Privacy Policy

Introduction

Skolarli Edulabs Pvt. Ltd. ("Skolarli," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, web application, and services (collectively, the "Services") at skolar.li.

By using our Services, you consent to the data practices described in this Privacy Policy. If you do not agree with the practices described herein, please do not use our Services.

This Privacy Policy is designed to comply with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and the Digital Personal Data Protection Act, 2023 ("DPDP Act") of India.

Data Controller and Data Processor

1. For Account Owners (Instructors, Trainers, Coaches, Organizations): Skolarli acts as the Data Fiduciary (Controller). We determine the purposes and means of processing your personal data in connection with your use of our Services.
2. For Learners/Students: Skolarli acts as a Data Processor on behalf of our customers (the Account Owners). The Account Owner who provides your course or training is the Data Fiduciary (Controller) for your personal data. Please refer to their privacy policy for information about how they handle your data.
3. When Skolarli processes personal data on behalf of Account Owners, we do so only as instructed by them and in accordance with this Privacy Policy and our Terms of Service.

Services to Minors

1. We only do business with adults. We do not knowingly engage in business with minors (persons under 18 years of age).
2. You may only use the skolar.li application with the guidance of your parents or legal guardian if you are not of legal age to do business in your country of residence.
3. If we become aware that we have collected or received personal information from a minor on our website or web application without parental consent, we will delete that information promptly.
4. If you believe we might have any information from or about a child under 18, please contact us at [email protected].

Personal Information We Collect

In order to provide the Services, we collect certain information from our customers. Here is a summary of the information we collect and what we do with it:

1. Account Information: We collect your name, email address, and IP address. We need this information to provide you with the Services, confirm your identity, and contact you.
2. Voluntary Information: You may voluntarily provide additional information regarding your registered account, such as profile details, API keys, or images and videos you choose to upload.
3. Usage Data: We collect data on how you interact with websites hosted by skolar.li. We also collect data about how and when you access your account to provide you with access and continuously improve our Services.
4. Course Content: When you voluntarily share personal information with us in connection with your course delivery and use of our Services, we store that personal information.
5. Payment Information: When transactions between you and our website involve payment by credit card, debit card, or third-party online payment services, we will collect transaction-related information as part of our business dealings with you, including billing address, phone number, and other transaction information.
   Note Full payment card details are processed by our payment providers and are not stored on our servers.
6. Learner Information: When you share personal information about your customers ("learners"), we store this information for you so you can handle registrations and better serve your customers.

Customers' Students & Subscribers

To provide our Services to you, we collect and store information about your students so that you and they can benefit from our Services, such as delivering courses, using AI to review course contents, and analyzing course engagement.

1. We allow you to collect the names, email addresses, and other personal information of your customers. A name and email address are required to allow individuals to access our Services for processes such as registration, authentication, or course administration.
2. We collect information about how your students interact with your courses and website, including but not limited to course progress, test results, survey results, discussion contributions, forum posts, and other student activities.
3. You may collect additional information about your learners as part of your course management process. As the course administrator, it is your responsibility to ensure that the information is collected legally. You should provide your own privacy policy to your students.
4. Skolar.li processes this information through the skolar.li platform to administer the Services. You have the option to access and delete your learners' information at any time. Skolar.li may retain a copy of learners' information to comply with legal or regulatory obligations.
5. Certain transactions between learners and our website or your courses may involve payment by credit card, debit card, or third-party online payment services. In such transactions, we will collect transaction-related information.
6. We may also receive personal information from our partners and third parties.
7. If skolar.li customers choose to use third-party tools or integrations as part of their use of our Services, these third-party tools may collect personal information on their own terms. Skolar.li has no control over third-party tools or integrations.

Website Visitors and Support Users

1. We collect information from people who visit the skolar.li website, including your IP address and how you interact with our website. We also collect information such as the date of your visit, the website you visited before visiting us, the website you visit when leaving our website, the operating system of your computer, location data, and the type of web browser you use.
2. We collect personal information that you submit through any messaging or email functionality available on any of our websites.
3. We may receive personal information when you submit a help ticket or make other requests to skolar.li through one of our websites.
4. We collect names, phone numbers, and voicemail messages from users who contact our helpline.
5. For all people who email us for help, we collect your name, email address, location, skolar.li website address, and any communication with a skolar.li support agent.
6. If you use our forums or communities, we collect your name and any content you upload.

Legal Basis for Processing

We process your personal data based on the following legal grounds:

1. Contract Performance: Processing is necessary to provide you with the Services you have requested and to fulfill our contractual obligations to you.
2. Consent: By using our Services, you consent to the collection and processing of your personal data as described in this Privacy Policy. For certain processing activities (such as marketing communications for B2C customers), we rely on your explicit consent.
3. Legitimate Interests: We may process your data for our legitimate business interests, such as improving our Services, preventing fraud, and ensuring security, provided these interests do not override your fundamental rights.
4. Legal Obligations: We may process your data to comply with applicable laws, regulations, and legal processes.

