1. Background

• 1.1 The website, www.bryt.in, together with its, (a) mobile based applications namely, Bryt Teacher, Bryt School, Bryt Student, and Bryt Home available at Google Play Store and/or Apple Play Store, and (b) web based application namely, Bryt Admin (collectively referred to as “Application”) are owned, managed and operated by Bryt360 Inc incorporated under the laws of the State of Delaware, United States (“Bryt360”) BRYT Learning Technologies Private Limited, a subsidiary company of Bryt360 incorporated under the Companies Act, 2013 and having its registered office at A-18, Hill Ridge Villas (IVRCL), Gachibowli, Hyderabad - 500008, State of Telangana acts as an authorized representative of Bryt360 (hereinafter referred to as the “Company” and, shall include its successors and permitted assigns).
• 1.2 The Company is an authorized representative of Bryt360 and is engaged in the business providing support, academic, and other services that are included in the Product(s) the you have purchased ("Services”) through its Application.
• 1.3 The Application and Services may have links to websites, sites and/or apps of other organisations. You shall accordingly be subject to the terms and conditions of such website. The Company does not warrant, promote, encourage and/or endorse Company’s websites, sites and/or apps. The Company shall not be responsible for the privacy practices or the accuracy or integrity of the content included on such websites, sites and / or apps.
• 1.4 The Company is committed to protect your privacy and shall take all reasonable measures that are necessary to protect your personal information and/or data that we collect from you in accordance with the Information Technology Act 2000 (“IT Act, 2000”) and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011 (“SPDI Rules”).
• 1.5 If the Services are being used by any individual/entity located in a foreign jurisdiction, the Company shall make reasonable endeavors to comply with the applicable laws of such foreign jurisdiction, to the extent required.

2. Meaning

• 2.1 The term "Information" shall have a same meaning as provided under IT Act, 2000 and SPDI Rules, and shall mean any personally identifiable information like name, gender, mobile number, phone number, address, email, date of birth, any identity proof issued by the government like Aadhaar, PAN Card, et cetera. The terms ‘Information’, ‘Data’, ‘Personal Information’ and ‘Personal Data’ may be used interchangeably under this Privacy Policy.
• 2.2 The term Information includes ‘Sensitive Personal Data or Information’ as defined under the SPDI Rules which relates to, (a) password, (b) financial information such as Bank account or credit card or debit card or other payment instrument details, (c) physical, physiological and mental health condition, (d) sexual orientation, (e) medical records and history, (f) Biometric information, (g) any detail provided to the Company in furtherance to providing service, and (h) any of the information received by the Company for processing, stored or processed under lawful contract or otherwise including Internet Protocol (“IP”) address, browser type, Internet Service Provider (“ISP”) (the “Information”).
• 2.3 The term “Bryt” or “Company” or “We/we” or “Us/us” shall refer to Bryt Learning Technologies Private Limited.
• 2.4 The term “You/you” or “Your/your” or “Yourself/yourself”’ shall refer to any visitor/user visiting the Website, www.bryt.in, and/or the User / Customer accessing the App.
• 2.5 The term “Person” shall mean and include an individual, group of individuals, partnership firm, company, an estate, a trust and any other entity or organization.

3. Applicability

• 3.1 This Policy is limited in its applicability only to your use of the Website. The term, (a) “User” shall mean and include such person who avails the Services of the Company and consenting to this Policy, and (b) “Visitors” shall mean and include such person who visits this website without availing the Services.
• 3.2 This Policy describes the manner in which the Company collects, uses/processes, stores and discloses your information, and the choices you have with respect to the manner in which the Company ought to be dealing with your Information.

4. General Consent

• 4.1 Please note that by providing the Information (as enumerated upon herein below) or by consenting to the provision of the Information by your respective School (as defined in the Terms of Service), you provide your consent and authorize us to collect, process, use, store or disclose Information for the Legitimate Purposes (as defined below) as stated in this Privacy Policy, the Terms of Service and as permitted or required by Applicable Law.
• 4.2 You understand and hereby consent that this Information may be transferred to any 3 rd party user for the purpose of providing Services through the Application or to any 3 rd party providers for rendering Services, any jointly developed or marketed services, payment processing, order fulfilment, customer services, data analysis, information technology services and such other services which enable us to provide Services through the Application.
• 4.3 This Privacy Policy shall be enforceable against you in the same manner as any other written agreement.
• 4.4 By visiting or accessing the Application and voluntarily providing us with Information, you are consenting to our use of the Information, in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, you may withdraw your consent any time, or alternatively choose to not provide us with any Personal Data and Information. Under such circumstance, your access to the Services we provide may be limited or we may be unable to render Services. Such an intimation to withdraw your consent can be sent to support@bryt.in.
• 4.5 The Company updates this Policy from time to time. Your continued use of the Services post the changes shall be deemed to be your acceptance of those changes made in this Policy.

5. Consent by Minors

• 5.1 If you are a minor (below 18 years) and wish to avail the Services, you are requested to take the consent of parent(s) and/or guardian(s) in the form provided by the Company which may be revised and/or updated from time to time as may be required under applicable laws.
• 5.2 In the event of discovery of incorrect or inadequate information, the Company shall be at the sole discretion to remove the information from its system and abstain from providing Services to the minor with immediate effect and without any notice.
• 5.3 The parent or guardian of a minor child shall be solely responsible for their minor child or children. This responsibility includes, but is not limited to, supervision, direction, safety, engagement with teachers, engagement with administrators, ensuring appropriate age related assignments, general welfare and well being.

6. Kinds of Information collected by us

• 6.1 “Personal Information” means and includes any information that relates to a natural person through which an individual is identified, such as the name, date of birth, educational information and related data, contact details, employment details, email address or any other relevant material provided by a User, including but not limited to, information gathered through availing Services.
• 6.2 “Technical Information” means and includes any information gathered through various technologies that may employ cookies, web beacons, or similar technologies to automatically record certain information from your device through which you use the Application. This technical information may include your Internet Protocol (IP) address, device or browser type, Internet Service Provider (ISP), referring or exit pages, clickstream data, operating system, hardware model, operating system version, unique device identifiers, and mobile network. This data includes usage and log information and user statistics.
• 6.3 “Locational Information” shall mean and include the geo-information obtained through GPS or other means, such as the geographical location of the User and sensor data from the device on which you access the Services.
• 6.4 “Information through use of our Service” means and includes information which is shared with us to avail our Services.
• 6.5 “Non-Personal Information” means and includes any information that does not reveal your specific identity, such as, browser information, information collected through Cookies (as defined below), pixel tags and other technologies, demographic information, crash reports, system activity, device state information etc. As is true with most websites and mobile applications, the Company gathers some information automatically when you visit the Application. When you use the Application, we may collect certain information about your computer or mobile to facilitate, evaluate and verify your use of the Application. For example, we may store environmental variables, such as browser type, operating system, speed of the central processing unit (CPU), referring or exit web pages, click patterns and the internet protocol (IP) address of your computer. This information is generally collected in aggregate form, without identifying any user individually. (The Personal Data, Technical Information, Locational Information, and Non-Personal Information are collectively referred to as “Information).

7. Purpose of Collection and Usage of this Information

• 7.1 The Information collected by us shall be used for availing our Services and utilised for other functions including but not limited to:
• a) to render Services (as defined in the Terms of Service) and provide feedback to the schools;
• b) for maintaining the Application;
• c) to evaluate the quality and competence of our personnel;
• d) to resolve any complaints, you may have and ensure that you receive the highest quality of Services;
• e) notifying you about changes to our Application;
• f) allowing you to participate in interactive features of our Application when you choose to do so;
• g) providing analysis or valuable information so that we can improve the Application;
• h) monitoring the usage of the Application;
• i) detecting, preventing and addressing technical issues;
• j) to conduct crash analytics in the event the Application and/or Service crashes;
• k) analyse usage patterns and user preferences;
• l) improve user experience;
• m) notify you about new products and features.
• 7.2 Business or Research Purposes: The Information saved and except Personal Data, is used for business or research purposes, including improving and customizing the Application for ease of use and the products and services offered by us. We may archive this information to use it for future communications for providing updates and/or surveys.
• 7.3 Aggregating Information / Anonymized data: We may aggregate Information and analyse it in a manner to further accentuate the level of services that we offer to our customers. This Information includes average number of Users of the Application, the average clicks of the services, the features used, the response rate, et cetera and such other statistics regarding groups or individuals. In doing so, we shall not be making disclosures of any Personal Data as defined above (Collectively referred to as “Legitimate Purposes”).

8. Disclosure and Sharing of Information

• 8.1 We do not rent, sell or disclose or share any Information that we collect from you, with third parties, save and except in order to provide you with the Services or for the Legitimate Purposes as specified above. Any such disclosure, if made, shall be in accordance with this Policy and as per the procedure prescribed by law and in compliance with our legal obligations. Additionally, we may share your Information in circumstances and for the purposes as specified hereunder:
• a) We may share the information to the third-party service providers/ vendors, to provide you with the Services and to effectuate any activities that fall under the Legitimate Purpose for which such Information has been collected.
• b) When compelled by law: We may disclose any Information provided by you on the Application as may be deemed to be necessary or appropriate:
• i) under Applicable law, including laws outside your country of residence;
• ii) to comply with legal process;
• iii) to respond to requests from public and government authorities including public and government authorities including public and government authorities outside your country of residence;
• iv) to protect our operations or those of any of our affiliates;
• v) to protect our rights, privacy, safety or property, and/that of our affiliates, you or others;
• vi) to allow us to pursue available remedies or limit the damages that we may sustain;
• vii) to protect against legal liability;
• viii) to protect the personal safety of Users of the Application;
• ix) to prevent or investigate possible wrongdoing in connection with the Application.
• c) Merger or Acquisition: We may share Information upon merger or acquisition of the Company with another company. We shall transmit and transfer the Information upon acquisition or merger of the Company with another company;
• d) With our service providers: We may share Information with other service providers on a needto- know basis, subject to obligations of confidentiality for provision of Services. We hereby clarify that the Company works with institutions, vendors, partners, advertisers, and other service providers, including (but not limited) to those who provide products or services such as contact information verification, website hosting, data analysis, providing infrastructure, information technology services, auditing services and other similar services, in different industries and categories of business by virtue of lawful contracts instituted between such third parties and Company to improve our product and services. Accordingly, we may share your Information with such service provider in order to provide you with Services;
• e) Employees /Agents of Company: We follow a strict confidentiality policy with regard to disclosure of confidential information to our employees or other personnel. There may be situations, where we may disclose the confidential information only to those of our employees and other personnel on a need-to-know basis. Any breach of confidential information by the employees, personnel within the Company is dealt with stringently by us.
• 8.2 Except for the Information disclosed pursuant to sub-clause (a), (b), (c), (d) and (e) of Clause 8.1 above, the Company may share Information, if you authorize us to do so.

9. Transfer of Information

• 9.1 Your information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the laws pertaining to data protection, privacy and information security may differ from those from your jurisdiction.
• 9.2 If you are located outside India and choose to provide information to us, please note that we may transfer the data to India to process the Information which shall be subject to laws governing data protection, privacy and information security in India.
• 9.3 Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
• 9.4 We shall take all steps as required under law to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your data will take place to an organization or a country unless there are adequate controls in place including the security of your data.

10. Public Data

• 10.1 Any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as Information for the purposes of IT Act, 2000 and the SPDI Rules.
• 10.2 The Company shall not be responsible in any manner of whatsoever nature for any unauthorized use, violation or misuse of such Information.

11. Data Retention and Storage

• 11.1 All Information provided by you, save and except upon withdrawal or termination, shall be retained in locations within the control of Company in accordance with applicable laws.
• 11.2 The Company may delete the Information on request received from you within a reasonable period and latest within thirty (30) days of receiving a deletion request. However, we may retain such portion of Information and for such periods as may be required under applicable law.
• 11.3 Notwithstanding anything contained herein, the Company may retain Information after account deletion if,
• a) there is/are any unresolved issue(s) relating to your account, or any unresolved claim or dispute; and
• b) required to by applicable law for the time being in force.
• 11.4 In the event, the Company is unable to process the Information submitted by you for whatsoever reason(s), the same shall be deleted unless it is otherwise required by us to do so under law and/or as may be required for any internal or external audit purposes.
• 11.5 The Company is committed to comply with applicable laws to ensure that all measures, so prescribed by law, are taken for storing the Information in order to ensure that such Information is safe and secure.

12. Purging your Information

• 12.1 The Company has necessary policies, mechanism and tools in place to ensure all the Information that are collected and stored are deleted as soon as the purpose as described in this Privacy Policy is completed, unless it is mandated by law to be maintained by the Company.
• 12.2 The Information, so provided by you, shall be destroyed and disposed off in a manner that protects the privacy of your Information in an appropriate manner as per the industry standard practices and/or in the manner as prescribed by law.

13. Your Right

• 13.1 The Company shall be happy to make corrections to your Information upon your written request. For this purpose, you are requested to write to us at support@bryt.in.
• 13.2 You retain several rights in relation to your Personal Data as provided under applicable law. These may include the rights to:
• a) access, confirm, and review Personal Data you may have provided;
• b) correct Personal Data that may be inaccurate or irrelevant;
• c) delete and erase your Personal Data from the publicly available pages of the Application;
• d) receive Personal Data we hold about you in a portable format;
• e) object to or restrict any form of processing you may not be comfortable with.
• 13.3 Control the collection or use of the Information: If you have any reservations and/or apprehensions regarding the access to, collection, storage, or any other use of the Information which you have provided to us, you may ‘opt out’ or ‘withdraw’ your consent expressly by writing to support@bryt.in.

14. Cookies and other Tracking Technologies

• 14.1 Our Application may utilize “cookies” and other Technical Information. “Cookies” are a small text file consisting of alphanumeric numbers used to collect the Information about Application activity. The Technical Information helps us analyse web traffic and helps you by customizing the Application to your preferences. Cookies in no way gives us access to your computer or mobile device. In relation to Cookies, you can deny access to the installation of the Cookies by modifying the settings on your web browser, however, this may prevent you from taking full advantage of the Application.
• 14.2 Our use of Cookies and Technical Information allows us to improve Application and your experience of Application and Services. We may also analyse Technical Information that does not contain Personal Data or Sensitive Personal Information for trends and statistics.

15. Information Security

• 15.1 The Company has ensured the safe and secure use of your Information as per the reasonable security standards as prescribed under applicable laws including but not limited to IT Act, 2000 and SPDI Rules, 2011.
• 15.2 We use reasonable security practices and procedures and use secure servers as mandated under applicable laws for the protection of your Information. We take all the security measures to safeguard against unauthorized access to our systems.
• 15.3 In the event of any query, clarification or support with respect to security of the Information provided by you, you are requested to write to privsec@bryt.in.

16. Limitation of Liability

• 16.1 Irrespective of anything contained herein or otherwise, the Company shall in no manner be liable for breach of any Information that is,
• a) already available in public domain;
• b) collected from other sources;
• c) collected by way of any illegal and unlawful means; or
• d) provided by any person who is incompetent under Section 11 of Indian Contract Act, 1872.

17. Changes and updates to Policy

• 17.1 We may modify or revise the Privacy Policy from time to time and shall accordingly notify you of any changes to the Privacy Policy by posting the revised Privacy Policy on the Application with an updated date of revision.
• 17.2 We shall endeavour to review, revise, update, modify, amend or correct the Privacy Policy on a regular and routine basis, especially whenever a significant update is made to the technology employed by us.
• 17.3 You must periodically review the Privacy Policy for the latest information on our privacy practices. In the event you continue to use the Application and our Services after any update in the Privacy Policy, your use of the Application shall be subject to such updated privacy policy. Your continued usage of Services, post any amendment would deem to mean that you accept and understand the revised Privacy Policy.
• 17.4 Further, we retain the right at any time to deny or suspend access to all, or any part of, the Service and/or access to the Application to anyone who we reasonably believe has violated any provision of this Privacy Policy.

18. Contact Information

• 18.1 If you have any questions or queries regarding this Privacy Policy, you may contact us through email at privsec@bryt.in or by simply writing to the mailing address given below: Bryt Learning Technologies Private Limited A-18, Hillridge Villas Gachibowli, Hyderabad 500008

19. Discrepancies and Grievances with Company

• 19.1 In case of any discrepancy or grievance with respect to all or any Information shared with Company, please feel free to contact our Grievance Officer: Attention: Mr. Deepak Ananth Email ID: grievance@bryt.in Address: A-18, Hillridge Villas Gachibowli, Hyderabad 500008
• 19.2 We assure you that we shall ensure implementation of the Privacy Policy and shall make the Privacy Policy available to individuals and put our best efforts to redress the grievances of the User expeditiously within 30 (Thirty) days from the date of receipt of the grievance.

20. Governing Laws and Jurisdiction

• 20.1 This Privacy Policy, our Services and the use of it is governed by the laws of India and the courts in Hyderabad, India shall have exclusive jurisdiction over any disputes connected to our Application or the Services.

21. Miscellaneous

• 21.1 The invalidity or unenforceability of any part of this Privacy Policy shall not prejudice or affect the validity or enforceability of the remainder of this Privacy Policy.
• 21.2 This Privacy Policy does not apply to any information other than the information collected by us through the Application.
• 21.3 This Privacy Policy shall be inapplicable to any unsolicited information you provide us through the Application or through any other means. All unsolicited information shall be deemed to be nonconfidential and we shall be free to use and/ or disclose such unsolicited information without any limitations.
• 21.4 The rights and remedies available under this Privacy Policy may be exercised as often as necessary and are cumulative and not exclusive of rights or remedies provided by law. Rights under this Privacy Policy may be waived only in writing. Delay in exercising or non-exercise of any such right or remedy does not constitute a waiver of that right or remedy, or any other right or remedy.
• 21.5 This Privacy Policy is to be read with the Terms of Use of the company available at https://www.bryt.in/bryt-terms-of-use.