Privacy Policy - Prose

CONFIDENTIAL DOCUMENT PRIVACY POLICY PRIVACY POLICY - PROSE Last updated : 09-03-2026 PIONEER EDUCATION TECH PRIVATE LIMITED ("Company", "we", "our", or "us") operates and manages the educational technology platform known as "Prose" including the Prose website and related digital services (collectively referred to as the "Platform"). The Company is committed to protecting the privacy and personal data of individuals who access or use the Platform and its services. This Privacy Policy explains how we collect, use, process, store and protect personal data when users access, register on, or use the Platform and the services available through it. This Privacy Policy applies to all users of the Platform and should be read together with the Terms of Service governing the use of the Platform. The Company processes personal data in accordance with applicable laws including the Digital Personal Data Protection Act, 2023 (DPDP Act), the Information Technology Act, 2000, and other applicable data protection laws in India. This Privacy Policy forms an integral part of the Terms of Service governing access to and use of the Platform. By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy. 1. SCOPE OF PRIVACY POLICY 1.1 This privacy policy applies to individuals who access or browse the platform, users who register for an account on the platform, and users who upload, input, generate or otherwise process content through the platform. 1.2 This Privacy Policy governs the collection, use, storage, disclosure and protection of personal data in connection with the use of the Platform and the services made available through it. 1.3 This Privacy Policy does not apply to third-party websites, services or platforms that may be linked to or integrated with the Platform, which shall be governed by the respective privacy policies of such third parties. 2. PERSONAL DATA WE COLLECT 2.1 When a User registers for an account on the Platform, the Company may collect personal data such as the User's name, email address, contact number, account login credentials and any other information voluntarily provided by the User during account creation or profile management. 2.2 The Platform enables Users to upload, submit, generate or otherwise process content through the Services. In the course of using the Platform, the Company may process personal data contained in materials submitted by Users, including documents, text inputs, educational or professional content, presentation materials, translation content and other materials uploaded or submitted through the Platform. Users remain responsible for ensuring that any personal data contained in such inputs is provided in compliance with applicable laws and with appropriate authorization where required. 2.3 The Platform may generate outputs based on information or materials submitted by Users. Such outputs may include documents, translations, presentations or other generated content produced through the Platform's tools or functionalities. To the extent that the User's inputs contain personal data, such personal data may also appear within the generated outputs. 2.4 Where Users subscribe to paid features or services available on the Platform, the Company may collect personal data relating to subscription selections, billing details and payment transaction information. Payment transactions on the Platform may be processed through third-party payment service providers in accordance with their respective policies. 2.5 When Users access or interact with the Platform, certain technical and usage-related information may be automatically collected. Such information may include internet protocol (IP) address, device information, browser type, system logs and data relating to the User's interaction with features and functionalities of the Platform. This information may be used for maintaining platform functionality, ensuring security and improving the Services. 3. SOURCE OF PERSONAL DATA 3.1 The Company may collect personal data that is voluntarily provided by Users when they create an account, use the Platform, upload or submit inputs, generate content through the Services, subscribe to paid features, communicate with the Company, or otherwise interact with the Platform. 3.2 The Company may collect personal data that is voluntarily provided by Users when they create an account, use the Platform, upload or submit inputs, generate content through the Services, subscribe to paid features, communicate with the Company, or otherwise interact with the Platform. 3.3 In limited circumstances, the Company may receive personal data from third-party service providers that support the operation of the Platform, including payment processors, analytics providers, hosting providers or other service partners engaged by the Company in connection with the Services. 4. PURPOSE OF DATA PROCESSING 4.1 Personal data may be processed for the purpose of creating and managing user accounts, enabling access to the Platform, providing the functionalities and tools available through the Services, and facilitating the processing of user inputs and the generation of outputs through the Platform. 4.2 Personal data may be used for administering the Platform, responding to user inquiries, providing technical support, managing user communications, and addressing service-related issues or requests submitted by Users. 4.3 Where Users subscribe to paid services or features, personal data may be processed for the purpose of managing subscriptions, processing payments, maintaining billing records and administering user access to subscription-based functionalities. 4.4 Personal data and usage information may be processed to maintain, improve and develop the Platform, monitor system performance, analyse usage patterns, and enhance the functionality and reliability of the Services. 4.5 Personal data may also be processed for purposes of maintaining the security and integrity of the Platform, preventing unauthorised access or misuse of the Services, enforcing the Terms of Service, and complying with applicable legal and regulatory obligations. 5. LEGAL BASIS FOR PROCESSING 5.1 Personal data may be processed on the basis of the User's consent, which is provided when the User registers on the Platform, submits information through the Platform, or otherwise voluntarily provides personal data for the purpose of accessing or using the Services. 5.2 Personal data may be processed where such processing is necessary for the performance of obligations arising under the Terms of Service governing the use of the Platform, including enabling access to the Platform, providing the functionalities of the Services, processing user inputs and generating outputs through the Platform. 