PRIVACY POLICY

Thank you for choosing to be part of our community at Penpencil Edu Service Private Limited (" Company ", "we", "us", "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at edutoos.support@pw.live.

When you use our mobile application, as the case may be (the "App") and more generally, use any of our services (the "Services", which include the website and App), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

This privacy notice applies to all information collected through our Services (which, as described above, includes our App), as well as any related services, sales, marketing or events.

Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.

WHAT INFORMATION DO WE COLLECT?
HOW DO WE USE YOUR INFORMATION?
WILL YOUR INFORMATION BE SHARED WITH ANYONE?
HOW DO WE HANDLE YOUR SOCIAL LOGINS?
HOW LONG DO WE KEEP YOUR INFORMATION?
HOW DO WE KEEP YOUR INFORMATION SAFE?
WHAT ARE YOUR PRIVACY RIGHTS?
CONTROLS FOR DO-NOT-TRACK FEATURES
HOW DO WE HANDLE CHILDRENâS PERSONAL DATA?
DO WE MAKE UPDATES TO THIS NOTICE?
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal data from you in accordance with the Digital Personal Data Protection Act, 2023 (âDPDP Actâ) and applicable Rules, only upon your informed and voluntary consent, and solely for lawful purposes related to providing and improving our App and Services. Your personal data will only be collected and processed upon your explicit consent, which is free, specific, informed, unconditional and unambiguous. So hereby you give you consent to use your information.

The personal information that we collect depends on the context of your interactions with us and the App, the choices you make and the products and features you use. The personal information we collect may include the following:

Personal Information Provided by You- We collect names; phone numbers; email addresses; billing addresses; passwords; usernames; and other similar information.

Social Media Login Data- We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the Information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS" below.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information such as your Internet Protocol (IP) address and/or browser and device characteristics is collected automatically when you visit our App.

When you use or navigate the App, we automatically collect certain non-personal and technical data to maintain security, ensure functionality, and enhance user experience. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our App and other technical information. This information is primarily needed to maintain the security and operation of our App, and for our internal analytics and reporting purposes.

The information we collect includes:

Log and Usage Data- Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our App and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the App (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).
Device Data- We collect device data such as information about your computer, phone, tablet or other device you use to access the App. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.

Information collected through our App

In Short: We collect information regarding your mobile device, push notifications, when you use our App. If you use our App, we also collect the following information:

Mobile Device Access- We may request access or permission to certain features from your mobile device, including your mobile device's camera, contacts, text messages, social media accounts, storage, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
Mobile Device Data- We automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our App, we may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID and information about the features of our App you accessed.
Push Notifications- We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our App, for troubleshooting and for our internal analytics and reporting purposes.

HOW DO WE USE YOUR INFORMATION?

In Short: We use your personal data only for purposes for which you have given specific consent under Section 6 of the DPDP Act, 2023, or as necessary to perform a contract, or to comply with legal obligations, in accordance with the DPDP Act, 2023.

We do not process your personal data for any purpose beyond what you have agreed to, and we ensure that the data collected is limited to what is necessary for each purpose.

We use personal information collected via our App for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

To facilitate account creation and logon process- If you choose to link your account with us to a third- party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract. See the section below headed "HOW DO WE HANDLE YOUR SOCIAL LOGINS" for further information.
To post testimonials- We post testimonials on our App that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at edutoos.support@pw.live. com and be sure to include your name, testimonial location, and contact information.
Request feedback- We may use your information to request feedback and to contact you about your use of our App.
To enable user-to-user communications- We may use your information in order to enable user-to-user communications with each user's consent.
To manage user accounts- We may use your information for the purposes of managing our account and keeping it in working order.
Fulfil and manage your orders- We may use your information to fulfil and manage your orders, payments, returns, and exchanges made through the App.
Administer prize draws and competitions- We may use your information to administer prize draws and competitions when you elect to participate in our competitions.
To deliver and facilitate delivery of services to the user- We may use your information to provide you with the requested service.
To respond to user inquiries/offer support to users- We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

We do not process your personal data for profiling, behavioral tracking, or targeted advertising without your explicit and separate consent.

You may withdraw your consent for any purpose at any time by contacting us. Upon withdrawal, we will cease processing your data for that purpose, unless we are required to retain it by law.

WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We do not share your personal data with any third party, except as permitted herein or under the DPDP Act, 2023 and the rules notified thereunder.

