Privacy Policy

Bloom & Boost ^TM : Brain Skills Program ("the Proprietorship") is committed to protecting the privacy and personal data of parents, guardians, website visitors, students, participants and other individuals who interact with our services.

This Privacy Policy explains how we collect, use, process, store, disclose, retain and protect personal data when individuals visit our website, contact us, enroll in programs, attend demonstrations, workshops, orientations, events, make payments or otherwise interact with our services.

This Privacy Policy is intended to comply with the Digital Personal Data Protection Act, 2023 ("DPDP Act") and other applicable laws of India.

By accessing our website, submitting information, making payments or using our services, you acknowledge that you have read and understood this Privacy Policy.

The Data Fiduciary responsible for processing personal data under this Privacy Policy is:

We may collect the following categories of information:

Information may be collected when users:

• Visit the website;
• Submit enquiry forms;
• Register for demonstrations, orientations, workshops, or events;
• Contact us through phone, WhatsApp, email or social media;
• Subscribe to updates or newsletters;
• Enroll in educational programs;
• Complete assessments;
• Make online payments;
• Participate in surveys or promotional activities.

Personal data may be processed for the following purposes:

Personal data may be processed based upon:

• Consent;
• Performance of requested services;
• Compliance with legal obligations;
• Legitimate uses permitted under applicable law and purposes reasonably necessary for operating and improving our services;
• Fraud prevention and security purposes;
• Legitimate uses permitted under applicable law.

Bloom & Boost respects the right of individuals to make informed decisions regarding the processing of their personal data.

Where consent is required under applicable law, personal data shall be processed only after obtaining valid consent from the Data Principal or, in the case of a child, from the parent or lawful guardian.

Bloom & Boost provides educational and developmental services for children. Bloom & Boost shall process children's personal data only to the extent reasonably necessary for providing educational and developmental services.

Accordingly:

• Registrations and communications must be undertaken by parents or lawful guardians.
• Parents or guardians are responsible for providing valid consent.
• We do not knowingly collect personal data directly from children without parental involvement.
• We do not knowingly undertake behavioural monitoring of children.
• We do not engage in profiling of children.
• We do not knowingly undertake targeted advertising directed at children.
• We do not knowingly undertake automated decision-making that may adversely affect a child.
• We do not process children's personal data in a manner likely to cause harm or detriment.

Any person providing information relating to a child represents and warrants that they are legally authorised to do so.

The website may use:

Users may disable cookies through browser settings.

Bloom & Boost may engage third-party service providers including website hosting providers, cloud service providers, communication service providers, analytics providers, advertising platforms, software providers, professional advisers and other authorised service providers.

Such providers may receive, access, store, process or transmit personal data solely for authorised business, operational, educational, technical, administrative, marketing, security or support purposes.

Bloom & Boost may utilise third-party analytics, advertising and marketing technologies including services provided by Google, Google Analytics, YouTube, Meta Platforms (including Facebook and Instagram) and similar service providers.

These services may collect technical information such as IP addresses, browser information, device information, cookies, website interactions and usage information for analytics, advertising measurement, audience insights, campaign effectiveness, website improvement and related purposes.

Certain service providers may process information outside India. Where such transfers occur, Bloom & Boost shall take reasonable measures to ensure appropriate protection of personal data and compliance with applicable Indian laws.

The website may contain links to third-party websites or platforms. Bloom & Boost does not control and is not responsible for the privacy practices, content, security or policies of such third parties.

Where required by applicable law, appropriate consent shall be obtained before deploying advertising or tracking technologies.

Bloom & Boost implements reasonable administrative, technical, contractual and organisational measures designed to protect personal data against unauthorised access, disclosure, alteration, misuse, loss or destruction.

Access to personal data is restricted to Bharavi, authorised employees, trainers, consultants, contractors, service providers and other authorised personnel who reasonably require access for authorised business, educational, administrative, operational, support, security or compliance purposes.

Individuals granted access to personal data are expected to maintain appropriate confidentiality, privacy and security obligations and may access personal data only on a need-to-know basis.

Security measures may include access controls, password protections, restricted access permissions, secure hosting environments, security monitoring, periodic reviews and other reasonable safeguards. Such safeguards may be reviewed, updated or modified from time to time in light of technological developments, business requirements, legal obligations and evolving security risks.

While Bloom & Boost strives to maintain appropriate security standards, no method of internet transmission or electronic storage can be guaranteed to be completely secure.

Individuals may interact with Bloom & Boost through social media platforms including Facebook, Instagram, YouTube, WhatsApp, LinkedIn, or similar platforms.

Information voluntarily submitted through messages, comments, enquiries, registrations, reviews, testimonials, or other interactions may be collected and used for communication, customer support, educational services, marketing, program administration, and legitimate business purposes.

During classes, workshops, demonstrations, orientations, events, competitions, online sessions, or similar educational activities, Bloom & Boost may create, collect, or use photographs, videos, audio recordings, testimonials, feedback, success stories, event highlights, or related media content.

Where required by applicable law, appropriate consent shall be obtained before using identifiable photographs, videos, testimonials, or similar content for educational, promotional, informational, marketing, website, social media, advertising, publication, or related business purposes.

Parents or guardians may contact Bloom & Boost regarding any concerns or restrictions relating to such content.

Bloom & Boost may use anonymised, non-identifiable, aggregated, or group-event content for legitimate educational, operational, informational, archival, or promotional purposes where permitted by applicable law.

Personal data may be disclosed:

• To Bharavi and authorised employees;
• To authorised service providers;
• To professional advisers;
• To regulatory authorities;
• To law enforcement agencies pursuant to lawful resquests;
• To protect rights, safety, security or property.

Personal data shall not be sold.

For safety, security, incident investigation, asset protection, access management, fraud prevention and lawful business purposes, Bloom & Boost may use CCTV systems or similar security monitoring technologies at its premises or event locations.

Recorded footage may be reviewed, stored, disclosed, retained or used where reasonably necessary for security, safety, legal, regulatory, evidentiary, dispute-resolution, insurance, operational or compliance purposes.

Access to CCTV recordings shall be restricted to authorised personnel and other authorised persons having a legitimate need to access such information.

Bloom & Boost may utilise software platforms, automation tools, cloud-based services, artificial intelligence-assisted technologies, communication tools, analytics systems, productivity tools, educational technologies, scheduling platforms, customer relationship management systems and similar technologies for educational, operational, administrative, communication, analytical, support, security and business purposes. Such technologies shall be used in accordance with applicable law and subject to reasonable safeguards intended to protect personal data.

Bloom & Boost does not intentionally rely solely upon automated processing to make decisions that would materially and adversely affect the rights or interests of a child. Bloom & Boost may generate, create, analyse, retain, publish or otherwise use anonymised, de-identified, statistical, aggregated or non-personally identifiable information for educational, operational, analytical, quality improvement, reporting, service enhancement, business development, marketing, compliance and other lawful purposes.

Such information shall not identify any individual.

In the event of a personal data breach, Bloom & Boost shall take such measures as may be required under applicable law, including investigation, mitigation and notification where legally required.

Bloom & Boost retains personal data only for as long as reasonably necessary to provide services, manage accounts, comply with legal, regulatory, accounting, security, operational and contractual obligations, resolve disputes and protect legitimate business interests.

Indicative retention periods may include:

• Website enquiries and prospective customer records – up to 3 years from the last meaningful interaction;
• Student and program participation records – up to 5 years after completion of the relevant program;
• Marketing consent records – until consent is withdrawn and for a reasonable compliance period thereafter;
• Financial and statutory records – for such period as required by applicable law.

Upon expiry of the applicable retention period, information may be deleted, anonymised or securely archived.

Subject to applicable law, Data Principals may:

• Access personal data;
• Obtain information regarding processing activities;
• Request correction;
• Request updating;
• Request deletion;
• Withdraw consent;
• Seek grievance redressal;
• Exercise rights available under applicable law.

Subject to applicable law, Data Principals may nominate another person to exercise their rights in the event of death or incapacity.

Bloom & Boost will make reasonable efforts to honour requests relating to personal data in accordance with applicable law. However, certain requests may be refused, restricted, or delayed where permitted or required by law, including where information must be retained for legal, regulatory, accounting, security, fraud-prevention, dispute-resolution or other legitimate business purposes.

Bloom & Boost is committed to addressing privacy-related concerns in a fair, transparent and timely manner.

If you have any questions, concerns, requests or complaints regarding the collection, processing, use, disclosure, retention, correction or deletion of your personal data, you may contact our Grievance Officer using the details provided below.

Upon receipt of a grievance, Bloom & Boost shall make reasonable efforts to acknowledge and address the concern within a reasonable period 30 days in accordance with applicable law.

In the event of a merger, acquisition, investment transaction, restructuring, succession, sale of business, transfer of assets, conversion of the proprietorship into another legal structure, formation of a partnership, LLP or company, franchise expansion, business reorganisation, or any similar transaction, personal data may be transferred to the successor, acquiring, investing, affiliated or continuing entity, subject to applicable law and appropriate safeguards.

Any such successor entity shall be entitled to continue processing personal data in a manner substantially consistent with this Privacy Policy unless otherwise permitted or required by applicable law.

Users represent and warrant that all information submitted is accurate, complete, current and lawful.

Bloom & Boost shall not be responsible for losses arising from inaccurate, incomplete, misleading or unauthorised information provided by users.

Where personal data relates to a child, Bloom & Boost expects that all information, registrations, enrolments, assessments, communications, permissions and consents relating to the child shall be provided by the child's parent, lawful guardian or another person who is legally authorised to act on behalf of the child.

Any individual providing information relating to a child represents and warrants that:

• they are the child's parent, lawful guardian or otherwise legally authorised to provide such information and consent on behalf of the child;
• they possess all necessary authority, permissions and rights required to disclose the child's information to Bloom & Boost;
• the information provided is accurate, complete and not misleading; and
• the provision of such information and any consent provided does not violate any applicable law, court order, custody arrangement, guardianship arrangement, parental rights or rights of any third party.

Bloom & Boost may rely upon the information, permissions and consents provided by the individual submitting such information unless it becomes aware of circumstances indicating otherwise.

Bloom & Boost reserves the right to request proof of identity, parental authority, guardianship, authorisation or other supporting documentation where reasonably considered necessary.

Bloom & Boost shall not be responsible for any loss, claim, dispute, liability or consequence arising from inaccurate, incomplete, unauthorised, fraudulent or improperly provided information, permissions or consents relating to a child.

Where Bloom & Boost becomes aware of a dispute concerning parental authority, guardianship, custody, consent or authorisation relating to a child, Bloom & Boost reserves the right to suspend, restrict or refuse processing of the relevant personal data until appropriate clarification or documentation is provided.

Bloom & Boost shall not be liable for delays, interruptions, security incidents or failures caused by circumstances beyond reasonable control, including cyber-attacks, internet failures, power outages, governmental actions, natural disasters, labour disputes, pandemics or failures of third-party service providers.

If any provision of this Privacy Policy is determined to be invalid or unenforceable, the remaining provisions shall continue in full force and effect.

Bloom & Boost may update, amend, revise, or modify this Privacy Policy from time to time to reflect changes in applicable laws, regulatory requirements, business practices, technology, services or data processing activities.

Any updated version of this Privacy Policy shall be published on the website together with the revised "Last Updated" date.

Notification of updates may be provided through the website, email, WhatsApp, platform notifications, or any other reasonable communication channel considered appropriate by Bloom & Boost. Continued Use Continued use of our services after the effective date constitutes acceptance of minor updates.

Where required under applicable law, Bloom & Boost may provide additional notice or obtain fresh consent before implementing material changes affecting the processing of personal data.

This privacy policy complies with the Digital Personal Data Protection Act, 2023 and will be updated as necessary to reflect any changes in the law or our data processing practices.

This Privacy Policy shall be governed by the laws of India. Subject to applicable law, the courts at Navi Mumbai, Maharashtra shall have exclusive jurisdiction over disputes arising from or relating to this Privacy Policy.

For questions regarding this Privacy Policy, please contact: