Subodha Privacy Policy

Subodha is the Accessible Learning Management System for the benefit of children with visual impairment and their teachers across India. Subodha is an initiative of Vision Empower – A registered Trust. Users of Subodha can access content for learning on the web at https://subodha-lms.visionempowertrust.org/ and the Subodha mobile application.

The privacy and protection of data of Subodha’s Users is of utmost importance and shall be ensured at all times. This Privacy Policy shall cover details of data protection and management on Subodha, including how personal data of users of Subodha is managed, used and processed. Users are individuals who access and use Subodha and broadly comprise (i) children with visual impairment who access and use Subodha after registering themselves with Vision Empower (“Registered Users”), (ii) persons with visual impairment who access and use Subodha after registering themselves with Vision Empower (“Registered Users”), (iii) teachers, teaching children with visual impairment who access and use Subodha after registering themselves with Vision Empower (“Registered Users”) and (iv) users who are registered with Vision Empower and are authorised to be administrators on behalf of Institutional Users (such as Special Schools for the Blind, Inclusive Schools, etc.) (“Administrators”). More details on the rights and responsibilities of Registered Users and Administrators are set out in the Term of Use.

By accessing and using Subodha, and by providing your information with Vision Empower, you consent to the collection and use of the information you disclose on Subodha by Vision Empower and relevant Administrators of Subodha in accordance with the policies and guidelines of Subodha as applicable from time to time, including the Terms of Use and this Privacy Policy. If you do not agree with the contents of this policy, please do not access or use Subodha.

This Privacy Policy should be read in conjunction with the Terms of Use. Defined terms used but not defined herein shall have the meaning ascribed to them in theTerms of Use.

1. Rights of Registered Users:

Right to fair, transparent and lawful collection of your data and information on Subodha
Right to be informed about the ways in which your data and information that is collected on Subodha will be understand
Right to receive all the information you need to provide informed consent before collection of your personally identifiable information or sensitive personal data or information on Subodha and sharing of the same with relevant Administrators
Right to revoke such consent
Right to privacy and confidentiality regarding your personal data and information
Right to proper use of your personal data and information by Administrators for specified and legitimate purposes related to your use of Subodha
Right to keep your personal information accurate and up to date
Right to secure collection, handling and storage of your personal data and information
Right to protection from unauthorised or unlawful use of your personal data and information
Right to view and access Subodha’s privacy policy

2. Responsibilities of Administrators with respect to Registered User data and information

To respect the privacy and data protection rights of Registered Users
ensure the security of and use of data (especially any personal information) shared by Registered Users is limited solely to the uses and purposes mentioned here
To know that any use of data for purposes outside of the proper use shall be considered violation of the terms of the policies of Subodha as well as applicable laws and policies of India and they shall be responsible and liable for such actions and for any loss or damage arising from failure to comply with this obligation
To ensure their communication (if any) with Registered Users is explicitly limited and relevant to the purpose of their usage of Subodha e. To ensure that their Content and programs on Subodha are not used for any of the Prohibited Uses set out in the Terms of Use