We may process or share your data that we hold based on the following legal basis:

Consent: We may process your data if you have given us prior, specific and informed consent to use your personal information for a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfil the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

Business Transfers- We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company, subject to appropriate data protection safeguards and only with prior notice
Affiliates- We may share data with our corporate affiliates, but only for purposes for which you have given specific consent. All such affiliates are required to comply with this privacy policy and ensure equivalent levels of data protection.. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
Business Partners- We may share your information with our business partners to offer you certain products, services or promotions.
Legal Compliance- We may disclose your data where required by applicable law or lawful authority, such as in response to a court order or official request under Indian law.
Offer Wall- Our App may display a third-party hosted "offer wall." Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our App and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our App. A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward. Please note that we do not control third-party websites and have no responsibility in relation to the content of such websites. The inclusion of a link towards a third-party website does not imply an endorsement by us of such website. Accordingly, we do not make any warranty regarding such third-party websites, and we will not be liable for any loss or damage caused by the use of such websites. In addition, when you access any third-party website, please understand that your rights while accessing and using those websites will be governed by the privacy notice and terms of service relating to the use of those websites.

Please note: You may withdraw your consent to any of the above data sharing activities at any time by contacting us. Upon withdrawal, we will cease sharing your data for that purpose unless otherwise required by law.

HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you. The exact data shared will depend on the privacy settings you have configured on the third-party platform.

Our App offers you the ability to register and login using your third-party social media account details (like your Facebook or Twitter logins). When you choose to register or authenticate in this manner, we may receive limited personal data from the relevant third-party platform, strictly based on your prior consent. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public on such social media platform.

We use this information only for the purposes of account authentication, profile creation, and providing personalized services on our App, as explicitly informed to you at the time of login. We do not use or share this data for any other purpose without obtaining your separate, express consent.

You can revoke your consent and unlink your social login account at any time by accessing your App settings or contacting our Grievance Redressal Officer. Upon revocation, we will no longer process data from the linked social account.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant App. Please note that your social media account provider remains independently responsible for how they collect, use, and share your personal data. We recommend reviewing their privacy policy and terms of service to understand how your data is handled on their platform.

HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, as stated in this Privacy Policy, or as required under applicable laws, including tax, accounting, or regulatory requirements.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law. No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our App is at your own risk. You should only access the App within a secure environment.

WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time.

If you have questions or comments about your privacy rights, you may email us at edutoos.support@pw.live.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

HOW DO WE HANDLE CHILDRENâS PERSONAL DATA?

Persons who are âcompetent/capableâ of contracting within the meaning of the Indian Contract Act, 1872 shall be eligible to register for the Application and all our products or services. Persons who are minors, un-discharged insolvents etc. are not eligible to register for our products or services. As a minor if you wish to use our products or services, such use shall be made available to you by your legal guardian or parents, who has agreed to these terms of Privacy Policy. In the event a minor utilizes the Application/Website/Services, it is assumed that he/she has obtained the consent of the legal guardian or parents, and such use is made available by the legal guardian or parents. The Company will not be responsible for any consequence that arises as a result of misuse of any kind of our Application or any of our products or services that may occur by virtue of any person including a minor registering for the Services/products provided. By using the products or services you warrant that all the data provided by you is accurate and complete and that student using the Application has obtained the consent of parent/legal guardian (in case of minors). The Company reserves the right to terminate your subscription and / or refuse to provide you with access to the products or Services if it is discovered that you are under the age of 18 (eighteen) years and the consent to use the products or Services is not made by Your parent/legal guardian or any information provided by you is inaccurate. You acknowledge that the Company does not have the responsibility to ensure that you conform to the aforesaid eligibility criteria. It shall be your sole responsibility to ensure that you meet the required qualification. Any persons under the age of 18 (eighteen) should seek the consent of their parents/legal guardians before providing any Information about themselves or their parents and other family members on the Application.

DO WE MAKE UPDATES TO THIS PRIVACY POLICY?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?

If you have questions or comments about this notice, you may email us at edutoos.support@pw.live or by post to:

Penpencil Edu Services Private Limited
Plot No. B-8, Tower A, 101-119, Noida One, Sector-62,
Noida, Gautam Buddha Nagar-201309,
Dadri, Uttar Pradesh, India

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please visit: edutoos.support@pw.live. We will respond to your request within 30 days.