PRIVACY POLICY

Last updated February 18, 2022

1. Introduction:

Lyka Learning LLP (hereinafter referred to as “the Company”) values all personal information provided by you. This document sets out the Company’s policy in relation to the receipt of personal information and accordingly applies to all personal information collected from Users as defined in the Terms of Use. The term ‘you’ used in this policy refers to all such persons from whom information is collected.

The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (hereinafter referred to as “Rules”) protect the privacy of an individual by controlling the manner in which personal information may be collected, held, processed, stored and used. Accordingly, any personal information collected and recorded by the Company in relation to you, will be subject to regulation by the Rules.

2. Meaning of personal information:

Personal information shall mean any information that relates to a natural person, which either directly or indirectly in combination with other information available or likely to be available with the Company, is capable of identifying such person.

3. Type of personal information collected:

The Company may collect such personal information from you as may be required for the lawful purposes specified below, including but not limited to the following:

▪ Name

▪ Contact details (including email address and phone number)

▪ Address and Identity proofs (e.g. passport copy)

▪ Age

▪ Correspondences exchanged with you

In addition to the above, we may collect information through our website by using cookies, clicktrails, data collection tags and directives (“Non-Personal Information”).

4. Purposes for collection and usage of information

The Company will use personal information that is collected for various lawful purposes including but not limited to the following purposes.

▪ Recovering outstanding dues as and when necessary;

▪ Creating a database of Users;

▪ For sending newsletters, circulars, bulletins and emails regarding the Company activities.

5. Disclosure of personal information:

The Company may transfer and/or exchange your personal information to and/or with all such persons and/or entities as may be required for the aforesaid lawful purposes including but not limited to the following:

▪ Any employee /office bearer/consultant of the Company and/or its affiliates;

▪ Advocates / Counsels/ accountants and other professionals dealing with the Company in the course of the Company’s work.

▪ Any agent, contractor or third-party service provider who provides administrative, telecommunication, computer, financial intermediary, payment or other services to the Company in connection with the Company’s business;

▪ Any other person to whom the Company believes it is necessary to share the information with, provided that such person is under a duty of confidentiality to the Company with an obligation to keep such information confidential;

▪ Any person to whom the Company is under a legal obligation to make a disclosure under and for the purposes of compliance with guidelines/ regulations issued by regulatory or other authorities which the Company is bound to comply with;

The Company will endeavour to ensure that the person/entity receiving any personal information maintains confidentiality and does not disclose such information onwards to any third party.

We may, however, disclose your private information when required by law to do so pursuant to judicial or other government orders, warrants and/or instructions. We don’t expect this to happen, but if it does, we will provide only the information required. However, we are not responsible for the manner in which such government agencies use such information, including any disclosures/publication

of such information by such Government agencies.

6. Option to withhold / withdraw:

Before collecting your personal information (including sensitive personal data) the Firm will give you an option to withhold the information sought. Further, if you have previously consented to the collection of information and wish to withdraw such consent at a later stage, you may do so by communicating your withdrawal of consent to the Company in writing. However, such withholding of information or withdrawal of consent may result in the Company being unable to provide you with services and/or facilities.

7. Deemed consent:

Unless you have exercised your option to withhold or withdraw consent, you are deemed to have agreed that once the personal information (including sensitive personal data) is collected by the Company, the Company shall have the right to use the same for such lawful purposes for which the same was collected and/or as provided in this privacy policy.

8. Accuracy / authenticity of and access to personal information:

The Company will not be responsible for the accuracy or authenticity of the personal information (including sensitive personal data) collected from you. It is your responsibility to notify the Company of any changes to any personal information (including sensitive personal data) collected by the Company. To this end, you may request the Company for reasonable access to and/or correction of your personal information (including sensitive personal data). If you wish to exercise this right, please write to the Operations Manager at info@lykalearning.com.

9. Publication:

The uploading, dealing, handling and/or using of any personal information for any lawful purpose by the Company, including for the purposes and in the manner outlined above shall not constitute ‘publication’ as contemplated under the provisions of the Rules and no objection shall be raised by you in this regard.

10. Retention of personal information:

We will retain your information in our databases in accordance with applicable laws. The Company may retain the information for such period as may be required for the purposes for which it is lawfully being used or is otherwise required under any other law for the time being in force.

11. Reasonable security practices & procedures:

The Company will strive to be in compliance with International Standard IS/ISO/IEC 27001 on ‘Information Technology – Security Techniques – Information Security

Management System – Requirements’.

12. Changes to the Privacy Policy

We reserve the right to change/amend and/or modify this privacy policy as and when deemed advisable to do so. Hence, this privacy policy will be updated from time to time to reflect these changes/ amendments/modifications. It shall be your responsibility to check for such updates.

13. Severability

If any part of the privacy policy is determined to be invalid or unenforceable in whole or in part, such invalidity or unenforceability shall attach only to such provision or part of such provision and the remaining part of such provision and all other provisions hereof shall continue to be in full force and effect.

14. Grievance officer:

The Company has appointed Mr. Naval Gamadia as a Grievance Officer to address and redress any discrepancies and/or grievances you may have arising out of or in connection with this policy. The Company will endeavour to resolve any grievances within one month from the date of receipt of grievance. The contact details of Mr. Gamadia are as follows:

Email ID: navalgamadia@gmail.com

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