3. What User data and information is collected on Subodha?

All Registered Users can expect the following data and information of theirs to be collected by Vision Empower or on Subodha:
1. Basic Information: Name, Email Address/Mobile Number, User Type (eg. teacher, student, other) and Subodha Password
2. Geographical Information: State and District
3. Preferences: Board of interest, Medium of instruction, Classes of interest, Subjects of interest
4. Subodha Usage: Usage history, time spent on Content, Content created/ contributed / published and its usage, progress in trackable collections of Content (eg. courses), scores & assessment results, question-wise answers and other telemetry data in relation to usage of Subodha, badges generated, certificates issued.
5. IP Address: The IP address of a User is collected once for the limited purpose of determining your approximate location - the State, City and District of origin. The IP address is not stored in the database of Registered Users and the precise location of any Registered User cannot be determined. The User can confirm or modify the State and District details determined on the basis of the IP address.
No other personally identifiable information or sensitive personal data or information of the Registered User is collected.
All Registered Users (using the Subodha mobile app/website to access Subodha) have a profile which specifies the User type and Geographical Information and Preferences. They may choose to customise their profile by changing these details at any time as well as providing their name. Only Registered Users can view their profile on both the Subodha mobile app as well as the Subodha web portal, and their profiles specify all the additional information provided by such a Registered User.
Children as Registered Users: Vision Empower collects the ‘year of birth’ of a Registered User in order to determine whether a User is below 18 years. In the event a person under 18 years of age is registering with Vision Empower, Vision Empower prompts the User to provide the email address or mobile number of a parent / guardian for the purposes of registration. Children under 18 years of age are neither required to nor encouraged to provide their personal information.
You represent to us that the data and information you provide to Vision Empower for registering on Subodha from time to time is and shall be correct, current and updated and you have all the rights, permissions and consents to provide such data and information. Your providing the information or data and the consequent storage, collection, usage, transfer, access or processing of the same in accordance with the Terms of Use and this Privacy Policy shall not be in violation of any third party agreement, laws, charter documents, judgments, orders and decrees.

4. How is Registered User data and information collected?

Basic Information, Geographical Information and Preferences are collected when a User registers with Vision Empower for the first time. These details can be updated by the User from their profile.
Usage data of Registered Users is collected as and when a Registered User accesses, uses and navigates Subodha.
The additional information provided by Registered Users, namely, Password, is collected when a Registered User logs in to Subodha for the first time to update the password created by Vision Empower at the time of registration or when a Registered User updates their profile.
Declared Information of Registered Users is collected with their explicit consent when they choose to provide the same on Subodha, through their profile or otherwise.

5. Who has access to User data and information?

Subodha Usage data (including Usage across the States and Districts) is a part of anonymised and aggregated data sets that is accessible to relevant Administrators of Subodha and to the employees, contractors or subcontractors of the technology service providers of Subodha.
If you are a Registered User, your Basic Information, Geographical Information, Preferences, and Usage data is accessible to the employees, contractors or subcontractors of the technology service providers of Subodha(under strict confidentiality obligations) if they need to access the data to process it on behalf of Vision Empower or an Administrator or to provide the services available on Subodha.
Registered Users have an option to explicitly consent to give relevant Administrators access to their Name, Basic Information, Preferences, Usage data, and Declared Information for specified purposes such as implementation of programs on Subodha like courses. Note that Institutional Users are required to ensure that their respective Administrators comply with and Administrators are responsible to comply with the relevant policies and guidelines of Subodha as applicable from time to time, including the Terms of Use and this Privacy Policy.
To provide and improve Subodha, a limited number of third-party services require access to some of your personal data and information, eg. OpenEdx, Google PlayStore, AppStore. Third party services are contractually prohibited from using your information except to provide the service.
Your data and information are only accessible outside of the Subodha platform when it is necessary to offer the service, comply with law, or with your permission.

