The purpose of this Privacy Policy is to describe how Usha International Limited, including its subsidiaries, (“USHA”, “We”, “Us” or “Our”) collects, uses and shares information about You, the User, through Our online interfaces including but not limited to use of www.studiooffashionandcraft.com (referred to herein as the “Website”) or any mode of registration or usage of Products or Services as defined in the Terms of Use, including through SD Cards, tablets, Laptops and/or storage / transmitting device, including at USHA’s Physical Centres or events hosted by USHA. We understand the importance of protecting User's (“You” or “Your”) privacy. We are committed to safeguarding the privacy of the personal data or information ("Personal Data") that We collect, possess, use, process, record, store, transfer, disclose, deal, handle and receive from You while rendering services in connection with Our Website and businesses. This Privacy Policy, which along with various guidelines, sets out how We intend to safeguard such Personal Data received and used by Us, in compliance with the prevailing Information Technology Act, 2000 ("IT Act") and Digital Personal Data Protection Act, 2023 and the respective applicable rules made thereunder.

By visiting this Website You agree to be bound by the terms and conditions of and give Your consent to this Privacy Policy. If You do not agree please do not use or access Our Website. By mere use of the Website, You expressly consent to disclose Your Personal Data in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to the Terms of Use.

SCOPE AND APPLICABILITY OF THIS POLICY

This Privacy Policy applies to UIL, its affiliates and its subsidiary companies, its employees, staff and team members who collect, use, process, store, transfer, handle and receive, Personal Data from You, and third parties in India, including but not limited to any consultants, contractors, advisors, accountants, agents, person, representatives of UIL and/or service providers etc who provide services to or on UIL's behalf in connection with its business ("Third Party"). This Policy summarizes what type of Personal Data (as defined hereinafter) We collect about You, purpose of collection, storage and usage of such Personal Data, to whom such Personal Data may be disclosed/transferred and how We protect Your privacy.

TYPES OF PERSONAL DATA OR INFORMATION WE COLLECT

The terms, personal data or information in this Privacy Policy refers to personal data which identifies You and/or is capable of identifying You as an individual and which we collect from You through Our Website. Some of Our Website’s functionality can be used without revealing any Personal Data, but for features or Services being subscribed by You and related to the Content Offerings as defined in Our “Terms of Use”, Personal Data is required. The types of Data that We may collect consist of following personal information relating to You:

• Information relating to your use of the Website: When users visit Our Website, We may track, collect and aggregate information indicating, which pages of Our Website were visited and which hyperlinks were clicked amongst other activity on the Website. We may also collect information from the URLs from which you are linked to Our Website, including information such as IP address, operating system and browser software used, details of Your interactions with customer service, such as the date, time and reason for contacting Us, transcripts of any chat conversations
• Personal Data provided directly by You: We collect Personal Data that you provide to us when You register for an account, update or change information for Your account, purchase or use of Our products or Services, complete a survey, sign-up for email updates, participate in Our public forums, send us email messages, and/or participate in Content Offerings or other Services on Our Website. Such personal data may include Your Name, Address, E-mail address, Mobile Number, IP Address, Bank a/c details, display picture, geographic location etc. In order to check and verify your identity, You may have to provide information viz. your date of birth, or official identification documents, such as Passport/ Aadhaar data/ Voter ID details; If You participate in a Content Offering, We may collect certain user-generated content, such as assignments submitted by the User. We also collect course data, such as responses to in-video quizzes, standalone quizzes, exams, and surveys. We may use the Personal Data that you provide to respond to Your queries, to provide You the specific Content Offering and/or Services You select, send You updates about Content Offerings or other USHA events, and send You email messages about Website maintenance or updates
• Third Party Payment Processing: USHA provides You with the ability to pay for Content Offerings and other Services using a credit card, debit card, UPI or other methods through a third party payment processing service provider. Please note that the payment gateway is provided by RazorPay and not by USHA. Razorpay may collect and process your financial information independently. Our third party payment processing service providers may use your financial information in accordance with their privacy policy, which is available at https://razorpay.com/privacy/. We do not have access to this data unless requested by Us. We understand that all payment transactions are processed through secure payment gateway providers. We do not store any card information (other than the last 4 digits of your card) in Our servers.

You are solely responsible for ensuring the accuracy of the Personal Data you submit to USHA. Inaccurate information may affect Your ability to use the Website, the information you receive when using the Website or availing Services, and Our ability to contact you. Provided that any Personal Data that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as Personal Data for the purposes of this Policy

HOW WE USE DATA COLLECTED FROM USERS

USHA collects and uses Personal Data and may be required to share Personal Data with third parties for the purposes provided hereunder.

• To provide Services: We use the Personal Data you provide to facilitate your access to and use of the Website, and to deliver the information, products, or Services you request from us. We use your Personal Data, and may share it with authorized third-party service providers, to facilitate and personalize your experience with various features of the Website, including grading functionalities, customized recommendations, and learner engagement tools. These features may leverage technologies such as machine learning and artificial intelligence to enhance their effectiveness and relevance. We engage third-party service providers to support USHA’s operations, including the purposes outlined in this Privacy Notice. These Contractors may access Personal Data only as needed to deliver services such as technology support, content delivery, and website maintenance.
• To provide technical support: We may use your Personal Data to provide you with technical support when needed or requested by You and to maintain the security and integrity of our Services and the Website. When you contact Us via email or through other communication channels, We, along with our authorized third-party service providers, may record and use the information you provide to respond to your inquiry and for other purposes outlined in this Privacy Policy. Additionally, when we send you emails, we may track your interactions with such communications, including whether you open the email or click on any embedded links, to help us improve our services and communication strategies.
• To provide updates: We use the Personal Data collected when you subscribe to our email or update services so we may send to you communications related to the Website and Content Offerings. We may also store this information and use it for future correspondence, where permitted by applicable law.
• To improve and upgrade the Website and Services: We use Personal Data, including by sharing it with authorized third-party service providers, to monitor, record, and analyse how users engage with the Website, its features, content, and our Services. This analysis may involve the use of advanced technologies, including machine learning and artificial intelligence tools, to enhance user experience and improve the effectiveness of our Services.
• To monitor your participation in the Services: We use the Personal Data collected from you during your participation in a Content Offering on the Website for various processing purposes, including, but not limited to, tracking your attendance, progress, and completion status. We may also share your Personal Data, including your performance and engagement metrics, with the instructor(s) delivering the Content Offering, teaching assistants, or other individuals authorized by the instructor(s) to support the development, delivery, or administration of the Content Offering, as well as with the affiliated Content Provider(s).
• To send marketing materials relevant to you: We use Personal Data to deliver and tailor marketing communications and advertising, to inform and refine our marketing strategies and content, to gain deeper insights into our audience, and to personalize promotional efforts to ensure greater relevance for specific user segments. For these purposes, we may share Personal Data with third-party service providers and technology platforms. This may include, for example, the use of advertising services provided by Meta and other similar platforms.
• To Comply with Legal Obligations and Protect Rights: USHA may disclose your Personal Data to government authorities, including regulatory agencies, law enforcement, and national security organizations, as well as external advisors and other relevant third parties when required by court orders, legal processes, or applicable laws. Such disclosures may also be made to investigate, prevent, or address illegal or suspected illegal activities, and to protect or defend the rights, property, safety, or legal interests of USHA, the Website, our users, customers, or others. We reserve the right to assert or waive any legal rights or objections available to us in these matters.

DATA COLLECTION DEVICES

In addition to Personal Data, We may use data collection devices such as "cookies" or other technology to obtain certain types of information when Your web browser accesses Our Website. Cookies are small files containing a string of characters to identify Your browser. Cookies allow the Website to remember important data or information that will make Your visit to the Website more useful. We use various types of cookies and related technologies, of different types, on the Website:

• Essential cookies and related technologies. Necessary for the operation of the Website. We may use essential cookies to authenticate users, prevent fraudulent use of user accounts, or offer Website features.
• Analytical/performance cookies and related technologies. Allow us to recognize and count the number of visitors and see how visitors move around the Website when using it. This helps us improve the way the Website works.
• Functionality cookies and related technologies. Used to recognize you when you return to the Website. This enables us to personalize our content for you (for example, your choice of language or region).
• Targeting cookies and related technologies. Record your visit to the Website, the pages you have visited, and the links you have followed. We will use this information to make the Website and the content more relevant to your interests. We may also share this information with third parties for this purpose.

If you'd like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser. Please note, however, that if you delete, reject, or refuse to accept cookies and related technologies, you might not be able to use some or all of the features We offer. You may not be able to log in, store your preferences, and some of our pages might not display properly. We will make best efforts to do so but do not warrant that Our Website is free of any operational errors nor do We warrant that Our Website will be free of any virus, computer contaminant, worm, or other harmful components. You acknowledge that Our Website, its services and contents are provided on an "as is" and "as available" basis, without warranties of any kind, either express or implied. We expressly disclaims that any service will be uninterrupted, timely, secure or error-free for any reasons whatsoever including but not limited to overload / breakdown of receiving network, servers or applications; system failures out of Our control or due to heavy traffic on network.

DISCLOSURES OR TRANSFER OF YOUR PERSONAL DATA

We will disclose or transfer Your Personal Data in accordance with this Policy and all applicable legal requirements. Your Personal Data will be disclosed or transferred, as may be required from time to time, as follows:

• For Business Purposes: to (i) the appropriate employees/staff/persons in Our offices; (ii) Our affiliates and associate companies; (iii) to Our different offices within India and outside India in accordance with the IT Act; (iv) to any Third Party, in the event of a proposed or actual business transfer; and (v) in connection with Our business and services provided by Us.
• For Centralized Data Processing Activities: We have centralized certain aspects of Our data processing and administration in order to allow Us to manage Our business in better ways. Such centralization may result in the transfer of Your Personal Data: (i) from one country to another; (ii) to Our employees/staff of the affiliates/associate companies of UIL in other locations etc. However, whenever Your Personal Data is transferred within UIL, it will be processed in accordance with the terms and conditions of this Policy.

SECURITY PRECAUTIONS

We have in Our Website, stringent security measures in place to protect the loss, misuse, and alteration of the information under Our control. Whenever You change or access Your account information, We offer the use of a secure server. Once Your information is in our possession We adhere to strict security guidelines, protecting it against unauthorized access. We take appropriate security measures to protect Your Personal Data against unauthorized access, alteration, disclosure or destruction. We limit access to Your Personal Data to members of Our team/Our employees /Third Party who We believe reasonably need to come into contact with that information for the purpose of performing their duties. We have strict confidentiality obligations that apply to such members/Our employees /Third Party.

RETENTION OF YOUR PERSONAL DATA

We are aware of the importance of timely destruction of Personal Data. We ensure that Your Personal Data is not stored/retained for a longer period than necessary for the purpose for which it was collected, used or processed or as provided in Our contracts except when there is a legal obligation to do so under any law. The length of time for which We retain any Personal Data depends on the purposes for which We collect and use such Personal Data and / or as required for compliance with applicable laws and to establish, exercise, or defend Our legal rights.

CONFIDENTIALITY & SECURITY OF PERSONAL DATA

We employ robust physical, technical, and organizational safeguards to protect your Personal Data from unauthorized access and disclosure. While we strive to keep your information secure, no method of transmission over the Internet or electronic storage is completely foolproof. As such, we cannot guarantee absolute security. Disclosure of your Personal Data to third parties will occur only as described in this Privacy Notice or in rare situations where it is necessary to prevent imminent harm, in compliance with the law. Protecting your account credentials is your responsibility, and you should exercise caution to keep them confidential. Please note that email is inherently vulnerable to interception and should not be used to transmit sensitive information.

UPDATING OR REVIEWING YOUR PERSONAL DATA OR INFORMATION / QUESTIONS OR COMPLAINTS

You can review the Personal Data provided by You any time. We will ensure that any change done by You in Your Personal Data shall be included as soon as possible. You have the right to withdraw the consent provided by you for collection of your personal data at any time by providing written notice to sfc_lmsadmin@usha.com. Upon such notice, your personal data will be deleted, unless its retention is required by law. You understand that withdrawing your consent may affect the services or support that you receive. You expressly state that Personal Data provided by You to Us is correct and complete in all respects and does not contain any false, distorted, manipulated, fraudulent or misleading facts. We expressly disclaim any liability arising out of the said data or Personal Data provided by You to Us. Further, You expressly agree that We are not responsible for the accuracy and authenticity of such data or information provided by You to Us and You agree to indemnify UIL for all losses incurred by UIL due to any false, distorted, manipulated, defamatory, libellous, vulgar, obscene, fraudulent or misleading facts made by You to UIL.

ENFORCEMENT RIGHTS

USHA and its affiliates will ensure that this Policy is observed. All USHA employees and employees of Third Parties who have access to Personal Data are required to comply with this Policy. All Third Parties shall only process the Personal Data in accordance with Our instructions or make decisions regarding such data or information as part of the delivery of their services. In either instance, We will select reliable Third Parties who undertake, by contract or other legally binding and permissible means, to put in place appropriate technical and organizational security measures to ensure an adequate level of protection of such data or information. We will require Third Parties to comply with this Policy or to guarantee the same levels of data protection that is adhered to by Us when handling/processing such data or information. Such selected Third Parties will have access to such data or information solely for the purposes of performing the services specified in the applicable service contract and are legally and contractually bound to maintain the privacy of such data or information shared with them and will not disclose it further. If We conclude that a Third Party is not complying with these obligations, We will promptly take appropriate actions to remedy such non-compliance or implement necessary sanction. Additionally, Our employees are bound by internal confidentiality policies. Any employee found to have violated this Policy or any other policies will be subject to disciplinary action, up to and including termination of employment and/or penalties under applicable laws. All Third Parties and USHA employees do hereby specifically agree that he/she/it shall, at all times, comply with the requirements of the IT Act, while collecting, receiving, possessing, using, processing, recording, storing, transferring, dealing, handling and disclosing Personal Data. The said Third Party and team members/employees/staff do further unequivocally declare that in case he/she/it violates any provisions of the IT Act, he/she/it shall alone be responsible for all his/her/its acts, deeds and things and that he/she/it alone shall be liable for civil and criminal liability there under or under any other law for the time being in force.

GRIEVANCE REDRESSAL

You may contact sfc_lmsadmin@usha.com for any questions or concerns related to the processing of your personal data or if you believe your account has been abused or hacked.

MODIFICATIONS TO THE POLICY

We reserve the right to update, change or modify this Policy, from time to time, without prior notification. This policy shall come into effect from the date of such update, change or modification. To make sure You are aware of any changes, please review this policy periodically. We will inform You regarding any such changes by updating and publishing this Policy on the Website. Effective with the implementation of this Policy, applicable USHA privacy guidelines or practices relating to the processing of Personal Data will be superseded by the terms of this Policy and modified accordingly. If any of the terms or definitions used in this Policy is ambiguous, the definitions established under the IT Act shall apply.

USE BY CHILDREN

As stated in out in the Terms of Use, You must meet the age requirements for registering and using Our Services. Persons who are minors (i.e. a child who has not completed the age of 18 (eighteen) years), un-discharged insolvents etc. are not eligible to register for the Services. As a minor if You wish to use Our Services, such use shall be made available to You by Your legal guardian or parents, who has agreed to the Terms of Use and this Privacy Policy. In the event a minor utilizes the Services, it is assumed that he/she has obtained the consent of the legal guardian, or parents and such use is made available by the legal guardian or parents. We will not be responsible for any consequence that arises as a result of misuse of any kind that may occur by virtue of any person including a minor registering for the Services provided. By using the Services, You warrant that all the data provided by You is accurate and complete and that the users using the Services has obtained the consent of their parent/legal guardian (in case of minors). We reserve the right to terminate Your access to the Services if it is discovered that You are under the age of 18 (eighteen) years and the consent to use the Services is not made by Your parent/legal guardian, or any information provided by You is inaccurate.

PRIVILEGED / EXCLUSIVE SERVICE

By having an USHA account, You have explicitly given consent for Us to capture images (followed by analysis), camera/mic permissions to make video calls and record the same.

YOUR CHOICES AND SELECTING YOUR PRIVACY PREFERENCES

We give you the choice of receiving a variety of information that complements our products. You can subscribe to receive certain product information like new models, upcoming products and Our general communications like offers, sale, discount or invitations to participate in market research or compliance reviews. We give you a choice regarding delivery of Our general communications by postal mail, email, telephone, or mobile device. Subscription communications include email newsletters, etc. that may be expressly requested by You or which You consented to receive. After You request such communications, You may opt out of receiving them by using one of the following methods: Select the email "opt out" or "unsubscribe" link, or follow the opt-out instructions included in each email subscription communication. To unsubscribe from messages delivered to mobile devices, reply to the message with the words "STOP" or "END." Be sure to provide Your name, relevant contact information, and specific relevant information about Our subscriptions that you no longer wish to receive. Please be aware that when You opt out of receiving certain subscription communications, it may affect the services You have chosen to receive from UIL where accepting the communications is a condition of receiving the services. This option does not apply to communications primarily for the purpose of administering order completion, contracts, support, product safety warnings or other administrative and transactional notices where the primary purpose of these communications is not promotional in nature.