This Privacy Policy (“Privacy Policy”) discloses the privacy practices for M/S SMRT GURU (“SmrtGuru”, “Site/site”, “We/we” or “Us/us”) with regard to Your (“You/you” or “Your/your”) use of the online platform www.smrtguru.com (“Website”). By visiting this Website, you agree to be bound by Terms and Conditions and by this Privacy Policy. If you do not agree to these conditions please do not use the website. Please note we may change the term or terms contained within this Privacy Policy without any prior notice. Collection of Information We collect your Personal Data only when you register with us on our website. You may visit our Site without registering with us but your access would be limited to certain pages, when you do so we collect certain information to analyze the trends, improve security with the objective of improving the overall customer experience. This information is automatically collected. Automatically tracked information includes Cookie information, your IP address, details of the device you use to access the Site, the pages you visit and the actions taken, the times and dates of actions you take on our website, your interactions with our email, text and in-app messages, the source of your visit and/or previous webpage before visiting our Site, and your page response times. The information collected is handled with utmost ethics and is not revealed to any other third party expect for availing analytics services. Our use of this data is limited to enhancing the customer experience by analyzing the same. As part of the process of using the Site and the Services, we require you to give us certain Personal Information which we need to provide our Service. Without this information we may not be able to fulfil our contract with you. This information includes:–

• Contact information such as name, email address, display picture, phone number, IP address;
• Billing information such as credit card details, debit card details, net banking details, UPI details, billing address;
• Other personal information like your date of birth, PAN card, mark-sheets;
• Unique identifier like password;
• Reviews and ratings, provided through our site
• Information provided to us through our service, participation in surveys or marketing campaigns
• Guru application details: so we can process your application to become a Guru. These details include your educational background and qualifications, your tutoring subjects, your profile picture and educational video, the prices you charge, your availability
• Communication history: to enable communication with other users of the website and with the SmrtGuru team, we store details about your communication history including user messages, requests you have made, and your interactions with the SmrtGuru team (including call recordings).
• Booking history: to facilitate tutorials including information on booking requests, status of bookings, booking subjects and class.
• Promotions you redeemed: we record details of referral codes shared, redeemed and other promotions you interact with to be able to apply rewards to your account.
• Identity verification information: when you apply as a Guru we may ask you to verify the claims you made by providing us legitimate documents and certificates.

  Payment via our site are processed by third party payment gateway(s) to facilitate secure transaction, we do not have any control over their operations and data collected by them. We do not store your credit/debit card number, expect for the last four digit to maintain a record of the transaction done (we store payment details of Guru to facilitate timely payments due to them). Your personal information like display picture, name may be publicly displayed to other users on our website depending on what type of service you use. Guru’s personal information in addition to the ones mentioned above include qualification, experience, subjects offered and their pricing, availability, description provided by you, and languages spoken. Processing Information We also use your information to support our legitimate interests in marketing our Site and the Services. These processes include:

• Marketing activities to promote our services to registered users. These communications may be personalised to you and your interactions with the Site and can be delivered by email, social media advertising and other digital marketing channels
• Notifying you about upcoming promotions, Referral Discount Codes, services or customer surveys
• Undertaking impact reporting to understand the efficacy of our Services
• Undertaking research to better understand our customers’ interests
• Analysing your interactions to improve the efficiency of our marketing activities

Who else has the access to your information?

1. Other users on the Site

Your Personal Information may also be viewed by Guru (where you are a Client) or by a Client or Guru (where you are a Guru) for the sole purposes of enabling Gurus to deliver their Tutoring Services direct to you and to provide you with information about their Tutoring Services and access to the Tutoring Services themselves. If you as a Client make a request for Tutoring Services with a Guru via the Site, your Personal Information will be shared with the Guru to enable the Guru to deliver the Tutoring Services or to follow up on any enquiry. Such details may include: first name and initial of surname, the contents of your message, and the subject, board and class you requested. If you as a Guru submit Personal Information on the Site for example by creating a profile, Personal Information in your profile may be accessible by any User who visits the Site. The personal information shared may include: first name and initial of surname, university details, the description you write for SmrtGuru, your profile picture and video, your grades, your tutoring subjects and price band, your tutoring record and reviews. Releasing this Personal Data is necessary for you to make use of the Site and the Services. If you as a user send a message to another user on the Site, you acknowledge that SmrtGuru may monitor the content of your message to fulfil our safeguarding obligations and to protect our legitimate interests. When you use certain features on our website like the discussion forums and you post or share your personal information such as comments, messages, files, photos, will be available to all users, and will be in the public domain. All such sharing of information is done at your own risk. Please keep in mind that if you disclose personal information in your profile or when posting on our forums this information may become publicly available.  

1. Third party companies and service providers

We use a variety of third party companies to provide the services and we may need to pass some Personal Information to these third parties. If we pass Personal Information to third parties, we minimise as far as possible what Personal Information is shared. The categories of third party providers we share personal data with include:

• Analytics providers
• Payment providers
• Communications platforms for email, text and in-app communications
• Marketing platforms
• Business operations tools
• Surveys and research providers
• Accounting and finance platforms
• Customer support platforms

Keeping Data Safe The privacy and protection of your Personal Information is important to us. You acknowledge that email messages sent over the internet are not encrypted and are not secure. Despite efforts to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to us, or to or from our online Services. You accept that SmrtGuru cannot be held liable for any breaches of confidentiality that may occur as a result of the use of email. You transmit all such information at your own risk. However, once we receive your transmission, we use our best efforts to ensure its security on our systems. The Site has security measures in place to protect the loss, misuse, and alteration of the information under our control. We use 128-bit industry-standard Secure Server Software (SSL) for your transactions with us. It encrypts all your Personal Information, including credit card number, name, and address, so that it cannot be read as the information travels over the Internet. Notwithstanding anything contained anywhere in this Agreement; we cannot assure absolute security to your personal data and by entering into or by logging into our website, you explicitly agree not to sue us for any data breach. Cookies We send cookies (small files containing a string of characters) to your computer, thereby uniquely identifying your browser. Cookies are used to track your preferences, help you log in faster, and aggregate to determine user trends. This data is used to improve our offerings, such as providing more- content in areas of greater interest to a majority of users. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Some of our features and services may not function properly if your cookies are disabled. Log When you access our Website, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, internet protocol address, browser type, browser language, the date and time of your request, and one or more cookies that may uniquely identify your browser. Apart from these, we maintain a log of your interactions with our website so as to have a record of the changes made by you to enable us to have reference data in case of any disputes. Retaining your information We plan to retain user data while an account is active and for at least three years afterward. We may alter this practice according to legal and business requirements. For example, we may lengthen the retention period for some data if needed to comply with law or voluntary codes of conduct. Unless otherwise prohibited, we may shorten the retention period for some types of data if needed to free up storage space. Changes to this Statement As the Company evolves, our privacy policy will need to evolve as well to cover new situations. You are advised to review this Policy regularly for any changes, as continued use is deemed approval of all changes. Consent By registering with us or using our site you give your consent to use your data as laid out in this Privacy Policy. Contact Information You may contact our grievance officer at [email protected] We keep our Statements under regular review. This Statement was last updated on 31 September 2021.