5.3 The Company may process personal data where such processing is necessary to comply with applicable laws, regulatory requirements, court orders or lawful requests from governmental or regulatory authorities. 5.4 Personal data may also be processed for legitimate operational purposes connected with the functioning of the Platform, including maintaining system security, preventing fraud or misuse of the Services, improving platform functionality and ensuring compliance with the Terms of Service. 6. COOKIES 6.1 The Platform may use limited technical mechanisms such as session identifiers, system logs or similar technologies that are necessary for the functioning and security of the Platform. 6.2 Such technologies may be used for purposes including maintaining user sessions, enabling secure access to user accounts, managing platform functionality and ensuring the proper operation of the Services. 6.3 If the Company introduces additional cookies or tracking technologies in the future for analytics, functionality or service improvement purposes, such use shall be disclosed through an updated Privacy Policy. 7. DATA SECURITY MEASURES 7.1 The Company maintains appropriate administrative, technical and physical safeguards designed to protect personal data. Such safeguards may include controlled access to systems and data, secure infrastructure, monitoring of platform activity and other security practices intended to protect the integrity and confidentiality of personal data processed through the Platform. 7.2 Access to personal data is restricted to authorised personnel, service providers or contractors who require such access for the purpose of operating, maintaining or supporting the Platform and the Services, and who are subject to appropriate confidentiality obligations. 7.3 While the Company undertakes reasonable efforts to safeguard personal data, no method of transmission over the internet or method of electronic storage is completely secure. Accordingly, the Company cannot guarantee absolute security of personal data processed through the Platform. 8. DATA RETENTION 8.1 Personal data may be retained for the duration of a User's account or for as long as required to provide the Services available on the Platform, including the processing of user inputs and the generation of outputs. 8.2 The Company may retain certain personal data for a longer period where necessary to comply with legal or regulatory obligations, resolve disputes, enforce contractual rights, maintain security records, or prevent fraud or misuse of the Platform. 8.3 Where personal data is no longer required for the purposes for which it was collected or processed, the Company may delete, anonymise or otherwise securely dispose of such data in accordance with applicable laws and internal data management practices. 9. THIRD PARTY SERVICES 9.1 The Company may engage third-party service providers to perform functions on its behalf in connection with the operation of the Platform, including services such as payment processing, cloud hosting, technical infrastructure, analytics or other operational support services. In the course of providing such services, these third parties may have limited access to personal data solely to the extent necessary to perform their functions. 9.2 The Platform may contain links to or integrations with websites, tools or services operated by third parties. Such third-party services operate independently of the Company and are governed by their own terms, privacy policies and data handling practices. 9.3 The Company does not control and shall not be responsible for the privacy practices, security standards or content of third-party services. Users are encouraged to review the privacy policies and terms of such third parties before providing personal data to them. 10. CHILDREN PRIVACY 10.1 The Platform may be accessed and used by individuals under the supervision of parents, legal guardians or educational institutions. The Company recognises the importance of protecting the personal data of children and processes such data in accordance with applicable laws. 10.2 Parents or legal guardians are responsible for supervising the minor's use of the Platform and for ensuring that any personal data provided in relation to the minor is submitted with appropriate authorisation and in compliance with applicable laws. 10.3 The Company shall take reasonable measures to ensure that personal data relating to minors is handled with appropriate care and used only to the extent necessary for providing the Services available on the Platform. 11. USER RIGHTS 11.1 Users may have the right to request information regarding the personal data processed by the Company, including the nature of such personal data and the purposes for which it is being processed. 11.2 Users may request correction of inaccurate or incomplete personal data or request deletion of personal data where such data is no longer necessary for the purposes for which it was collected or processed, subject to applicable legal requirements. 11.3 Where the processing of personal data is based on the User's consent, the User may withdraw such consent at any time. Withdrawal of consent may affect the User's ability to continue accessing certain features or services on the Platform. 11.4 Users may raise complaints or concerns regarding the processing of their personal data by contacting the Company through the contact details provided in this Privacy Policy. The Company shall make reasonable efforts to address such grievances in accordance with applicable laws. 12. CHANGES TO THIS PRIVACY POLICY The Company may update or revise this Privacy Policy from time to time to reflect changes in the Platform, applicable laws or data processing practices. Any updated version shall be published on the Platform and shall become effective upon publication unless otherwise stated. 13. CONTACT If Users have any questions, concerns or requests relating to this Privacy Policy or the processing of personal data, they may contact the Company using the details provided below. PIONEER EDUCATION TECH PRIVATE LIMITED A-19, FIEE Complex, Okhla Phase 2 Okhla Industrial Estate New Delhi - 110020, India Email: contact@pioneereducationtech.com The Company shall make reasonable efforts to review and respond to queries or concerns relating to personal data or privacy within a reasonable time in accordance with applicable laws. This Privacy Policy shall be read together with the Terms of Service governing the use of the Platform, and both documents collectively regulate the relationship between the Company and Users with respect to the use of the Platform and the processing of personal data.