Background:

Empagnie Education Private Limited (hereinafter referred to as “Company”, “us”, “we” or “our”) believes in connecting students to colleges and different careers by leveraging AI (artificial intelligence) and via a pool of knowledge provided by expert contributors worldwide. All information is provided to users (hereinafter referred to as “you”) who wish to gain more knowledge about the Company’s offerings through its Websitewww.collegepass.org (the “Website”). The Website is a platform that facilitates online education and career guidance for students through videos and may also include any written material, blogs, audio, or any other mode of communication used by the Company. We also believe in respecting and protecting your privacy with the highest standards, and keeping that in mind, we have listed our privacy policy (hereinafter referred to as the “Privacy Policy”) below.

Important Notice:

Kindly read this privacy policy carefully. By using the Website, you acknowledge that you have read, understood, and agree to be bound to all terms and conditions of this privacy policy. If you do not agree to such terms, exit our Website now and do not access or use our Website any further.

This Privacy Policy is a legally binding electronic agreement formed under the Information Technology Act, 2000 and the Rules made thereunder, and the amended provisions pertaining to electronic documents/records in various statutes as amended by the Information Technology Act, 2000.

Our Commitment:

We respect your privacy and are committed to protecting the privacy of all personal information we obtain from you through the Website. This Privacy Policy is created to inform you about how the Website collects, uses, and shares your personal information and to inform you about our general rules on the management of privacy. We are available to address any questions and concerns that you may have regarding this Privacy Policy. Please contact us at support@collegepass.org. Please note that we may modify this Privacy Policy from time to time to bring about certain changes. You are requested to review this Privacy Policy regularly and see when it was last updated. If we make any changes to this Privacy Policy, we may notify you on this webpage, via email, or by means of notice through the Website. Your continued use of the Website is deemed to accept this Privacy Policy and any changes thereto. You can visit the Website and browse without having to provide Personal Information. During your visit to the Website, you remain anonymous, and at no time can we identify you unless you provide any Personal Information to us (for example, to download documents) or have an account on the Website and log on with your Account Information.

Types and Uses of collected information:

We receive and collect information when we provide our services. Sometimes, we may also disclose to third parties certain personal information, including name, email, phone number, and other information that we collect, including but not limited to educational information, as you access and use the Website, including device information, location, network carrier, etc. The Website may also collect Personally Identifiable Information about you, i.e., the information that identifies your personal identity.

• Name;
• Username;
• Email address;
• Mobile number;
• Gender identity;
• Date of birth;
• Photographs;
• Location; and
• Login information for social media accounts that you connect to your CollegePass Account (this could include, for example, your Facebook and Instagram accounts).

Personally, Identifiable Information includes:

(a) “Contact Data” (for example - your name, address, city, state, zip code, and email address),

(b) “Financial Data” (such as your credit card number, bank information, expiration date, and verification code) (only if applicable)

(c) “Demographic Data” (for example - your Zip code / PIN Code, gender, etc),

(d) “Educational Data” (for example – the name of your school, degree, educational qualifications, work experience, etc.).

When you access the Website by creating an account, we may ask you to provide certain information about yourself. Please note that some of the information we ask you to provide may be mandatory, and some may be identified as voluntary. If you do not provide the mandatory information for a particular purpose, you will not be permitted to engage with the Website. Once asked and received correctly, the Website may not ask you again for the information above if such is already stored with us. We may also use Personally Identifiable Information to solve disputes, perform administrative actions, contact you, enforce our agreements with you, including our Terms of Use and this Privacy Policy, comply with applicable law, and cooperate with law enforcement activities.

The Company may also collect Non-Personally Identifiable Information, which means the information may include things like the Uniform Resource Locator (commonly known as URL) of the websites that you accessed before visiting our Website, the URL of the Website you visit after leaving our Website, browser information such as what type and version of the browser you are using, your Internet Protocol address (commonly known as IP address), or general and/or aggregated location data that does constitute Personally Identifiable Information. The Website and/or our authorized Trusted Third Parties may automatically collect this information when you visit or use the Website through electronic tools like Cookies and web beacons or Pixel tags, as described below in this Privacy Policy.

We will keep your Personal Information only for as long as we are required to by law or as is necessary for the purposes it was collected. Your Personal Information may be used for one or more of the following purposes:

a) to facilitate your use and personalize your experience of the use of the Website.

b) to record, support, and facilitate your selected services and activities.

c) to respond to your inquiries or fulfill your information request about our services.

d) to provide you with information about our services and send you information and materials from the Company.

e) to send you important information regarding the Website, our Terms and Conditions, Policies and/or other general business information.

f) to help you address problems with the Website, including any technical or use-based problems.

g) to improve the content of the Website.

h) to help detect and prevent identity theft, fraud, and other potentially illegal acts and protect the website's integrity.

i) to provide information to law enforcement agencies or in connection with an investigation on matters related to public safety.

j) to resolve disputes and troubleshoot problems.

k) in connection with any investigation or complaint.

l) to provide you with relevant information or services that you request from us or which we feel may interest you based on previous interactions where you have consented to be contacted.

