RETHINK+ APPLICATION PRIVACY POLICY

Thank you for choosing Rethink+ Application (“Rethink+ App” or “App”) developed and owned by Rapidue Technologies Private Limited (“Recykal”, “we,” “us,” or “our”). This Privacy Policy applies to Rethink+ App (mobile or web based) owned or/and developed by us. 

The Rethink+ App downloaded on users (“you” or “your”) device provides a gamified learning experience and is intended for users of ages 5 to 13 years of age, except otherwise mentioned.

Please read this Privacy Policy in its entirety, including but not limited to our Children’s Privacy Policy section, before using our App. In the event of any conflict between Children’s Privacy Policy and General Privacy Policy, the Children’s Privacy Policy shall prevail.

By using the App, you provide explicit consent to the practices described in this Privacy Policy. 

OBJECTIVE 

Data Privacy is important to us and we strive to be transparent in our data collection and use practices. This Privacy Policy along with Terms of Use describes our practices regarding your choices in relation to how we collect, store, use, share and secure your Personal Information across when you use our app available on the Google Play Store and Apple App Store or any other App Store or database on which the app is available (collectively referred to as the “Stores”). It also describes your choices regarding use, access and correction of your Personal Information and your rights in relation to your Personal Information and how to contact us or supervisory authorities in the event you have a complaint. We will not use or share your information with anyone except as described in this Privacy Policy. Each time you use our App, you are accepting the practices described in this Privacy Policy at that time. If you do not agree with the terms of this Privacy Policy, please do not use/access this App. We reserve the right to review this Privacy Policy from time to time to make sure it is up to date. If you are just a visitor, then please note that this Privacy Policy is subject to change at any time without notice. To make sure you are aware of any changes, please review this Policy periodically. We are not liable to notify you every time we make changes to this Policy. 

DATA PRIVACY LAWS

Ensuring a child’s privacy is the joint responsibility of their parents/guardians and stakeholders handling their data. As of now, Indian privacy law requirements for children’s data are straightforward, i.e., the law requires data controllers to, inter alia, obtain the consent of the data subject prior to collection; personal data of minors is not separately regulated. However, certain other Indian laws have a knock-on effect on data collection practices. Indian contract laws do not recognize minors, i.e., persons under the age of 18, as competent persons to contract with. Therefore, obtaining a child’s consent has no legal validity, thereby making it necessary to obtain the consent of a parent/guardian to collect a child’s data.

This Privacy Policy has been made pursuant to and in consonance with the current applicable laws, rules, notifications and judicial precedents for the time being in force.

CHILDREN’S PRIVACY POLICY

Protecting the privacy of children is especially important. All references to “children” or “child” in this Children’s Privacy Policy shall mean children in the age group of 5 to 17 years of age, and all references to the term “parent” shall include legal guardians. We encourage parents to supervise their child’s use of the App. No personal information is collected or solicited from a child user of the App. We do not knowingly collect personal information from children without verifiable parental consent. If you believe we have collected personal information from a child without parental consent, please contact us immediately at grievance@recykal.com. We may collect analytics data (which does not contain personal information) from a child’s use of the App in order to offer and update the App, and we may collect information about a child as part of your use of the App and the creation of your child’s user profile. We strive to keep the level of information collected from your child to a minimum, and in no event do we collect more information than what is required to use our learning app. We require all users of the App to use a parent’s phone number in order to create an account. You can login on the App only after entering the One-Time Password (“OTP”) received on your registered mobile number. Entering OTP shall mean that parental consent has been obtained for accessing our App, including the content of the App offered from time to time. In order to enable interactive features, the App may request permission to access your device’s camera. Images captured by your device’s camera are processed only on your device by the App and are never saved. We do not receive the images captured by your device. 

We will obtain prior parental consent if any changes we make to this Privacy Policy affects children.

DEFINITIONS

• “Children” shall mean a person in the age group of 5 to 17 years of age;

1. “Force Majeure” shall mean any event that is beyond our reasonable control and shall include, without limitation, sabotage, fire, flood, explosion, pandemic, epidemic, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption;
2. “Parents” shall mean legal guardians of children who have the authority to grant consent on behalf of children;
3. “Personal Information”  means 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 a body corporate, is capable of identifying such person;
4. “Stores” shall mean and include Google Play Store, Apple App Store or any other App Store or database from where you can download Rethink+ App.

TERMS AND CONDITIONS

1. Collection of Information
   1. When you create an account on our App, we collect your name, phone number, email id or any other additional information you choose to provide.
   2. For children, we collect personal information such as their name, class, section, roll number, school, photo or any other additional information you choose to provide, with verifiable parental consent.
   3. For schools, we collect personal information such as school name, address, school point of contact including his/her name, phone number, email id or any other additional information you choose to provide.
   4. You can choose not to provide any information that is affirmatively requested of you. However, this may limit your ability to use the App.
   5. We collect information about you and your use of our App, your interactions with us as well as information regarding your computer or other device used to access our App. This information includes your activity on our App, including the videos you watch, quizzes you take, and your performance on quizzes; details of your interactions with customer service , such as the date , time and  reason for contacting us, transcripts of any chat conversations, and if you call us , your phone number and call recordings; device  IDs or other unique identifiers, device and software characteristics (such as type and configuration), connection information,  statistics on page views , referring source (for example, referral URLs), IP address (which may tell us your general location),  browser and standard web server log information, mobile network information, information collected via the use of cookies, web beacons and other  technologies. 
   6. If you use a feature that requires payment of a fee, options like UPI or Card will appear. In such cases, we will redirect you to registered payment gateways. You may store and save your payment details like card numbers with the gateway. We do not have access to this data. All payment transactions are processed through secure payment gateway providers. We do not store any card information (other than the last 4 digits of your card) in our servers. 
   7. Our App may include buttons or tools that link to other companies’ services (for example, a Facebook or Google button). We may collect information about your use of these features. In addition, when you see or interact with these buttons, tools, or content, some information from your App may automatically be sent to the other company. Please read that company’s privacy policy for more information, as these sites may have their own privacy statements in place, which we recommend you review if you visit any linked websites. We are not responsible for the content of linked sites or any use of the sites or for the privacy practices of those other websites. 

1. Purpose of Collection of Information
   1. Our primary goal in collecting your Personal Information is to provide you a safe, efficient, smooth, and customized experience. 
   2. To comply with legal requirements and processes (for example, in response to subpoenas, court orders, and law enforcement or governmental requests or investigations), and to protect our legal rights or the rights of others (for example, by working to reduce the risk of fraud or misuse of the App).
   3. Information collected, which relates to Engagement Activities or any other activities, may be utilised by us for the purpose of, including but not limited to, analytics, marketing. This information will, however, be aggregated and anonymized such that individual users will not be identified. 
   4. We do not voluntarily make this information available to third parties, nor do we use it for any other purpose, except as set out herein.

1. Usage of Information
   1. As a general practice, we shall use your Personal Information for the purpose with which you intended to share it with us. However, at times, certain information may be collected from you when you visit the app. Such information is aggregated to measure the number of visits, average time spent on the app, pages viewed etc. This gives us an idea of which parts of our app users are visiting, in order that we may improve the content to offer you better services.
   2. We use the collected information to provide you with access to the features and functionalities of the App, including videos, quizzes, analytics, leaderboards etc.
   3. The information so collected from you allows us to provide courses, study material, tutorials that most likely meet your needs and to customize our App to make your experience better. 
   4. We use your Personally Identifiable Information together with other information to help us better understand our users and to improve the content and functionality of our App. The information we learn from you helps us personalize and continually improve your experience at our App.  
   5. We use your information to analyse, diagnose and fix issues in our product and service offerings.
   6. Based on our research and experience, the data collected pursuant to this App will be used to deliver age-appropriate educational content and optimize the learning experience. The content on our App may be updated from time to time based on the usage. 
   7. We may use your phone number to send you important updates, announcements, and newsletters related to the App. For children, we will be notifying on the App before sending any communication, and the onus shall be on the parents to verify and agree to such communications.
   8. We may anonymize and aggregate the collected data to create statistical information, insights, and reports for research and analytical purposes. This aggregated data does not identify individual users.
   9. Any Analytics, Research, Development or data collated by us shall be the sole property of Rapidue Technologies Private Limited, and we are under no obligation to share our data with you.

1. Storage of Information 

All data or information collected will be uploaded/ created/ collated/ processed/ analysed/ reported in the centralised database which will be under the control of a cloud service provider. Recykal has appropriate technical and organisational security measures against unauthorised or unlawful use or processing of any data and will be providing all the security measures as may be available from a cloud service provider, which may be governed by Terms and Conditions of the Cloud Service Provider. By using the App, you expressly provide your consent to the Terms and Conditions of the Cloud Service Provider. However, no electronic servers are 100% fail-proof. We are not responsible for security incidents not reasonably foreseeable or reasonably within our control.

1. Security of Information
   1. We understand that the security of your information is vital and have in place strong administrative, technical, and physical security controls and measures to keep data safe and secure. Our privacy practices are designed to provide protection for your personal information. 
   2. We implement appropriate security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction.
   3. We use industry-standard encryption protocols to protect sensitive data transmission between the App and our servers.
   4. While we strive to maintain industry-standard privacy and security practices, it should be noted that no industry system is fail proof, and we are not responsible for security incidents not reasonably foreseeable or reasonably within our control.
   5. Notwithstanding anything contained anywhere in this Privacy Policy, we cannot assure absolute security to your Personal Information and by entering or by logging into our App, you explicitly agree not to hold us liable for any breach.
   6. We would like to caution you about phishing attacks, wherein unscrupulous third parties seek to extract sensitive and confidential information from you by posing as a genuine website or by sending an email misrepresenting it to be from a genuine source. Please be aware that we never seek sensitive or confidential information such as regarding your financial or health record through emails or through our websites. If you receive such a message claiming to be from Rapidue Technologies Private Limited, then please do not reply to it and immediately bring it to our attention by contacting grievance@recykal.com. We shall not be held responsible for any loss, damage caused by responding to such emails and sharing information with third parties.
   7. We reserve the right to conduct a security review at any time to verify your identity.  You agree to provide us all the information that we request for the security review.  If You fail to comply with any security request, we reserve the right to terminate your Account with us and prohibit your access to the App.
   8. We are not liable and cannot be held liable for any breach of security or for any actions of any third parties that receive your Personal Information.
   9. Notwithstanding anything contained in this Policy or elsewhere, we shall not be held responsible for any loss, damage or misuse of your Personal Information, if such loss, damage or misuse is attributable to a Force Majeure Event.

1. Retention of Information

We will retain your information for as long as is reasonably necessary in relation to the purposes for which this data was collected. In many instances, we will retain your data while it is necessary for your use of the Service, which may include maintaining this information beyond when you cease using the Service.

1. Sharing of Information
   1. We will display certain personal information like name, phone number, grade, auto-generated avatar about you in your profile page and elsewhere on the App You can review and revise your profile information at any time. We may also share or disclose your personal information with your consent, and also as otherwise described below. 
   2. We will not rent or sell your personal information with independent third parties for marketing purposes.
   3. To operate the App, we may share your personal information with our agents, representatives, and contractors, including but not limited to Cloud Service Providers, Payment Processors, Analytics, so they can provide us with support services and other features. Generally, we limit the information so provided to that which is reasonably necessary for them to perform their functions. Further, they are obligated to protect it and use it solely for the purposes of providing the services to us.
   4. We may disclose your personal information if required to do so by law or subpoena or government or semi-government orders, or if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our rights or property.
   5. As we develop our business, we may buy or sell assets or business offerings. Customers, email, and visitor information is generally one of the transferred business assets in these types of transactions and we may transfer your personal information in these instances. We may also transfer or assign such information in the course of corporate divestitures, mergers, or dissolution. We will use reasonable efforts to notify you of any change of ownership or control in which your personal information is transferred.
   6. We may disclose aggregated, anonymized or otherwise non-personally identifiable information, such as anonymous usage data, platform types, etc., with interested third parties to help them understand your usage patterns.

1. Ownership of Rights
   1. All rights, including copyright, in this App are owned by us. Any use of this App or its contents, including copying or storing it or them in whole or part, other than for your own personal, non-commercial use, is prohibited without our permission. You are prohibited from modifying, copying, distributing, transmitting, displaying, printing, publishing, selling, licensing, creating derivative works or using any content available on or through our App for commercial or public purposes.  You may not modify, distribute or re-post something on this App for any purpose.
   2. The App contains copyrighted material, trademarks, or other proprietary information, including, but not limited to, text, software, photos, video, graphics, music, sound, and the entire contents of Rethink+ App is protected by copyright as a collective work under the applicable copyright laws.
   3. You acknowledge that you do not acquire any ownership rights by downloading copyrighted material. Trademarks that are located within or on our App shall not be deemed to be in the public domain but rather the exclusive property of Rapidue Technologies Private Limited.
   4. Rapidue Technologies Private Limited does not have any express burden or responsibility to provide you with indications, markings, or anything else that may aid you in determining whether the material in question is copyrighted or trademarked. You shall be solely liable for any damage resulting from any infringement of copyrights, trademarks, proprietary rights or any other harm resulting from such a submission.

1. Users Rights over Personal Information
   1. You have the right to withdraw your consent at any time in writing by sending an e-mail to us at grievance@recykal.com, in accordance with the terms of this Privacy Policy. However, please note that withdrawal of consent will not be retrospective in nature and shall be applicable prospectively. 
   2. You may write to us at grievance@recykal.com to review, modify or correct your Personal Information or withdraw your consent to provide Personal Information. We are not responsible for the authenticity of the information provided by you.
   3. You agree and acknowledge that Your right to access, modify and/or withdrawing Your consent to provide Personal Information as mentioned above may be denied or limited by us, as may be required under any applicable law, law enforcement requests or under any judicial proceedings.

1. Modification

We may at any time modify the Privacy Policy of our App without any prior notification to you. Should you wish to terminate your account due to a modification, you may do so email us at grievance@recykal.com.  However, if you continue to use the App, you shall be deemed to have agreed to accept and abide by the modified Privacy Policy of the App.

1. Governing Law and Jurisdiction

In the event of any dispute arising between the parties with respect to this Privacy Policy, the same shall be referred to the Sole Arbitrator and the arbitration shall be in accordance with Arbitration and Conciliation Act of 1996. The language of arbitration proceedings shall be English. The seat and place of arbitration shall be Hyderabad, Telangana and the decision of the Arbitrator shall be final and binding on both parties herein. This contract shall be subject to the exclusive jurisdiction of courts in Hyderabad, Telangana India and shall be governed by the Indian laws.

CONTACT US

Should you have any remaining questions about how we treat your Privacy, you may reach out to us at support@recykal.com.