6. What is User data and information used for?

Subodha processes your data and information when necessary for providing access to Content for educational purposes and running programs on Subodha. These purposes are legitimate. The uses of your data are set out below:
1. To create a profile for you to have a customised experience on Subodha,
2. To suggest relevant Content for you to conveniently discover Content based on your preferences, activities on Subodha, and Content you are viewing on Subodha;
3. To enable you to access and use Content on Subodha;
4. To enable you to participate in programs run by Institutional Users on Subodha;
5. To provide you push notifications on your hand-held devices, only if you have provided permission for the same during app installation;
6. To track your progress in collections of Content for which progress is tracked / recorded such as courses, textbooks;
7. To generate badges for or issue certificates to you upon completion of milestones;
8. To maintain records of your progress and certificates/badges in relation to collections of Content you have accessed and used;
9. To measure interest in the offerings on Subodha and to improve Subodha over time;
10. To track and analyse usage of Content on Subodha by Administrators and Content providers to improve Subodha and its offerings over time;
11. To contact you and deliver information, administrative notices, seek feedback or other communications in connection with your usage of Subodha. By accepting the Terms of Use including the Privacy Policy, you expressly agree to receive this information;
12. To suggest details for your profile such as your declared State and District;
13. To resolve disputes, troubleshoot problems, detect and protect you against fraud and other criminal activity, enforce the Terms of Use and any other agreements;
14. At times multiple users may be looked at to identify problems or resolve disputes, and in particular may examine your information or data to identify users using multiple User IDs or aliases. Your information or data may be compared or reviewed for errors, omissions and for accuracy; and
15. For any other use that may be described to you at the time of collection.
The technology support providers of Subodha may use third parties as service providers to facilitate or outsource one or more aspects of service operations that are provided on Subodha (e.g., search technology, discussion boards, technical service providers, affiliate) and therefore some of your information or data may be provided directly to these service providers. These service providers are subject to confidentiality and other legal restrictions that prohibit their use of the information provided to them for any purpose other than to facilitate specific website related operations.
If we wish to use your data and information for a new purpose, not covered by this Privacy Policy, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing, unless authorized by law.
In any event, your data will not be used for any of the following purposes:
1. Rent or sale or other commercial purposes;
2. Advertising or marketing;
3. Phone calls or other forms of unsolicited communication that is not related to your usage of Subodha;
4. Building a personal profile, other than for educational purposes on Subodha;
5. Any of the Prohibited Purposes set out in the Terms of Use; and
6. Any purpose that is not disclosed in this policy or on Subodha.
Administrators are responsible for any use of data and information outside the proper use and shall be held accountable for the violation of the terms and policies of Subodha, as well as applicable laws and policies of India for any misuse. Administrators shall be liable for such actions and for any loss or damage arising from failure to comply with the obligation of proper use of your data and information. Should you believe that your data or information is being used in a manner inconsistent with this Privacy Policy, please contact the Subodha support team with the details of your concern by sending an email to visionempowersubodha@gmail.com.
As a Registered User, you understand, agree and acknowledge that the collection, storage and processing of your information or data on Subodha is for a lawful purpose connected with a function or activity of Subodha. You further understand, agree and acknowledge that your information or data which is classified as personal information as per applicable laws is considered necessary for us to provide various services on and in relation to Subodha to you and for your usage of Subodha.

7. How is User data and information stored?

Reasonable and appropriate security practices and procedures are being adopted to secure your personal data and information in accordance with Indian laws currently in force, including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. These measures include administrative, physical security, and technical controls in order to safeguard your personal data and information.
Your data, including your Declared Information, any personally identifiable information or sensitive personal data or information is securely stored using Microsoft Azure cloud services which have it’s servers in India. Your data and information will primarily be stored in electronic form however certain data may also be stored in physical form.
Third party service providers are engaged to store and process your data. These service providers are contractually bound to follow reasonable security standards to safeguard your data.
Your email address and mobile number and any other personally identifiable information is only collected should you choose to provide the same and it is encrypted and stored securely. Personally identifiable information is only shared with Administrators for purposes specified to you, with your explicit consent and under the obligation that the Administrators will use such information only in connection with your usage of Subodha.
Your IP address is only collected once for the limited purpose of ascertaining and suggesting your State and District. Your IP address is not stored on Subodha at any time.
Additionally, a variety of methods such as network and infrastructure security, encryption and manual security procedures are used to secure your information and data against loss or damage and to help protect the accuracy and security of your personal information / general information / usage data and to prevent unauthorized access or improper use. If you think that Subodha or any of your personal information / general information / usage data is not secure or that there has been unauthorized access to the Subodha account or your personal data, please contact visionempowersubodha@gmail.com immediately.
Although Subodha strives to protect your personal information and data, it cannot guarantee the security of your data while it is being transmitted to its site; any transmission is at your own risk. Once your information has been received, reasonable procedures and security features are in place to reasonably endeavour to prevent unauthorized access in accordance with Indian law.

