Privacy Policy

Privacy Policy

This Privacy Policy (“Privacy Policy” or “this Policy”) applies to personal information of the children (along their parents/legal guardians, their siblings, and other individuals) (collectively, “the children and their families”, “you”, your”, ”yours”, as applicable) who are enrolled with Founding Years Learning Solutions Private Limited (“FYLS”, “we”, “us” or “our”) for various programmes, child care support, products, child daycare, crèche, preparatory school and after school services (collectively, “Products”, “Services” or “Program”). We respect privacy and we have a longstanding commitment to protecting personal information of the children and their families.

For the purposes of this Policy, “Personal Information” is defined as any identifiable information about the children and their families, such as contact details, health information, biological information, living arrangements, background information, the child’s personal characteristics, behaviour styles and any other information as disclosed to us.

Personal information is only collected, used and disclosed by us for Services in accordance with this Privacy Policy.

The Privacy Policy along with the Terms of Use describes our practices and your choices in relation to how we collect, store, use, share and share your personal information across our online platform klay.co.in (“Website”) and Curious Learners and Prepared Parents (CLAPP App).

This document is an electronic record in terms of Information Technology Act, 2000 and rules there under as applicable and the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.

Capitalised terms and expressions used in this Policy but not defined shall have the same meaning as ascribed to such terms in Terms and Conditions.

WHY DO WE COLLECT PERSONAL INFORMATION?

When enrolling your child/children in our Program, as a parent or a legal guardian, you are asked to provide certain pieces of information in order for us to provide you and your child / children with the safe, efficient, customised experience for Program activities. In addition to your contact details, the names and contact information of your family members, your child’s file may include the following information about your child, such as:

• Contact Information such as name, email, display picture, mailing address, phone number, IP address, geographic location, phone number, occupation, skill interest,
• Information to enable us to check and verify your identity eg. your date of birth, photo id proof details.
• Personal characteristics, skills, behavioural and health information.
• Details about the course enrolled, recording of session, children interaction with teacher/instructors.
• We may collect information such as occupation, language, pincode, area code, referrer URL, location, and the time zone where our Services are used so that we can better understand customer behavior and improve our products, services, and advertising.
• We may collect and store details of how you use our Services, including search queries. This information may be used to improve the relevancy of results provided by our Services. Except in limited instances to ensure quality of our Services over the Internet, such information will not be associated with your IP address.
• With your explicit consent, we may collect data about how you use your device and applications in order to help app developers improve their apps.

Personal information is only collected for the following purposes:

• To identify the children and their families;
• To provide the children a safe, efficient, smooth experience of the Program;
• To improve security, analyse trends and administer the Website with a view to improve Program experience;
• To secure and protect the site against fraudulent logins and detect and prevent abuse and unauthorized use of your account.
• To monitor developmental levels, skill acquisition and special needs of the children;
• To establish a culturally sensitive and developmentally appropriate program for the children;
• To understand the desires, concerns and opinions of the children for the activities and their families;
• To establish and maintain good relationships with the children and their families;
• To provide responsible and customised services experience for the activities program to the children and their families; and
• To manage and enhance our business and operations; and to meet legal and regulatory requirements (if any).

We never collects more personal information than is needed to fulfil these purposes, unless you have consented to such collection.

We collect information about the children and their families for use of our Services, your interactions with us. This information includes your activity on our Website, such as online classes, activity materials; details and recording of your interactions and classes with our professionals like teachers and trainers etc. with the aim to provide better services and better interaction with teachers and trainers.

In case of payments via credit or debit card, we will redirect you to registered payment gateways such as Razorpay and other such registered 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.

WHEN DO WE DISCLOSE PERSONAL INFORMATION AND TO WHOM

We will make sure that any required disclosures of Personal Information are made on a “need to know” basis, and where applicable, on a confidential basis. Personal information is never traded, sold or leased by us to any external entity.

When sharing personal information, we release limited information as required for the activities that will be performed by the representative on our behalf i.e. instructors, teachers and trainers. We also ensure that every representative is clear on their obligation to protecting Personal Information and using the same for the purpose(s) for which it is being provided.

We may advertise and promote our Program to get more traction by sharing the photographs and video recording of the sessions in a secured manner without sharing the personal information of the children and their families.

Disclosure to Third Parties

At times we may make certain Personal Information available to strategic partners that work with us to provide Services, or that help us market to customers. For example, when you purchase any Services from us, you authorize us to exchange the information you provide during the activation process to carry out service. Personal Information will only be shared by us to provide or improve our products, services and advertising; it will not be shared with third parties for any marketing purposes.

Service Providers

We may share Personal Information with companies who provide services such as information processing, fulfilling customer orders, delivering products to you, managing and enhancing customer data, assessing your interest in our Products and Services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your information.

Others

It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for us to disclose your Personal Information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.

We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

HAVE YOU CONSENTED?

Having read this policy and by enrolling your child for our Program and by providing us with the personal information requested, you consent to the collection, use and disclosure of your personal information as specified herein.

If we will be using or disclosing Personal Information for purposes that have not been stated in this Policy and that we do not feel are obvious to you, we will first obtain your consent. We may imply your consent if we feel we are using your personal information for purposes that are obvious to you. For example, if you tell us that your child has some allergy, we may not seek your consent before providing this information to the professional conducting the activities. With written notice you may withdraw consent at any time subject to legal or contractual restrictions and reasonable notice. You may contact us for more information regarding the implications of withdrawing consent.

