances regarding about Our Platform, the content thereof, our data handling policies, or about our Services, you can reach out to The Grievance Officer of the Company customer support at hello@smavy.com.

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