8. How long is User data and information stored?

Your data will not be retained for a period more than necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required by law or for directly related legitimate purposes.

9. What are the system permissions required by the Subodha?

Microphone - Your system Microphone will be used if voice recording is explicitly requested as part of a Content for the purposes of practice. This voice recording is only stored locally on your system. Your system Microphone will be used if a Registered User creating Content wants to add a voice recording to Content. This voice recording will become part of the Content.
Camera - Your system Camera will only be used if you want to scan QR codes to access Content on Subodha.
Access to file manager / files - This is used by the Subodha android / iOS applications (as may be applicable) to transfer Content to an external storage space. Additionally, on the Subodha desktop app, this is used to transfer Content to and from an external storage device like a pendrive or SD card.

10. Cookies: How are they used? What types of cookies are used? How to manage your cookies?

Only the Subodha web portal uses cookies. Subodha only uses session cookies, none of the other types of cookies. Subodha session cookies are used to store URLs in order to better redirect users to the right pages. For example, when a User signs-in to Subodha from the courses page, they'll need to be redirected back to the courses page at the end of sign-in for a cleaner user experience. Session cookies are also used to store whether to use the Content Delivery Network (CDN) to pull images, plugins and other assets that are shown on the user interface. This is to enable faster loading of the pages the User interacts with. No personal information, or user preferences are stored in cookies.
Registered Users can clear their cookies by going to their browser settings and clearing their browsing data (by specifically checking off the option to clear cookies). Doing so, does not impact their user experience on Subodha as usage of Subodha sets the cookies again. Registered Users can also choose to block cookies from the settings as well. Doing so, will mean that certain things on Subodha will not function properly. For eg., images/plugins may take a long time to load and the user will not be taken to the right pages after login.

11. Data and information Vision Empower is not responsible for

Vision Empower is not responsible for the privacy practices of other websites/plug-ins and registered users need to be aware of the data privacy practices of such sites/plug-ins should they choose to use these links.

12. Compliance with laws and law enforcement

The administrators and technology support providers of Subodha cooperate with governments and law enforcement agencies or any third party by any order under law for the time being in force to enforce and comply with the law. Any information about you will be disclosed to the government or law enforcement officials or private parties as, in the sole discretion of the administrators and technology support providers, if they believe necessary or appropriate to respond to claims and legal process, to protect their property and rights or a third party, to protect the safety of the public or any person, or to prevent or stop any illegal, unethical or legally actionable activity.
Your information or data may also be provided to various tax authorities upon any demand or request from them. You acknowledge that Subodha can be accessed from anywhere in the world and it will have users from all over the world and therefore governments, judiciaries or law enforcement authorities in various parts of the world may have or assume jurisdiction over Subodha and Subodha may be subject to the laws, rules, regulations and judgments of various countries, states, municipalities or provinces where it may not have a direct presence to store, process, collect, use or keep your information or data. You acknowledge that government or law enforcement authorities in the countries where your data or information is stored may have the right to decrypt, collect, monitor or access your data or information, which actions are completely out of the control of the administrators and technology support providers of Subodha. The administrators and technology support providers of Subodha do not take any responsibility for such actions.

13. Deleting your information

If you wish to have the information or data that you have provided deleted, you can always do so by sending an email request to visionempowersubodha@gmail.com. You may note that deletion of certain information or data may lead to cancellation of your registration with Subodha and your access to certain features of Subodha. You also agree and acknowledge that certain data or information cannot be deleted or may be prohibited to be deleted as required under any applicable law, law enforcement requests or under any judicial proceedings.

14. Changes to this Privacy Policy

Subodha reserves the right to modify this privacy statement at any time, so please review it frequently. If a material change is made to the practices regarding your personally identifiable information, you will be notified, by means of a notice on Subodha.

15. How to contact us?

If you have any queries, comments, or requests, please contact us by sending an email to visionempowersubodha@gmail.com.