The Company may use Non-Personally Identifiable Information to troubleshoot, administer the Website, analyze trends, gather demographic information, create internal quality standards, generate data analysis reports, comply with applicable law, and cooperate with law enforcement activities, if applicable. We may also share this information with our authorized Trusted Third Parties to measure the overall effectiveness of our products and services.

Data Retention and Deletion:

We keep your personal information only as long as we need it for the legal basis relied upon and as permitted by applicable law. When you delete your account, or we deactivate it, we make sure it is no longer viewable in the App. For up to 28 days, it is still possible to restore your Account if it was accidentally deleted or wrongfully deactivated. After 28 days, we begin the process of deleting your personal information from our systems unless:

1. we must keep it to comply with applicable law (for instance, if you make purchases within the App, some personal data may be kept for tax and accounting purposes)

2. we must keep it to evidence our compliance with applicable law (for example, if an account is blocked, we keep some account information and a record of the behaviour that led to the block - this information is retained for evidential purposes in case of queries or legal claims concerning the block);

3. case of queries or legal claims concerning the block); there is an outstanding issue, claim, or dispute requiring us to keep the relevant information until it is resolved; or

4. The information must be kept for our legitimate business interests, such as fraud prevention and enhancing Users’ safety and security (for example, information may need to be kept to prevent a user who was banned for unsafe behaviour or security incidents from opening a new account).

Release:

We will not sell or share your Personally Identifiable Information with other parties except as provided below:

a. Remarketing: Remarketing is an effective way for our Company to connect with various people based upon your past interactions with our Website. To put this into effect, the Company may hire vendors such as marketing companies or individuals to perform remarketing services. As a result, third-party vendors, including Google™, may show the Company’s products or services’ advertisements on the Internet. Third-party vendors may use cookies to serve advertisements based on a user’s prior visits to the Website. Users may opt out of Google™’s use of cookies by visiting the Google™ advertising opt-out page at http://www.google.com/privacy_ads.html.

b. Acquisition: The Company may also merge with or be acquired by another company. In case any of this happens, the successor company shall acquire the information we presently maintain, including Personally Identifiable Information, which will still remain subject to this Privacy Policy.

c. Legal Compliance: The Company reserves the right to disclose your Personally Identifiable Information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a court order or legal process served on us, enforce or apply this Privacy Policy, Terms of Use or other agreements or protect the rights, property or safety of the Website.

Advertising: The Company or any of our advertising partners may deliver advertisements on the Website to you. The Company may also use third-party service providers to serve advertisements when you use the Website. These providers may use Non-Personally Identifiable Information about your visits and use of the Website, and visits to other websites or locations to provide, through network tags, advertisements about goods and services that may be of interest to you. Our advertising partners may also set cookies, which will allow them to recognize your computer each time they send you an advertisement. This way, they may also compile information about where you, or others using your computer or device, saw their advertisements and determine which advertisements are clicked. This information shall allow an advertising partner to deliver targeted advertisements that they believe will most interest you. The Company does not have access to or control the cookies that may be placed by the third-party advertising servers of advertisement partners. This Privacy Policy covers the use of cookies by the Company and does not cover the use of cookies by any of its advertisers.

Third Party Websites: The Website may maintain links to other websites, and if you choose to visit other websites, the Company shall not be responsible for the privacy policies or content of those other websites, and it is your responsibility to review the privacy policies and terms of use of those websites to confirm that you understand and agree with their practices and policies.

Data Tracking and Cookies:To enhance your experience of using the Website, we may store cookies on your computer or other similar devices through which you access the Website. Please be informed that a cookie is a small text file stored on your computer or other mobile or tablet device for record-keeping purposes that contain information about you. The Company uses cookies to save you time while using the Website, remind us who you are, and track and target your interests to provide a customized experience. Cookies also allow the Company to collect Non-Personally Identifiable Information from you, like which pages you visited, what links you clicked on, and how you used the Website. We may use Trusted Third Parties to display advertisements on our Website. They may also place separate cookies on your computer or similar devices we have no access to or control over. This Privacy Policy covers the use of cookies by the Website only and does not cover cookies by any third party. You are hereby informed that most browsers automatically accept cookies; however, you may be able to modify your browser settings to decline cookies. Kindly note that if you decline or delete these cookies, some parts of the Website may not work correctly.

If, for any reason, you believe that your privacy has been breached through the use of our Website, you may contact us immediately at support@collegepass.org

Please note that all trade names, trademarks, logos, and business identifiers that are listed in this Privacy Policy but are not owned by the Company, are owned by their respective owners. The Company claims no affiliation or partnership with these trademarks or their owners, and any presumption of such affiliation, association, partnership, or endorsement shall be entirely at your risk and costs.