In certain circumstances, Personal Information can be collected, used or disclosed without the knowledge and consent of the individual (or his/her parents/legal guardian). For example: If it is clearly in the interests of the individual and consent cannot be obtained in a timely way, such as when the individual is seriously ill or mentally incapacitated; if seeking the consent might defeat the purpose for collecting the information, such as in the context of an investigation of a breach of an agreement or if there is an emergency where the life, health or security of an individual is threatened.

HOW LONG IS YOUR INFORMATION RETAINED?

We retain personal information only as long as it remains necessary or relevant for the identified purposes, and in accordance with legal requirements.

Therefore, we will retain your child’s file as long as your child is enrolled in our Program and for a fixed period of time thereafter.

Depending upon the circumstances, where Personal Information has been used to make a decision about an individual, we will retain the information for a period of time that is reasonably sufficient to allow for access by that individual (or his/her parent/legal guardian).

We retains and securely destroys personal information in accordance with our internal record retention procedure. Our retention procedure takes into account retention requirements for financial and insurance records and the statutes of limitation relevant to injuries that occur while children are in our care.

HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE?

We have procedures and policies in place to ensure that Personal Information, in both paper and electronic formats, are protected against the risk of loss, theft, unauthorized access, disclosure, copying, modification or destruction. For example, we have the following safeguards in place:

• All visitors are required to report to the office and will be escorted while on the premises.
• Filing cabinets containing personal information are only accessible to the directors, centre heads, administration staff and the onsite supervisors of our child care programs. When filing cabinets are not in use and after hours they are locked.
• Access to electronic files is limited on a need to know basis depending on the job function.
• Paper records containing personal information that are no longer needed are securely shredded.
• Password selection criteria and password expiry make unauthorized access to our systems extremely difficult. Our databases are well protected on servers equipped with enterprise firewalls that are immediately updated when new patches and fixes are released.
• Installed safety measures, in full conformity with all information and technology laws and strictly complied to ensure for the safe and secure digital environment for the online activities.

Staff training on the importance of privacy and security is undertaken regularly.

HOW CAN YOU ACCESS YOUR PERSONAL INFORMATION AND CHECK ITS ACCURACY?

We rely on the information provided by you when enrolling your child in our Program. You may at any point of time make a written request for access to your or your child’s personal information. Personal information will be provided in an understandable form within a reasonable time and at minimum or no cost to the individual.

However, in certain situations we may not be able to provide access to all of the Personal Information we hold about an individual (or his/her child). For example, we cannot provide access to Personal Information about another individual if they have not consented, or to information that could reasonably be expected to threaten the life or security of another individual. Also, we cannot provide access to information that was generated in the course of a formal dispute resolution process. If we are unable to provide you with all the information contained in your child’s file, we will let you know.

We strives to maintain accurate records of your Personal Information, however, this cannot be achieved without your help. In this ongoing effort, we ask you to provide us with up to- date information. Let us know of any Personal Information you have given to us in the past that is incomplete, inaccurate, or no longer relevant, or of any new issues or information that will help us related to the program for your child. If you feel a record in your child’s file is inaccurate or incomplete, and we agree with your assessment, we will promptly correct or complete the information. Any unresolved differences as to accuracy or completeness will be noted in the file.

COOKIES AND OTHER TECHNOLOGIES

A “cookie” is a small piece of information stored by a web server on a web browser so it can be later read back from that browser. Cookies are useful for enabling the browser to remember information specific to a given user. We place both permanent and temporary cookies in your computer’s hard drive. The cookies do not contain any of your personally identifiable information.

We use data collection devices such as “cookies” on certain pages of the Website to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our product and services, measure promotional effectiveness, and promote trust and safety and to gather demographic information about our user base as a whole. We may use this information in our marketing and advertising services.

In some of our email messages, we use a “click-through URL” linked to content on the Website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications.

“Cookies” are small files placed on your hard drive that assist us in providing our services. We offer certain features that are only available through the use of a “cookie”.

We also use cookies to allow you to enter your password less frequently during a session. Cookies can also help us provide information that is targeted to your interests. Most cookies are “session cookies,” meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the Website and you may be required to re-enter your password more frequently during a session.

OWNERSHIP OF RIGHTS

All rights, including intellectual of property rights and copyrights, Website or its contents, including copying, recording or storing it or them in whole or part, is prohibited without our permission.

You are prohibited from modifying, copying, distributing, downloading, recording including screen-recording, transmitting, displaying, printing, publishing, selling, licensing, creating derivative works or using any content available on or through our physical premises or our Website for commercial, public or any other purposes. You may not modify, distribute or re-post something on this Website for any purpose.

CONDITIONS OF USE

We do not warrant that this Website, its servers, or email sent by us or on our behalf are virus free. We will not be liable for any damages of any kind arising from the use of this Website, including, but not limited to compensatory, direct, indirect, incidental, punitive, special or consequential damages, loss of data, goodwill, business opportunity, income or profit, loss of or damage to property and claims of third parties.

LOCATION-BASED SERVICES

To provide location-based services for our Programs, we may collect, use, and share precise location data, including the real-time geographic location of your computer or device. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and, and other technologies to determine your devices’ approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used by us, and our licensees to provide and improve location-based products and services. For example, your device may share its geographic location with application providers when you opt in to their location services.

CONTACT US WITH ANY QUESTIONS OR CONCERNS

If you have any further questions or concerns about the Privacy Policy or data processing or if you would like to make a complaint about a possible breach of local privacy laws, please contact us on Privacy@klay.co.in. You can always contact us by contact details provided in our website.

All such communications are examined and replies issued where appropriate as soon as possible. If you are unsatisfied with the reply received, you may refer your complaint to the relevant regulator in your jurisdiction. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.

We may update our Privacy Policy from time to time. When we change the policy in a material way, and may be posted on our website along with the updated Privacy Policy.