PRIVACY POLICY

This Privacy Policy ("Privacy Policy"/"Policy") explains how we collect, use, disclose, and protect the information that you share with us. This Privacy Policy applies to all users of the Platform, including and without limitation, all persons and users who access the Platform for availing its Services (referred to as "Students") or users who access the Platform otherwise (collectively referred to as "you", "your", or "user(s)"). Incase of use of words such as "PIPPAMS", "we", "us", and "our", we collectively mean – a company incorporated in the state of Michigan, USA and all of its affiliates which have the license to host the Platform and offer Services. Your consent to the collection, use, disclosure, sharing, and storing of information described in this Policy, the Terms and Conditions, and any other rules, policies, or guidelines published on the Platform as applicable to you (collectively, the "Platform Terms") is granted to PIPPAMS by accessing and using the Platform, providing your Personal Information (defined below), or by otherwise indicating your agreement when the option is presented to you. PIPPAMS disclaims all liability arising therefrom. In case you unintentionally provided PIPPAMS with your Personal Information before reading this Policy, or if you disagree with the manner in which PIPPAMS uses, stores, or accesses your Personal Information, you can access, edit, or remove it in compliance with this Policy. PIPPAMS will have the sole discretion to delete any information provided by you and revoke your access to the Platform, in case it is in violation to the Platform Terms, with or without informing you. Use of capitalized terms which are not defined herein can be found in the Terms and Conditions. In case of queries relating to this Policy, feel free to contact us at help@pippams.com.

1. Applicability of the Privacy Policy

   All users of the Platform are subject to the terms of this Policy

2. Accessibility to the Platform

   Guests are allowed accessibility to the Platform, without having to create an account or providing Personal Information. We disclaim any liability for the information that is provided by you as a guest, except as otherwise provided under law. In order for you to have complete availability of all features and Services of the Platform, you are required to create an account and provide Personal Information, as requested during registration. We may also request for optional information from you which is discretionary for you to provide. We may keep a record of telephone calls, emails or texts received from or made by you for making enquiries, Feedback, or other purposes for the purpose of rendering Services effectively and efficiently.

3. Utilization of Platform/ Services in case of Minors

   The "Age Requirement" (as defined in our Terms and Conditions) must be fulfilled in order to register on the Platform. In case of a Minor or Child, only your Parent, may register on your behalf, accept all Platform Terms, and grant you access while they supervise you.
   
   With regards to the collection of a Child’s Personal Information, our Services may require the same and we understand that such information has been provided with the consent of the Parent. In case such information has not been provided with the consent of the Parent, kindly contact us at help@pippams.com.
   
   Please email us at help@pippams.com, if your child experiences any kind of abuse or harassment while using our Services so that appropriate action can be taken.

4. Controller of information

   PIPPAMS is the controller of information provided by you while using the Platform and the Services provided by us.

5. Scope of Personal Information

   Any information provided by the user which can be used to identify the user, such as, first and last name, identification number, email address, location, age, gender, and/or phone number entered during the Platform registration or at any point subsequently, shall mean Personal Information. Personal Information is inclusive of Sensitive Personal Information which includes passwords and financial information (apart from the truncated last four digits of a credit or debit card); health information; official identifiers (such as biometric information, an Aadhar number, a driver's license, a passport, etc.); information regarding sexual life; account details and passwords; or other data/ information classified as "Sensitive Personal Data" or "special categories of data" under the applicable law.
   
   We bear no responsibility of privacy of Personal Information provided by you that is not specifically requested by us.

6. Information obtained by us

   We only request Personal Information on a need-to-know basis. We may request the following information

   1. Information sought for registration of account on the Platform such as name, email address, country of residence, username, password, phone number, etc.;
   2. Academic history such as grades obtained during school;
   3. Extra-curriculars opted for profile building;
   4. Communication details such as email address and phone number for correspondence purposes in case of queries, doubts and legal purposes;
   5. Call recording;
   6. Survey responses;
   7. Location;
   8. Age and gender;
   9. Bank account details;
   10. Nationality;
   11. Government issued ID proof.

   Certain information might be collected automatically by us while you browse the Platform. This includes device and log information which means information that web browsers, mobile devices, and servers normally make available when you use our Platform. This information includes the type of browser you are using, your IP address, your preferred language, the website you are referring to, the date and time of your visit, your operating system, and details about your mobile network. When you use our platform, for instance, when you create or modify your account information, we log information about your activity. Moreover, we also collect information regarding your usage of our Platform, your location information, and other publicly available information (such as the information available on social media) regarding you, as permitted by the applicable law.

7. Collection and Processing of Personal Information

   In some circumstances, we process your Personal Information only with your consent. Your consent is requested at the time of collection of your Personal Information, and such processing will take place where consent is obtained, if we need it, in order to collect and process certain Personal Information in accordance with the requirements under the applicable laws. Personal Information provided by you may be processed by us to the extent of complying with the applicable legal requirements. Personal Information may be processed due to any reason which includes but is not limited to the following:

   1. To fulfill your request for Services, follow your instructions, or fulfill other commitments under our contract;
   2. To honor our legal commitments and maintain documentation of our compliance procedures;
   3. It is required by us or a third-party recipient of your Personal Information, provided that these interests do not conflict with your interests or your fundamental rights and freedoms;
   4. Due to your decision to make your Personal Information visible to the public on a Platform feature that is accessible to all users, like a comment section;
   5. To safeguard your essential interests;
   6. To serve public interest;
   7. Your express consent to process your Personal Information in any manner

   You have the authority to withdraw consent for processing of your Personal Information at any point in time in accordance with this Policy. Please be aware that we reserve the right to withdraw or stop providing our Services to you upon your consent withdrawal, if it means that we are unable to continue providing our Services to you. By sending a written request to the address listed in the "Grievances" section below, you may withdraw consent. You may be informed of the consequences of withdrawing your consent after your request has been received. Your request for withdrawal will be handled once you consent to it.

8. Usage and Sharing of Personal Information

   Your Personal Information is used and processed by us as mentioned below:

   1. In order to provide you with an access to our Services and the Platform, we use your Personal Information. Such information is used, among other things, to create and manage your account, offer customer support, process purchases made on the Platform, check user information, and fix any issues that may arise with the Platform. Kindly note that the execution of a contract between you and us, your consent, or, where applicable, our legitimate interests in the appropriate administration of our Platform, serves as the legal basis for this processing.
   2. We use the information you provide us with, to enhance and personalize the Platform and our Services. Some examples of these efforts include automatically updating the Platform to the latest version and developing new features in response to the insights into the Platform usage. Additionally, we use your information to guard against fraud, abuse of our Platform or network, illegal activity, threats to PIPPAMS or a third party's property, and other violations that could endanger the safety of PIPPAMS, its users, or others. We also use this information to prevent, detect, investigate, and take appropriate action in these cases. Kindly note that the execution of a contract between you and us, your consent, or, where applicable, our legitimate interests in the appropriate administration of our Platform, serves as the legal basis for this processing.
   3. To develop more precise and custom-made marketing programs for our Platform. This includes, communicating latest offers, products, Services, and receive Feedback. Kindly note that the execution of a contract between you and us, your consent, or, where applicable, our legitimate interests in the appropriate administration of our Platform, serves as the legal basis for this processing.
   4. We might need your Personal Information to handle legal matters or defend against legal claims, whether in court, administrative, or other proceedings. The legal basis for this processing is our legitimate interest to protect and assert our rights and those of others, including you.
   5. We can also use your Personal Information in order to minimize risk and to obtain professional advice. Our legitimate interest in the appropriate protection of our business and Platform serves as the legal basis for this processing.
   6. We may use your Personal Information, after obtaining your consent, as per the terms of this Policy or otherwise.

   We only disclose/ share the Personal Information obtained in accordance with the provisions of this Policy in the manner described below. We do not sell or otherwise reveal Personal Information collected from you in exchange for money or other consideration. Furthermore, only authorized PIPPAMS representatives with a need-to-know basis utilize any information acquired from you and as consented by you. We may examine any unauthorized use or disclosure of information discovered by us, or upon your complaint as indicated in the 'Grievances' section below, and take the relevant action in accordance with the applicable laws.

   1. In order for us to provide enhanced Services, we might share you Personal Information with our affiliates, subsidiaries and partner organisations. They might process your Personal Information on our behalf.
   2. In order to provide support services to you or us, or to carry out services on our behalf, either directly or through the Platform, we may disclose information about you to third-party vendors or service providers (such as consultants, payment processors, and other service providers and integrated services). Assistance with customer service, business and sales analysis, website functionality support, payment processing facilitation, contest, survey, and other platform features are a few examples of these services. These third-party vendors are obliged to process and use the information in compliance with this Privacy Policy, and they are not permitted to use it for any purpose other than the one for which it was provided.
   3. We might provide information about you in response to a request from the government or a court order. In addition to the aforementioned, we reserve the right to reveal such information when we have a good reason to believe that doing so will help us to comply with the applicable laws, rules, court orders, requests from the government and law enforcement agencies; to protect and defend the rights and property of PIPPAMS or a third party; to ensure the safety of PIPPAMS, its users, employees, or others; or to stop, detect, look into, and take action regarding illegal activity, fraud, misuse, or unauthorized use of our Platform. We assure you that we will try to provide you with prior notice before such disclosure in respect to such a request, to the extent permissible.
   4. In case of a merger, acquisition, business transfer, sale of company assets, in part or in full, with another company, or in the event of bankruptcy of PIPPAMS, such user information would likely be one of the assets that is transferred or acquired by a third party. In the event that any of these things occurr, this Privacy Policy would still be in effect and your information would still be used, but only in accordance with this Privacy Policy, by the party that received it and would not make PIPPAMS liable for any breach of Personal Information.
   5. We may use your Personal Information for advertising purposes

   We may share your Personal Information for purposes not specified in this Policy, but only after obtaining your permission.

9. Cross-Border Data Transfer

   PIPPAMS hereby reserves the right to disclose select personal information, including but not limited to school name, age, grade, nationality, email address, and residency, to Essai, the designated SubLicensor of PIPPAMS operating in India. This disclosure is strictly limited to a period not exceeding 10 years.

10. Duration of storage of Personal Information

    Taking into account the reasons for which it was originally collected, we keep your Personal Information with us for a maximum of 10 years. The length of time that Personal Information must be kept depends on how it is used and whether it complies with the applicable laws. Furthermore, Personal Information may be kept in order to prove, utilize, or protect our legal rights. Additionally, once the initial reason for collection has been satisfied, we reserve the right to delete your Personal Information before the retention period ends.

11. User’s rights and choices

    The Personal Information you give us is always entirely up to you, and you always have the choice to update or remove it. Kindly note that you might not be able to access the Platform or any of its features, partially or fully, if you choose not to provide us with the necessary information.
    
    Additionally, you will be able to select the type of communication you want to receive from us as well as whether you want to receive any communication at all. You might not be able to restrict some communications considering they are necessary for security or legal reasons, such as modifications to different legal agreements.
    
    It is your sole discretion to alter your web browser's default settings if they are set to "accept cookies". You can reject or delete cookies from your browser. Please be aware, though, that if you reject, delete, or disable cookies, some Services provided on the Platform might not work or be accessible to you.

    You have the following rights with respect to your Personal Information specified below:

    1. Confirmation and access to the Personal Information available with us.
    2. Rectification of Personal Information available with us.
    3. Right to restrict or prevent from continuing sharing of Personal Information.
    4. Right to withdraw/ delete your Personal Information from our Platform, except as otherwise stated in this Policy. This might result in complete deletion of your account, which shall be non-retrievable.
12. Security of Personal Information

    On the Platform, we take commercially reasonable measures to secure your Personal Information. Kindly note that considering our security protocols, we occasionally might ask for identification before disclosing to you any Personal Information that is legally yours. However, it is important to note that while we employ various security protocols, no method of data transmission over the Internet, wireless transmission, or electronic storage can be guaranteed to be entirely secure. We cannot assure or warrant the complete security of any Personal Information collected through our Services.
    
    By using our Services and providing us with your Personal Information, you acknowledge and accept the inherent risks involved. You do so at your own discretion and risk. We also disclaim any liability arising out of breach of Personal Information arising from a third-party act or your usage of third-party applications/ website for accessing the Platform.

13. Modifications to the Policy

    Our Policy may change from time to time on the basis of our business goals. Unless you have instructed us otherwise, we may, at our discretion (and unless mandated by applicable laws) email you periodic reminders of our notices and conditions. However, we strongly advise you to check our Platform frequently to stay up to date on any changes. Our current Policy is applicable to all information we currently have about you and your account, unless specified otherwise. Nonetheless, we stand by the assurances we give, and we will not significantly alter our procedures or policies to make them less secure for consumer data that we have previously collected.

14. Grievances

    For any inquiries concerning this Policy, your rights, privacy of your data, or grievances pertaining to privacy regarding the Platform, feel free to send us an email to help@pippams.com with a detailed description to Kritvi Rana, Head of Partners and Program.