AI and Automated Processing

Skolarli uses artificial intelligence (AI) technologies to enhance our Services.

1. Course Content Review: We may use AI tools to review, analyze, and provide suggestions for your course content to help improve quality and engagement.
2. Analytics and Insights: AI may be used to analyze learner behavior and provide insights to help you optimize your courses.
3. AI Service Providers: We use third-party AI services including OpenAI (ChatGPT), Anthropic (Claude), Google (Gemini), Perplexity, and our own in-house models to provide these features.
4. Data Not Used for Training: Your personal data and content are NOT used to train AI models. AI tools process your data solely to provide the requested features and services.
5. Human Oversight: AI-generated suggestions and analyses are provided as recommendations. Final decisions regarding content and courses remain with you.

Cookies and Tracking Technologies

We use cookies and similar tracking technologies on our websites and applications.

1. Essential Cookies: These cookies are necessary for the website to function and cannot be switched off. They are usually set in response to actions made by you, such as setting your privacy preferences, logging in, or filling in forms.
2. Analytics Cookies: We use analytics services including Google Analytics, Mixpanel, Microsoft Clarity, and Sentry to understand how visitors interact with our website. These tools help us improve our Services by collecting and reporting information anonymously.
3. Session Tracking: Cookies may be used to track your session on our website and personalize your experience.
4. Managing Cookies: Most web browsers allow you to control cookies through their settings. You can set your browser to refuse cookies or delete certain cookies. However, if you block or delete cookies, some features of our Services may not function properly.
5. Third-Party Cookies: Some cookies may be placed by third-party services that appear on our pages. We do not control these third-party cookies and recommend reviewing their respective privacy policies.

Data Sharing and Third Parties

We share your personal data with the following categories of third parties to provide and improve our Services:

1. Cloud Hosting: Amazon Web Services (AWS) — Our application and data are hosted on AWS servers located in Mumbai, India.
2. Content Delivery and Security: Cloudflare — We use Cloudflare for content delivery network (CDN) services, DDoS protection, and video streaming (Cloudflare Stream).
3. Video Hosting: Vimeo — We use Vimeo to host and stream video content.
4. Payment Processing: Razorpay and PayPal — We use these payment processors to handle transactions. Your payment information is processed directly by these providers and is subject to their privacy policies.
5. Email Services: Brevo (formerly Sendinblue) — We use email service providers to send transactional and marketing communications.
6. Analytics: Google Analytics, Mixpanel, Microsoft Clarity, and Sentry — We use these services to analyze website usage and improve our Services.
7. AI Services: OpenAI, Anthropic, Google, Perplexity — We use AI services to provide content analysis and enhancement features.
8. Service Providers: We may share data with other service providers who assist us in operating our business and providing the Services.

We may also disclose your information: (a) to comply with legal obligations; (b) to protect and defend our rights or property; (c) to prevent fraud or illegal activity; (d) to protect the safety of our users or the public; or (e) with your consent.

Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected:

1. Active Accounts: We retain your personal data for as long as your account remains active.
2. Deleted Accounts: Upon account deletion, all personal data will be deleted within 30 days, unless retention is required for legal or regulatory purposes.
3. Learner Data: Learner activity and analytics data are retained for as long as the associated Account Owner's account remains active.
4. Payment and Transaction Records: We retain payment and transaction records as required by applicable tax and financial regulations in India (typically 7-8 years).
5. Support Communications: We may retain support tickets and communications for our records, analytics, and to improve our Services.
6. Backups: Data in backups will be deleted in accordance with our regular backup rotation schedule.

Assessment Data Retention

Skolarli's assessment platform generates additional data classes that are subject to specific retention rules:

1. Proctoring Snapshots: Webcam snapshots captured during proctored assessments are retained for 15 days by default, after which they are automatically purged from our systems. Customers may request extended retention in writing for compliance, audit, or dispute resolution purposes.
2. Audio Recordings: Continuous audio chunks recorded during assessments (where audio recording is enabled by the Account Owner) are retained for 15 days by default. Extended retention is available upon explicit written request from the customer.
3. Reference Photos: The reference photo captured during liveness verification at the start of an assessment is retained alongside the candidate's session record for the lifetime of the customer's account, unless explicit deletion is requested.
4. Candidate Dossiers & Results: Assessment results, scores, evaluator notes, AI-assisted summaries, and the final candidate dossier are retained for the lifetime of the customer's account, unless the customer explicitly requests deletion. These records are part of the auditable hiring trail and may be required for compliance review.
5. Violation Logs: Trust score violations, anti-cheat events, and the snapshots linked to them are retained alongside the dossier for as long as the dossier itself is retained.

Data Location and International Transfers

1. Primary Data Location: Your data is primarily stored on Amazon Web Services (AWS) servers located in Mumbai, India (ap-south-1 region).
2. International Transfers: Some of our third-party service providers (such as Cloudflare, payment processors, AI services, and analytics providers) may process data in locations outside India, including the United States and other countries. When your data is transferred internationally, we ensure appropriate safeguards are in place to protect your data in accordance with applicable data protection laws.
3. Compliance: We comply with applicable Indian laws regarding cross-border data transfers, including the provisions of the DPDP Act, 2023.

Your Rights

Under applicable data protection laws, including the DPDP Act, 2023, you have the following rights regarding your personal data:

1. Right to Access: You have the right to request a summary of your personal data that we process and information about how it is being used.
2. Right to Correction: You have the right to request correction of inaccurate or incomplete personal data.
3. Right to Erasure: You have the right to request deletion of your personal data. For Skolarli Akademy (B2C) users, you can delete your account directly within the application. For B2B users, account deletion depends on your organization's policies.
4. Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw your consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.
5. Right to Grievance Redressal: You have the right to lodge a complaint with our Grievance Officer or with the Data Protection Board of India if you believe your data protection rights have been violated.
6. Right to Nominate: Under the DPDP Act, you have the right to nominate another individual to exercise your rights in the event of your death or incapacity.

To exercise any of these rights, please contact us at [email protected].

Marketing Communications

1. We may send marketing and promotional emails to our B2C (Skolarli Akademy) customers about our products, services, events, and offers that may be of interest to you.
2. B2B customers (organizations and their users) do not receive marketing communications unless explicitly opted in.
3. Opt-Out: You can opt out of receiving marketing emails at any time by clicking the "unsubscribe" link at the bottom of any marketing email, or by contacting us at [email protected].
4. Please note that even if you opt out of marketing communications, we may still send you transactional emails related to your account and use of the Services (such as account notifications, password resets, and payment confirmations).

Securing Personal Information

Our web application is hosted on Amazon Web Services (AWS), a premier global cloud hosting service. We implement appropriate technical and organizational measures to protect your personal data, including:

1. Data encryption at rest using AES 256-bit encryption
2. Data encryption in transit using TLS 1.2 or greater
3. Web Application Firewalls (WAF) to protect against malicious internet traffic
4. DDoS protection through AWS Shield and Cloudflare
5. Access controls within the organization based on the principle of least privilege
6. Regular security audits and vulnerability assessments
7. Employee security training

For more details about our security practices, please refer to our Security Policy.

Usernames and Passwords

Every skolar.li user has a unique user ID which they use to log in to our application. No two users will share the same username. We enforce a strict policy on sharing of usernames and passwords. Should we learn that any Instructors, Trainers, or Coaches share usernames and passwords to create courses and deliver them, we shall terminate the account with immediate effect and may blacklist such users from using skolar.li in the future.

Information Modification & Correction

While most of your information is editable on the website, we do not allow modifications of some business-critical information for security and compliance purposes, such as GST numbers and Government Issued IDs. Should you need any of these to be corrected or deleted, please reach out to us at [email protected].

Terminating Your Account

At any given point, should you wish for your account and information to be deleted from our application:

1. Skolarli Akademy (B2C) Users: You can delete your account directly within the application. This will delete all your personally identifiable information (PII).
2. B2B Users: Account deletion depends on your organization's policies. Please contact your organization administrator or reach out to us.
3. Manual Request: You may also send an email to [email protected] and our team shall delete all of your information within 30 days and communicate the status to you.
4. Should you have backed up any of your data on our servers, those shall be deleted as well.

Changes to This Privacy Policy

1. We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors.
2. We will notify you of any material changes by posting the updated Privacy Policy on our website with a new "Last Updated" date.
3. For significant changes that materially affect your rights, we will send an email notification to the address associated with your account.
4. Your continued use of our Services after any changes to this Privacy Policy constitutes your acceptance of the updated policy.
5. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting your information.

Grievance Officer

In accordance with the Information Technology Act, 2000, and the DPDP Act, 2023, the contact details of the Grievance Officer are provided below:

Grievance Officer
Skolarli Edulabs Pvt. Ltd.
Email: [email protected]

If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, please contact our Grievance Officer. We will respond to your inquiry within 30 days.

If you are not satisfied with our response, you may lodge a complaint with the Data Protection Board of India as established under the DPDP Act, 2023.

Contact Information

If you have any questions about this Privacy Policy, please contact us: