Virohan Private Limited (hereinafter referred to as "we", "our", "us" and "Virohan" and shall include any affiliates) understands the privileged position we are in while providing the services through our website, platforms and App(referred to as "App") and are committed to protecting the information and data shared by all of our users (hereinafter referred to as "you", "yourself" and "User").

In light of the same, we have created this privacy policy ("Privacy Policy") which is in compliance with the Information Technology Act, 2000 ("IT Act"), Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the "SPI Rules"). The privacy mechanism outlined in this Privacy Policy, as amended from time to time, identifies personally identifiable or personal information that may be collected, how such information is used, collected, stored, processed, disclosed, transferred and the choices you have regarding our use of this information.

Please read this Privacy Policy carefully as by providing your consent to it, you agree to the collection, storage, processing, disclosure, use and transfer of your personal information as set out in this Privacy Policy. Any information provided to us or collected by us is subject to this Privacy Policy. If you do not agree to any or all of these terms, please write to us on info@virohan.org. Should you continue to access and use the App and provide your personal information, such act would constitute your consent to the terms contained herein.

This Privacy Policy shall be read in conjunction with the Terms of Use as applicable to the App.

Your Consent

A prerequisite for usage of the App and the services provided on the App is the acceptance of this Privacy Policy. This Privacy Policy shall apply to all individuals and entities that use the App. After providing your consent to the Privacy Policy, you may:

access the App;
register for programs offered on the App in the manner as provided for in the Terms & Conditions;
submit any information to Virohan; and
use any features and services offered by Virohan on the App.

If you are registered on the App, we may need to send routine communications to you, such as administrative messages through email and notifications posted on the App or through other means available, including text and other forms of messaging. Though we prefer to communicate with the users via email and SMS, as may be deemed necessary, you agree to receive our phone calls or any other mode of communication as may be deemed appropriate by us.

When you register on the App you also consent to allowing us to periodically send emails, SMS communications, WhatsApp messages or messages through any other means of communication available to Virohan based on the details provided by you and the nature of services opted for by you, now or in the future, for relaying information which you may find useful, interesting or in line with your interests. If you do not wish to receive promotional information from us, you can, at any time, choose to opt out of receiving such promotional communications by following the process mentioned in the promotional communication or by contacting us on info@virohan.org or clicking on the 'unsubscribe' button.

You must ensure to provide us with the correct or up-to-date information at the time of registration on the App. This will allow us to contact you for further correspondences with respect to the services provided on the App or otherwise. We are not responsible for any inaccurate information you provide to us, which may affect your experience when using the App and the services.

If, at any time, you want to access, update, modify or eliminate any information provided by you, you may do so by writing to us on info@virohan.org. You may also withdraw your consent for use of your personal information provided and stop using the services for which consent is required. Virohan reserves the right to stop providing any services to which consent has been withdrawn.

You may also write to us at info@virohan.org with a request for accessing, updating, modifying or deleting any information shared by you.

Personal Information and What Types Of Personal Information Do We Collect About You

"Personal information": means any information that relates to an individual, which directly or indirectly, in combination with other information available or likely to be available with us, is capable of identifying such individual or such other information that is considered as Personal Information under applicable laws.

"Sensitive Personal Information": means any Personal Information of an individual, which consists of information relating to financial information such as bank account, credit card, debit card or other payment instrument details; passwords; biometric information; sexual orientation; physical, physiological and mental health condition; and medical records and history or such other information that is considered as Sensitive Personal Information under applicable laws. Information freely available or accessible in public domain is not treated as Sensitive Personal Information.

Depending on who you are (e.g., a merchant, customer, cardholder, consumer, supplier or business partner) and how you interact with us (e.g., telephone, IVR, API, online or offline), we may collect, use, receive, store, analyse, combine, transfer or otherwise process different categories of your Personal Information (including Sensitive Personal Information).

Below is a table of the categories of Personal Information and Sensitive Personal Information which we may collect about you

Category of Personal Information	Which includes information such as:
Identity and Account Log-In Information	Full name(s), title, age, user ID, gender and your date of birth.
Contact Information	Telephone/mobile number(s), permanent and current address(es), state/city of residence, country, pin code, email address(es), and chosen billing address(es), details of parents/guardian.
Financial Information	Personal bank account numbers and bank account data which may include e-nach, NEFT, IMPS and UPI ID details, credit or debit card information, including the credit or debit card number, card type, expiry date on the credit or debit card, card token. - Financial information is collected on a need basis and subject to provisions of applicable laws
Identification Information or other Sensitive Personal Information	Know Your Customer (KYC) documents including all proofs of identity and address, photograph, Permanent Account Number (PAN), GST Number, etc. Other identifiers such as cookie id, device id etc. or any other identifier from a third party.
Payment Information or Transactional Information	Payment gateway ID, name of issuing bank, mode of payment, the date, currency and amount of the payment was transaction(s), whether the transaction was successful, and other information provided by you directly or indirectly to us or provided to us by banks, payment gateway or other service providers or business partners.
Usage and Technical Information	IP addresses, application, device or browser type, versions and configurations, operating systems, device brand and model, time zone setting, geo-location information, content, unique identifiers associated with your device(s) and pages that you access on the App and the dates and times that you visit the App and paths taken. During the use of the App via the internet, we may automatically receive technical information about your computer/device, including your IP address, your computer operating system, time-zone, browser type and browser plug-in details due to the communication protocol settings on the Internet. We may also collect information regarding the pages you viewed, the web addresses from which you arrive or click through to, time spent on certain pages, download errors and page response times. All these information help us analyze user's trends and preferences, and thus assist us in improving our services.
Credit related Information	Credit or affluence information or assessment provided by third parties such as financial institutions or account aggregators or similar third parties as permitted under applicable laws of India including our business partners, independent service providers and our business partners.
Marketing and Communications Information	Communications with customer service support, behavioural data (for example, data collected using cookies), information about promotions, surveys, promotional campaigns and records of your decision(s) to subscribe to or to withdraw from receiving marketing materials, if any.
Information in your device(s)	We may also access your location data in your devices to enable you to access our services after seeking necessary permissions as permitted under applicable laws. We may also collect, use, process and/or share non-Personal Information and/or anonymized and/or aggregated data such as statistical or demographic data in accordance with this Privacy Policy.

Virohan may also keep records of telephone calls received and made to their personnel for provision of the services or for making inquiries, orders, or other reasons for the purpose of administration of services.

Any data that is freely available to the public or made available to Virohan through public sources or by way of right to information will not be considered as personal information. We do not knowingly collect personal information from children, and all information uploaded by a user shall be deemed to be uploaded in compliance of all applicable laws and any children uploading personal information shall be deemed to be doing so with the consent of their parent or guardian.

In case we collect any Sensitive Personal Information in order to provide our services or products to you, such as some categories of Financial Information including bank account numbers, last 4 digits of credit/debit card and details. In such cases, we ensure that such Sensitive Personal Information is collected, used, processed, stored and/or disclosed in accordance with this Privacy Policy and in compliance with applicable laws of India.

Virohan may include other optional requests for information from the Users with a view to customize the App to deliver personalized information to the User and for other purposes as mentioned in this Privacy Policy. Any such additional personal information will also be processed in accordance with this Privacy Policy.

Virohan shall not be responsible in any manner for the authenticity of the information including the Personal Information or Sensitive Personal Information supplied by the User to Virohan. If a User provides any information that is untrue, inaccurate, not current or incomplete (or becomes untrue, inaccurate, not current or incomplete), or Virohan has reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, Virohan has the right to suspend or terminate use of features or services on the App at its sole discretion.

Virohan has implemented reasonable security practices and procedures that are commensurate with the information assets being protected and with the nature of our business. While we try our best to provide security that is commensurate with the industry standards, because of the inherent vulnerabilities of the internet, we cannot ensure or warrant complete security of all information that is being transmitted to us by you. However, Virohan will take all reasonable measures to ensure that your information is not modified or used for any unauthorized purposes.

How do we collect your Personal Information?

How we collect Personal Information (including Sensitive Personal Information) will depend on the following broader situations:

If we receive or collect it directly from you

We collect Personal Information (including Sensitive Personal Information) directly from you in different ways on the App or through product or service offerings. For example, you give us your Personal Information (including Sensitive Personal Information) when you:

give us your Contact Information so that we can contact you about our services and products;
conclude a contract or verify to us who you are (whether by email, phone or electronic verification);
provide your Personal Information (including Sensitive Personal Information) on the Apps, or by connecting to us through other modes of communication, both online or offline;
provide your Personal Information (including Sensitive Personal Information) on the checkout pages in order for us to complete the transaction(s);
provide your Personal Information (including Sensitive Personal Information) when you send us a support request including filing a complaint or for resolution of dispute with us or raise any query;
apply for our products or services directly with us or through our business partners (such as university websites, offline campuses, resellers or business partners);
are prompted to give us your Identity and Account Log-In Information, Contact Information, Financial Information, Identification Information, and/or Payment Information on our web checkout /payment pages or via other similar channels to complete a transaction;
enter a competition, promotion or survey or you agree to receive marketing materials to be sent by us; or
access, use and/or browse our App.

Collection from third parties, business partners or from publicly available sources

We obtain Personal Information (including Sensitive Personal Information) through third parties including our business partners, independent service providers or from publicly available sources, as permitted under applicable laws of India.

Use of Personal Information

Virohan will collect, process and retain your personally identifiable information to the extent that it is necessary to fulfill our services to you, as is permitted under applicable laws and for regulatory purposes. Any personal information submitted by you on the App or collected by us will be used only for the purposes mentioned below:

For registration of the User on the App;
To carry out our obligations arising from your requests for services on the App;
To improve the App's functionality, and to customize your future experience with us;
To make sure that our App's content is presented in the manner that is most effective for you;
To deliver personalized information and target advertisements to the user;
For conducting research on efficient administrative practices on the App;
To communicate with you about any changes to our services, special offers;
Non-personally identifiable information, exclusively owned by Virohan may be used in an aggregated or non-personally identifiable form for internal research, statistical analysis and business intelligence purposes including those for the purposes of determining the number of visitors, and Virohan may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates;
Ensuring that the provisions of the Terms of Use and Privacy Policy are complied with by all users;
To record, support and facilitate your participation in the services you select, track your preferences;
To notify you of any updated information relating to the products and services on the App;
To assist you with customer service or technical support issues;
To follow up with you after your visit to any campus of Virohan;
To otherwise support Your relationship with us and/or to prevent fraud and unlawful use;
To comply with our legal, regulatory and contractual obligations;
For our legitimate business interests (where permissible by law) or those of a third party;
Where you have given us explicit consent to do so.

Disclosure of personal information

Virohan, in the course of performance of the services may need to disclose/ transfer certain personal information to third parties for the purposes mentioned in this Privacy Policy and the Terms & Conditions. The third parties to whom such information may be disclosed include:

Third party service providers to perform various services on our behalf or assist us in delivering our services to you. These service providers help with tasks such as marketing, advertising, customer communications, infrastructure and IT services, personalizing and optimizing your experience, processing payments, providing customer support etc. for the purpose of ensuring services are available on the App.
To our affiliates in India or in other countries who may use and disclose your information for the same purposes as us.
To our employees for the purpose of ensuring provision of services on the App, subject to the fact that our employees shall be bound by obligations of confidentiality.
To government institutions/ authorities to the extent required:
- under the laws, rules, and regulations and/ or under orders of any relevant judicial or quasi-judicial authority;
- for the purposes of prevention, investigation and prosecution of cyber incidents;
- for reporting any offenses committed by users;
- to protect and defend the rights or property of Virohan;
- to enforce Virohan's Terms of Use (of which this Privacy Policy is also a part);
- for verification of any information provided by Users; or
- when Virohan, in its sole discretion, deems it necessary in order to protect its rights or the rights of others.
To third party ad servers, ad agencies, technology vendors such as Facebook, Google etc., and research firms to serve advertisements to the user.
Where substantially all our assets are 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, Virohan would attempt to ensure that the third party acquiring Virohan follows the provisions of this Privacy Policy and process your personal information as set forth in this Privacy Policy.
Details like your name, testimonials, exam scores, and other relevant information about exams/courses you have pursued or plan to pursue, may be shared for promotional purposes. This may include sharing across various media channels such as social media platforms, television commercials, digital advertisements, hoardings, interviews, live events, and on our mobile app or websites. You consent to this sharing of Personal Information for promotional activities that support Virohan's business strategy.
We may disclose account information if we believe it is necessary to identify, contact, or take legal action against individuals violating our terms and conditions of service or causing harm to our rights, property, or users.
When making purchases, your information will be transferred to third-party payment processors. These payment gateways may also access your purchase details and sensitive financial information like your credit/debit-card details are transacted upon secure sites of approved payment gateways which are digitally under encryption.
If you express interest in availing an educational loan or other financial services, we may share your personal information with financial institutions and other third parties in compliance with applicable laws and as necessary. This information will be used for assessing your eligibility for loans, processing your loan applications, and facilitating the loan approval process.

How long will personal information be retained

Virohan may store your Personal Information (including Sensitive Personal Information) for as long as the same is required and is permissible as per the applicable laws in India for the fulfilment of purposes for which we collected it. The retention of Personal Information (including Sensitive Personal Information) by Virohan is determined by considering compliance with legal (that is, contractual or statutory or regulatory requirements), accounting and compliance reporting requirements.

Security Policy

We are committed to safeguarding your Personal Information and implement reasonable security practices and procedures to protect it from unauthorized access, alteration, disclosure, or destruction. In line with this, App takes necessary steps, within its limits of commercial viability and necessity, to ensure that the user's information is treated securely. We store and process your personal information on AWS cloud servers, Google Cloud Platform and other cloud service providers within and outside India. Some of the safeguards We use are firewalls and encryption using SSL, and information access authorization controls. We use reasonable safeguards to preserve the integrity and security of your information against loss, theft, unauthorized access, disclosure, reproduction, use or amendment. To achieve the same, we use reasonable security practices and procedures as mandated under applicable laws for the protection of your information. Subject to applicable laws, the information you provide to us may be stored on our secure servers located within or outside India.

Virohan takes careful precaution to protect our Users' information from unauthorized access, improper use or disclosure or unauthorized modification. To prevent unauthorized access, we have put in place the industry-standard security technology and procedures to safeguard the information we collect online including technical, operational and physical security controls. We store your personally identifiable information on the computer servers placed in a secure environment. Even though we have taken significant steps to protect your information and specifically your personally identifiable information, no company, including the App can fully eliminate security risks associated with personal information. We further disclaim any responsibility for any intercepted information sent via the internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner.

However, it is important to note that no method of data transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security, and you are encouraged to take precautions to protect your information, such as using secure passwords and keeping your devices safe.

User Responsibilities

If any user gains access to our APIs, whether secured or unsecured, without explicit authorization, such use shall constitute a violation of our Privacy Policy and Terms and Conditions. Unauthorized access, use, or disclosure of our APIs is strictly prohibited, and we reserve the right to take appropriate legal action against any individual or entity found violating these terms.

Third Party Links

The links to third-party advertisements, third party Apps or any third-party electronic communication services (referred to as "Third Party Links") may be provided on the App which are operated by third parties and are not controlled by, or affiliated to, or associated with Virohan unless expressly specified on the App. If you access any such Third-Party Links, we request you review such App's privacy policy. Virohan does not have oversight of these third-party websites, plug-ins and applications and we are not responsible for their collection, processing, usage or transfer of your Personal Information or Sensitive Personal Information. Any information collected by a third party in this manner is subject to that third party's own data collection, use, processing and disclosure policies and you must make yourselves conversant with those.

Marketing

In relation to the products and services provided by us including our business partners or affiliates with whom we share your Personal Information (including Sensitive Personal Information) as per this Privacy Policy, you may receive marketing communications from Virohan or such other business partners or affiliates of Virohan by messages, SMS email, or through other digital modes, on the App or other platforms including social media platforms, if we have received or you have provided us your Personal Information (including Sensitive Personal Information) as per this Privacy Policy. Virohan's business partners or affiliates may market their own products or services including third party products and services using such communications. The provision of such marketing activities shall be in accordance with the applicable laws of India. For marketing activities done by Virohan, we will keep a record of marketing and communication information. You are entitled to opt out from receiving such marketing communications by either clicking on an opt-out link or un-subscribe the link, if any such link is provided, or write to us at info@virohan.org.

Virohan may also use Marketing and Communications Information in order to improve and customize the content of any ads, promotions and advertising that may be of interest to you.

The App collects information about your use of our services, interactions with us, and details about the device you use to access our services. This includes your activity on our App, such as courses, study materials, and search queries; customer service interactions, IP address (which may indicate your general location), browser information, and data collected through cookies, web beacons, and other technologies. Such information may be stored in server logs in the form of data which will help us understand the use and number of Users visiting the App. The App uses temporary cookies to store certain data (that is not sensitive personal data or information) that is used by us for maintenance of the App and its features as well as research and development, and for provision of any services available on the App. In the course of serving advertisements or optimizing Services, we may allow authorized third parties to place or recognize a unique cookie on the Your browser which may enable them to collect information about your visits to our App. We do not store personally identifiable information in the cookies. Some or all data collected may be shared with the sponsors, investors, advertisers, developer, financing partners, strategic business partners of Virohan, in compliance with applicable laws.

Amendment of Privacy Policy

Virohan may update or amend this Privacy Policy at any time, with or without advance notice. Please revisit this page periodically to stay aware of any changes to this Privacy Policy.

Should you have any concern or reject the changes in the Privacy Policy you can refuse to accept the amendments and opt for withdrawing your Personal Information by writing to the Grievance Officer. By continuing to use the App after any changes to the Privacy Policy, you agree to accept and abide by those changes.

Governing Law and Jurisdiction

Any disputes arising under this Privacy Policy shall be governed by the laws of India. In the event of any dispute arising between the parties with respect to this Privacy Policy, the same shall be referred to a sole arbitrator and the arbitration shall be in accordance with the Arbitration and Conciliation Act of 1996. The language of arbitration proceedings shall be English. The seat and place of arbitration shall be Faridabad and the decision of the arbitrator shall be final and binding on the parties herein. Subject to the arbitration clause above, this Privacy Policy shall be subject to exclusive jurisdiction of courts in Faridabad.

Minor's Privacy

Our services do not address anyone under the age of eighteen (18) years ("Minor"). We do not knowingly collect personally identifiable information from Minors. If you are a parent or guardian and you are aware that your Minor has provided us with Personal Information, please contact us. If we discover that a Minor has provided us with Personal Information, we will delete such information from our servers immediately.

Grievance Officer

If you have any complaints or grievances or concerns with respect to the App or this Privacy Policy, please inform such matters to the designated Grievance Officer as mentioned below in writing or through electronic mail:

Name: Anshul Pandey

Contact Details: info@virohan.org

Designation: Manager, Legal