PRIVACY POLICY- MYCLASSMATE EDUTAINMENT APPLICATION

ITC Limited respects an individual’s right to privacy. This policy lays down our practices with respect to confidentiality and disclosure of personal information. Please familiarize yourself with our privacy practices, as given below. Should you choose to share your personal information with ITC Limited, it will be assumed that you have no objection to the terms of this privacy policy.

This Privacy Policy covers the information ITC Ltd  (“Platform” and/or “We”) collects from the user(s) (“User(s)” and/or “You”) of MyClassmate Edutainment Application (“Application”) and any associated mobile sites, applications (“apps”) and/or the Services provided by the Platform on the application (as defined in the Terms of Use of the application – “Terms of Use”), which Services can be used or accessed on the application (as defined in the Terms of Use).

The Application is a one stop Edutainment destination for children with modules ranging from subject concepts to knowledge enhancement via Quizzes and interesting trivia to fun modules like Augmented Reality depiction of a Notebook cover, DIY videos, etc. The App also facilitates a child’s learning and schedule management via Converter and Scheduler Management modules. The Subject Fundas module of the App provides users subject concepts, formulas, laws, important tables and calculation techniques. Users can bookmark important formulas and concepts. Users can scan Classmate notebook covers and watch the cover image come to life via augmented reality. Users can also click a Selfie with the augmented reality depiction of notebook, share the same and also learn interesting trivia about the notebook cover. Myriad quizzes such as Spell Bee and Grammar allows one to test their knowledge and challenge themselves. Performance snapshot of the quiz is also available. Explore interesting DIY videos to learn about interesting art and craft techniques and hobby ideas. Knowledge snippets and trivia enhances general knowledge and stimulates one’s interest to learn more. Schedule your daily calendar such as birthdays, exam schedule, study schedule, holiday schedule, events and class timetable. User can efficiently manage their daily time table. Explore interesting vocations including conventional ones such as doctors, scientist, etc. as well as unconventional ones such as professional chef, architect, physical trainer, etc. Young children can learn about previously unheard of or unexplored professions and thereby build interest beyond conventional work domains.

ITC Limited has also adopted reasonable security practices and procedures comprising of managerial, technical, operational and physical security control measures with a view to ensure confidentiality and prevent unauthorized disclosure of personal information. ITC Limited uses the personal information only for the purpose for which the same has been furnished. ITC Limited does not retain information after the purpose for which it is furnished is accomplished unless the same is required to be retained under any law in force or for audit purposes. In such cases also, confidentiality of such information is maintained.

This Privacy Policy should be read in conjunction and together with the Terms of Use available on the Application. Personal Information of a User(s) is collected if the User(s) registers with the application, accesses the application or takes any action on the application or uses or accesses the Services as defined in the Terms of Use. The terms ‘Personal Information’, ‘Sensitive Personal Data’ and ‘Information’ shall have the meaning ascribed to it under the Information Technology Act, 2000. Your use of our services offered on the application is constructed to mean that You consent to our collection, storage, processing and transfer of your Personal Information or Sensitive Personal Data or Information in accordance with this Privacy Policy and you consent to the terms and conditions of this Privacy Policy. ITC Limited shall not be responsible in any manner whatsoever for any violation or misuse of your personal information by unauthorised persons consequent to misuse of the internet environment.

Here are our privacy principles:

1. Collection Of Information And Use

The Personal Information or Sensitive Personal Data or Information which You may provide to the Platform and/or which We may collect as part of the information provided is or could be the following:

Your Registration Details Which May Include Device ID, Device Type, Device Operating System, Device Manufacturer, User Name, Profile, image Email Address, Mobile/Contact Details, Age, Gender, Password, Location, School Name, Class Name/Standard, City Name, School Board, Subject Name provided By You. Your feedback received through the App is captured to further improve the App for a better user experience. Your Images taken via UnCover module, Class TimeTable, Tuition Time Table, Coaching Time Table, etc., Scheduler namely, Exam schedule, study schedule, holiday schedule, Birthday, Anniversary, Submission and Other Events, Notification tone preference, Performance details in QuiZone module namely, percentage score, percentile score, top 3 score, etc., Profile details namely, Class Number/Standard, Profile Name, Profile Image, Mobile Number, Date of Birth, School Name, School Board and City Name to enhance user experience.

Your Comments Or Other Content That You Publicly Post Or Share On The Application. Your Usage Behavior Of The Application  Or Interests, , Other Traceable Activities Online, On Apps And On Mobile Such As Destinations Visited, Viewed Advertisments or Content Consumed. Details Of The mobile operating System Or mobile operating Network Which You Use To Visit The  Application And Undertake Any Activity On The Application , Such As A Unique Device Identifier  Session Identifiers From Device ID, Commercially Available Services, Data Aggregator Platforms. User Preferences (E.G., Preferred Language Settings); Operating System, , And Other Types Of Mobile And Connection Related Information Relevant To Identifying Your Type Of Device, Connecting To The Application, Enabling Data Exchange With You And Your Device, And Ensuring A Convenient Use Of The Application; The Uniform Resource Locator (URL) And IP Address Of The Website From Which You Accessed, Or Were Directed To, Our Application, Including Date And Time; Subpages Visited While On Our Application, Links Followed On The Application, Including Date And Time; The Full URL Click Stream To, Through And From The Application, Including Date And Time; Service Requests; Search Terms Entered; Services Viewed Or Searched For On The application;;Information Collected By Cookies Or Similar Technologies (As Described In The Next Paragraph);Newsletter Subscriptions, Enrollment For Promotions, Use Of Special Offers, Etc. Consents, Authorizations, Etc. Granted; Survey Answers, Reviews, Ratings And Other Types Of Feedback Provided; Content Of Any Communication Sent Through The Application, Including Any Information Posted In Social Communities On The Application Or Otherwise Shared With Platform And/Or Other Users; Information On Software Downloaded From The Application; And Any Other Information That You Enter On, Or Upload To, The Application (E.G., Content That You Fill Into An Online Form, A Photo That You Upload).

Our primary purposes in collecting information including Personal Information or Sensitive Personal Data or Information from You is to allow You to use the Application and various features and Services on or in relation to the Application or any Sites contact you for any Services provided by the Platform or its affiliates or its various service providers or Platform business partners and advertisers; to record Your information and details as permitted and required under applicable laws, statutory direction or judicial orders; to serve various promotion materials and advertising materials to You; and such other uses as provided in the Terms of Use and this Privacy Policy. We may also use the Personal Information or Sensitive Personal Data or Information provided by You or collected by the Platform for content recommendations, transactional emails or to provide You with information, direct marketing, online and offline advertising and other materials regarding products, services and other offers from time to time in connection with the Platform or its parent, subsidiary and affiliated companies (“Platform Entities”) and its joint ventures.

We may also collect information or Personal Information to track User behavior and preferences for internal analytics of all Users of the Application. We may also use your information: (i) to evaluate your eligibility for certain types of offers, products or services; (ii) to perform analytics and conduct customer research, including general market research or surveying our customers' needs and opinions on specific issues, generating sales and traffic patterns, and to analyze advertising effectiveness, both on an anonymous basis (e.g., by aggregating data) or on an individual basis (if legally permissible);

This Personal Information or Sensitive Personal Data or Information is collected through the use of server log files and tracking technologies to analyze certain types of technical information. We may also collect and process information about your location using GPS technology in the mobile. You can stop all collection of information by the Application easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

We may combine Your Personal Information or Sensitive Personal Data or Information, other information and information collected from tracking technologies and aggregate it with information collected from other Users using our Application to attempt to provide You with the Services and a better experience on the Website.

You understand, agree and acknowledge that our collection, storage and processing of your Personal Information or Sensitive Personal Data or Information is for a lawful purpose connected with a function or activity of the Platform Entities and its joint ventures. You hereby consent to the collection, storage, use, disclosure, transfer, of the Personal Information or Sensitive Personal Data or Information by Platform for the purposes set out herein. You further understand, agree and acknowledge that Your Personal Information which is classified as Sensitive Personal Data or Information as per applicable laws is considered necessary for the Platform to provide various services on its Application to You and for Your usage of the Application and other services provided by Platform in relation to the Application and you affirmatively consent to its collection, storage, transfer and processing.

2. Information Sharing And Disclosure

Platform is the recipient of Your Personal Information or Sensitive Personal Data or Information and shall exercise reasonable commercial endeavours for the prevention of unauthorized disclosure of the Personal Information including any Sensitive Personal Data or Information provided by the Users. We may enable access of Your Personal Information or Sensitive Personal Data or Information to the Platform Entities, joint ventures, business partners, agents or third parties for the purposes of the services provided by them or for any other marketing related activity undertaken by or on behalf of the Platform Entities and/or its joint ventures, and/or for the purposes of enhancing the quality of the services provided to You on the Application, and You expressly consent to the same.

We shall endeavour that the third parties and agents engaged by us to whom we may provide access to Your Personal Information or Sensitive Personal Data or Information for the purposes set out herein are under a contractual obligation to protect Your Personal Information or Sensitive Personal Data or Information in accordance with the same standard as the Platform has agreed to be subject to in this Privacy Policy.

3. Compliance With Laws And Law Enforcement

Platform cooperates with mandated government and law enforcement agencies or to any third parties by an order under law for the time being in force to enforce and comply with the law. We will also disclose any information including Sensitive Personal Data or Information about You to government and law enforcement agencies without your permission as we, in our sole discretion, believe necessary or appropriate to respond to valid claims and legal process, to protect the property and rights of Platform or a third party, to protect the safety of the public or any person, or to prevent or stop any illegal, unethical or legally actionable activity. Platform may also provide Your Personal Information including Sensitive Personal Data or Information to various governmental authorities including tax authorities upon any demand or request from them.

4. Email Policies

Platform may use Your Personal Information or Sensitive Personal Data or Information for the purposes mentioned in this Privacy Policy. You have full control regarding which emails You want to receive. If You decide at any time that You no longer wish to receive such communications from the Platform Entities , please follow the unsubscribe instructions provided in any of the communications. Please note that once we receive Your request, it may take an additional period of time for Your opt-out to become effective.

5. Data Security

We understand the importance of data security and we want your user experience with us to be as safe as possible. We have implemented reasonable safeguards and precautions to protect Your Personal Information or Sensitive Personal Data or Information, including technical and organizational measures against unauthorized access, improper use, alteration, unlawful or accidental destruction, and accidental loss, both in an online and offline context.

We have adopted reasonable security practices and procedure and We maintain technical and organizational security measures and procedures to protect the security of your Your Personal Information or Sensitive Personal Data or Information, which are consistent with measures used by other similar Applications.

Please understand that, while we strive to protect Your Personal Information or Sensitive Personal Data or Information against potential risks and exposures, there is no absolute security in the online sphere. Hence, we ask you to support our IT security efforts by not disclosing any of Your Personal Information or Sensitive Personal Data or Information data on our Application that is particularly sensitive or not required in the specific context. Furthermore, you can help us protecting your personal data by signing off when you finish using login-protected areas of the Application.

6. Data Retention

We retain Personal Information or Sensitive Personal Data or Information only for as long as We believe it to be necessary for purposes set out herein for which the Personal Information or Sensitive Personal Data or Information was collected, subject to any legal requirements for the data to be retained for longer periods of time.

7. Deleting Your Information

If You wish to have the Personal Information or Sensitive Personal Data or Information that You have provided to us deleted, You can always do so by sending a request to us on the e-mail id of our Customer Services department provided at the bottom of this page. You may note that deletion of certain Personal Information may lead to cancellation of your registration with the Application and/or your access to certain features of the Application can be restricted and may also lead to complete cessation of Your Access to the Application.

8. Links To Other Sites / Financial Data

We provide links to other websites and portals for your convenience and information (“Other Websites”). Please note that while you transact with other websites, the Platform does not directly collect any details from You. Such Other Websites are not controlled by us. When you visit such Other Website you do so at your own risk. These Other Websites may have their own privacy policies in place, which we recommend You review if You visit any such Other Websites. We do not assume any responsibility or liability for such Other Websites, the content of such Other Websites and their privacy practices, nor do we endorse them. We encourage you to familiarize yourself with the privacy statements provided by such Other Websites prior to providing them with information about you or entering into any transactions on them.

For example, You may choose to use third-party data backup services such as iCloud or Google Drive that are integrated with the Application or interact with a share button on a third party’s website. Please note that when you use third-party services, their own terms and privacy policies will govern your use of those services. Backup feature includes backup of Images taken via UnCover module, Class TimeTable, Tuition Time Table, Coaching Time Table, etc., Scheduler namely, Exam schedule, study schedule, holiday schedule, Birthday, Anniversary, Submission and Other Events, Notification tone preference, Performance details in QuiZone module namely, percentage score, percentile score, top 3 score, etc., Profile details namely,  Class Number/Standard, Profile Name, Profile Image, Mobile Number, Date of Birth, School Name, School Board and City Name.

While transacting with these Other Websites , You may provide Your financial information including without limitation Your bank account details, credit card account details or your details pertaining to any payment settlement or pre-paid instrument service provider. You understand, agree and acknowledge that the Application and Platform never receives any such information from these Other Websites. Your Personal Information, Sensitive Personal Data or Information and financial information will be dealt with by these Other Websites in accordance with their respective privacy policies and other terms and conditions and the Platform shall not be liable, accountable or responsible for Your Personal Information, Sensitive Personal Data or Information and financial information which You provide to these Other Websites.

9. Security

We are concerned about safeguarding the confidentiality of your information. Platform uses commercially reasonable security practices and procedures designed to help keep your Personal Information or Sensitive Personal Data or Information safe. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Application.

Your information may be transferred to or may be maintained on computers, computer systems and computer resources located outside of Your state or country where the privacy laws may be different as those where you live. If You are located outside India and choose to provide information to us, please be aware that the Application is hosted in India and that Platform keeps or transfers information to and from India for storage and processing. Your submission of such information represents your agreement to that transfer.

Unfortunately, the transmission of information over the Internet is not completely secure. Although We strive to protect your personal data, We cannot guarantee the security of your data while it is being transmitted to our Application; any transmission is at your own risk. Once We have received your information, We have commercially reasonable procedures and security practices in place to reasonably endeavour to prevent unauthorized access.

10. Changes In Privacy Policy

ITC Limited reserves its right to revise this privacy policy from time to time at its sole discretion. Such policy will be available on the Application.

Your continued use of our Application and the Services constitutes Your acceptance of the then-current Privacy Policy and Terms of Use so We encourage You to visit this page periodically to review any changes.

11. Contact Us

If You have any questions about this Privacy Policy, the practices of Platform or Your dealings with the Application, You can contact us at or via the links at the bottom of the page. Email id: classmate@itc.in

12. Grievance Officer

In accordance with the Information Technology Act, 2000 and the Rules framed thereunder, the name and contact details of the Grievance Officer are provided below:-

Quality Manager

ITC Ltd. – ESPB, ITC Centre, 5th Floor, 760, Anna Salai, Chennai – 600002

Email id: classmate@itc.in

Phone no.: 18004253242

9 AM to 5 PM (on all working days)

If You have any questions or grievance or want to delete or modify Your Personal Information, You shall mark Your correspondence (given under the heading “About Us”). Any communication which is not marked as such shall not be treated as a valid and binding communication for the purpose of this Privacy Policy and applicable laws with respect to this Privacy Policy.