Privacy Policy

1. Overview

Tangible Learning ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our tutoring services, access our exam portal, and interact with our related platforms and services (collectively, "Services"). Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access our Services.

2. Information We Collect

2.1 Information You Provide Directly

We collect personal information that you voluntarily provide to us when you:

• Register for tutoring services or create an account
• Contact us through our website, email, or WhatsApp
• Schedule consultations or tutoring sessions
• Enroll in courses or educational programs
• Submit homework, assignments, or queries
• Subscribe to our newsletter or educational content
• Participate in surveys or feedback forms

This information may include:

• Full name
• Contact information (email address, phone number, country)
• Parent or guardian details (for minor students)
• Academic background and course preferences
• Payment-related information (processed securely via third-party gateways such as Razorpay and Wise)
• Homework submissions, messages, and educational queries
• Class registration and scheduling information
• Communication preferences

2.2 Exam Portal Data

When using our exam portal, we collect:

• Test attempts, answer submissions, and scores
• Time taken per question and overall test duration
• Timestamps of when tests are started and completed
• Progress analytics and learning patterns
• Activity logs and session history
• IP address and login history
• Device and browser information
• Performance data and personalized learning analytics

2.3 Automatically Collected Data

When you visit our website or use our Services, we may automatically collect certain information through cookies and analytics tools (including Google Tag Manager and Google Analytics):

• IP address and general geographic location
• Browser type, device type, and operating system
• Pages visited, referral source, and session duration
• Interaction behavior and navigation patterns
• Click-through rates and feature usage
• Time and date of visits

2.4 Class Recordings and Communications

We may collect and store:

• Live class recordings (for educational and quality control purposes)
• Video and audio content from tutoring sessions
• Chat messages and discussion forum content
• Email communications and support inquiries
• WhatsApp messages and communications through our business account

3. How We Use Your Information

We use the information we collect for the following purposes:

• Provide and manage tutoring services: Deliver personalized education, schedule sessions, and maintain your account
• Deliver exam portal features: Track test attempts, generate performance reports, and provide personalized recommendations
• Personalize learning: Create customized study plans and recommend appropriate materials
• Send educational materials: Provide class recordings, study resources, and course materials
• Process payments: Complete transactions and maintain billing records
• Respond to inquiries: Answer questions and provide customer support
• Maintain platform security: Detect and prevent fraud, unauthorized access, and misuse
• Improve our Services: Enhance course quality, platform functionality, and user experience
• Send service updates: Communicate about changes to our Services, policies, or schedules
• Send educational content: Share newsletters, tips, and learning resources
• Send marketing communications: Promote new courses and special offers (only with your consent)
• Analyze usage patterns: Understand how users interact with our Services to make improvements
• Comply with legal obligations: Meet regulatory, tax, and legal requirements

4. Information Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We only share information in the following circumstances:

4.1 Trusted Third-Party Service Providers

We share information with service providers who help us operate our business:

• Hosting services: Web hosting providers for our website and platforms
• Analytics tools: Google Analytics and Google Tag Manager for usage analysis
• Exam portal technology: Providers who help maintain and operate our testing platform
• Payment processors: Razorpay and Wise for secure payment processing
• Video conferencing platforms: Zoom, Google Meet, and similar services for online classes
• Email service providers: Platforms that help us send educational and transactional emails
• Communication platforms: WhatsApp Business API for student communications

All third-party partners are contractually required to maintain confidentiality and protect user data in accordance with applicable laws.

4.2 Educational Staff

We share necessary information with teachers and instructional staff directly involved in delivering your academic program.

4.3 Parents and Guardians

For minor students, we may share information with parents or legal guardians who have authority over the student's account.

4.4 Legal Requirements

We may disclose your information when required by:

• Law, legal process, or court order
• Government or regulatory authorities
• Law enforcement agencies investigating illegal activities
• The need to protect our rights, property, or safety, or that of our users

4.5 Professional Advisors

We may share information with lawyers, accountants, and other professional advisors under confidentiality agreements.

4.6 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred to the acquiring entity, with adequate data protections in place.

5. Data Security

We implement appropriate technical and organizational security measures to protect your personal information:

• Encrypted data transmission: HTTPS/TLS encryption for all data transmitted to and from our servers
• Secure authentication: Password protection and access controls for user accounts
• Encrypted storage: Sensitive exam data and personal information stored with encryption
• Regular security audits: Ongoing vulnerability assessments and security reviews
• Firewall protection: Network security measures and intrusion detection systems
• Staff training: Regular education on data handling and security best practices
• Limited access: Personal data accessible only on a need-to-know basis
• Secure backups: Regular data backups with appropriate security measures

Disclaimer: While we implement industry-standard security measures, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security of information transmitted to or stored by our Services.

6. Data Retention

We retain your personal information only as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements.

Specific retention periods include:

• Exam portal data: Test attempts and score history retained for the duration of enrollment plus 2 years
• Class recordings: Available to enrolled students during enrollment period, retained for up to 3 years
• Attendance logs: Retained for 3 years from last session
• Payment records: Retained for 7 years for tax and accounting purposes
• Communication logs: Support tickets and inquiries retained for 2 years
• Marketing data: Retained until you opt-out or withdraw consent

After retention periods expire, data will be securely deleted or anonymized for statistical purposes only.

7. Your Rights and Choices

You have the following rights regarding your personal information:

• Access: Request a copy of your personal data we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your data (subject to legal retention requirements)
• Data Portability: Request your exam history and academic records in a portable format
• Opt-out: Unsubscribe from marketing communications at any time
• Restrict Processing: Request limitation of how we process your data
• Object: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw previously given consent for data processing

To exercise these rights, contact us at naveenp@tangiblelearning.in. We will respond to your request within 30 days (or as required by applicable law).

8. Children's Privacy

We understand that many of our students are minors. We take special care to protect children's privacy:

8.1 Users Under 13 Years of Age

• Parental or guardian consent is mandatory before registration
• We do not knowingly collect data from children under 13 without verified parental consent
• Parents/guardians can request access to, correction of, or deletion of their child's information
• Parents/guardians have the right to refuse further collection or use of their child's information

8.2 Users Aged 13-17

• We encourage parental involvement in educational services
• Parents/guardians maintain oversight of their minor's account
• Account activity and academic progress may be shared with parents/guardians

If you believe we have collected information from a minor without proper consent, contact us immediately at naveenp@tangiblelearning.in.

9. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to enhance your experience and gather usage data.

9.1 Types of Cookies We Use

• Essential/Functional Cookies: Necessary for website operation, login sessions, and security features
• Analytics Cookies: Google Analytics and Tag Manager to understand site usage and improve functionality
• Performance Cookies: Monitor website performance and identify technical issues
• Preference Cookies: Remember your settings and preferences for a better experience

9.2 Cookie Duration

• Session cookies: Automatically deleted when you close your browser
• Persistent cookies: Remain on your device for specified periods (typically 1-24 months)

9.3 Managing Cookies

You can control cookie preferences through your browser settings. However, disabling certain cookies may limit website functionality, including exam portal access and login persistence.

9.4 Third-Party Cookies

Our website may use third-party cookies from:

• Google Analytics (analytics and usage tracking)
• Google Tag Manager (tag management and tracking)
• Video platforms (embedded content)

10. Do Not Track Signals

Our website does not currently respond to "Do Not Track" (DNT) browser signals, as there is no universal standard for DNT implementation. We will update our practices if industry standards emerge for recognizing and honoring DNT signals.

11. International Data Transfers

Your data may be transferred to, stored, and processed in countries outside your region, including India, United States, Singapore, and other jurisdictions where our service providers operate.

We ensure international transfers are protected through:

• Standard Contractual Clauses (SCCs) approved by relevant authorities
• Adequate data protection agreements with service providers
• Compliance with applicable cross-border data transfer regulations
• Appropriate safeguards to ensure your data receives adequate protection

By using our Services, you consent to the transfer of your information to countries that may have different data protection laws than your country of residence.

12. GDPR Compliance (EU/EEA/UK Users)

If you are located in the European Union, European Economic Area, or United Kingdom, you have additional rights under the General Data Protection Regulation (GDPR).

12.1 Legal Basis for Processing

We process your personal data under the following legal bases:

• Contractual Necessity: To fulfill our tutoring service agreement with you
• Legitimate Interests: To improve our services, prevent fraud, and maintain security
• Consent: For marketing communications and non-essential cookies
• Legal Obligations: To comply with tax, accounting, and regulatory requirements

12.2 GDPR-Specific Rights

In addition to the rights listed in Section 7, you have:

• Right to lodge a complaint with your local Data Protection Authority (DPA)
• Right to detailed information about automated decision-making
• Enhanced rights to data portability
• Right to object to direct marketing (absolute right)

12.3 Automated Decision-Making

Our exam portal uses automated systems to:

• Generate performance analytics and personalized recommendations
• Identify learning patterns and suggest study materials
• Flag unusual exam activity for manual review

You have the right to:

• Request human review of automated decisions
• Express your point of view regarding automated decisions
• Contest automated decisions that significantly affect you

12.4 Data Protection Contact

For GDPR-related inquiries, requests, or complaints: naveenp@tangiblelearning.in

12.5 EU Representative

As we do not have an establishment in the EU, we process data as a non-EU controller. If required by law, we will appoint an EU representative and provide their contact details here.

12.6 Cross-Border Data Protection

International data transfers comply with GDPR requirements through Standard Contractual Clauses (SCCs) or other approved transfer mechanisms recognized under EU law.

13. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to Know: What personal information we collect, use, disclose, and sell
• Right to Delete: Request deletion of your personal information
• Right to Opt-Out: Opt-out of the "sale" or "sharing" of personal information (Note: We do not sell personal information)
• Right to Non-Discrimination: Not receive discriminatory treatment for exercising your rights
• Right to Correct: Request correction of inaccurate personal information
• Right to Limit: Limit use of sensitive personal information

To exercise California privacy rights: naveenp@tangiblelearning.in

We will verify your identity before processing requests and respond within 45 days as required by California law.

14. Third-Party Links and Services

Our website may contain links to third-party websites and services, including:

• YouTube (embedded video testimonials and educational content)
• Payment processor websites (Razorpay, Wise)
• Social media platforms (Instagram, LinkedIn, YouTube)
• University and examination board websites
• Educational resource websites

We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies before providing any personal information. When you click on third-party links, you are leaving our website and are subject to the privacy policies of those sites.

15. Video and Class Recordings

15.1 Class Recordings Policy

• Live tutoring sessions may be recorded for educational, quality assurance, and student review purposes
• Recordings are accessible only to enrolled students and authorized instructional staff
• Students will be notified before recordings begin
• Recordings are stored securely and retained according to our data retention policy (Section 6)
• Students may request that their camera/microphone be turned off during recordings
• Recordings cannot be downloaded, shared, or distributed without written permission from Tangible Learning

15.2 Recording Access and Usage

Class recordings are provided for personal educational use only. Unauthorized distribution, public posting, or commercial use of recordings is strictly prohibited and may result in legal action.

16. Marketing Communications

16.1 How We Use Your Information for Marketing

With your consent, we may send you:

• Educational content and course updates
• Special offers and promotions
• Newsletter and blog updates
• Student success stories (with permission)
• Tips and learning strategies

16.2 Your Choices

• Opt-out anytime by clicking "unsubscribe" in marketing emails
• Manage communication preferences in your account settings
• Contact us at naveenp@tangiblelearning.in to update preferences

We will not send marketing communications to users who have opted out. Please note that you will continue to receive transactional and service-related communications even after opting out of marketing.

17. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect:

• Changes in our practices or services
• New legal or regulatory requirements
• Feedback from users and stakeholders
• Enhanced security measures and technologies

17.1 Notification of Changes

When we make material changes:

• We will update the "Last Updated" date at the top of this policy
• We may notify you via email to your registered address
• We may display a prominent notice on our website
• For significant changes affecting your rights, we will seek renewed consent where required by law

Continued use of our Services after changes constitutes acceptance of the updated Privacy Policy. We encourage you to review this policy periodically to stay informed about how we protect your information.

18. Contact Information

For questions, concerns, or requests regarding this Privacy Policy or our data practices: