Buddy's Gate App
Privacy Policy
Effective Date: 12th February 2025
This is the privacy policy ("Policy") of the Buddy's Gate App (hereinafter collectively referred to as "App"). This App
is owned, operated and managed by Lighthouse Learning Private Limited (hereinafter referred to as "Company",
"We", "Us", "Our").
This Policy applies to all visitors, parents, lawful guardians and other persons whose data will be obtained
through the App (hereinafter referred to as the "User", "You", "Your"). Reference to User, You, or Your in this
Policy includes reference to yourself as well as the Child User (as defined below) whom you are Guardian (as
defined below) of, unless the context otherwise requires.
This Policy is published in English. In the event You require Us to share this Policy in any local language, You
may write to Us at developer@lighthouse-learning.com.
Please read Policy carefully to understand how We collect, use, store, retain, disclose and otherwise process
Your personal data in relation to the access and usage of the App. The Policy applies to all personal data
shared in digital form, or in non-digital form but subsequently digitized.
By giving Us Your data, You confirm to Us that:
- You have read the terms of this Policy which forms a legally binding and enforceable contract between You
and the Company. Such contract is formed when You provide Your consent by sharing the one time password
("OTP") which You will receive on Your registered mobile number;
- You are legally capable of entering into this contract and have formed a contract with Us out of Your own
free will. We will consider that Your consent is free, specific, informed, unconditional and unambiguous and
You are not disqualified from contracting by law;
- You have the ability and authority under applicable law to share Your personal data with us, and permit us
to use such data for the purposes mentioned in this Policy;
- You are, at all times, responsible for Your as well as Child User's usage and activities on the App.
If You have any questions related to how this Policy applies to the processing of Your personal data, please
write to Our Grievance Officer at developer@lighthouse-learning.com.
If You do not consent to the terms of this Policy, please do not share the OTP. If You wish to opt-out or
withdraw Your consent, We request You to refer to Clause 8 (Rights of the User) below and write to Us at
developer@lighthouse-learning.com.
Any and all consequences of Your withdrawal of consent resulting in, inter alia, any inability by Us to comply
with Our obligations viz-a-viz You, limitations, or deletion of Your personal data from Our records, will be
borne entirely by You.
1. Personal Data We Collect
- Personal data means any data about an individual who is identifiable by or in relation to such data.
- We collect, store and otherwise process personal data when You access or use the App. This data includes:
For the purpose of this Policy, "processing" of personal data means a wholly or partly automated operation or set
of operations performed on digital personal data, and includes operations such as collection, recording,
organisation, structuring, storage, adaptation, retrieval, use, alignment or combination, indexing, sharing,
disclosure by transmission, dissemination or otherwise making available, restriction, erasure or destruction.
- You are responsible to provide accurate, error-free and complete personal data. We shall not be liable for
any errors, inaccuracies, or incompleteness in the personal data provided by You, or any direct or indirect
consequences arising from such incorrect, inaccurate or incomplete personal data. If We find out that You
have provided false personal data, We shall be at liberty to restrict Your access to the App.
2. How We Collect Your Personal Data
Some of the ways in which We collect Your personal data are:
- Directly from You.
3. How We Process Your Personal Data
We may process personal data collected from You. The purposes include:
- Visitor Management: To track and manage visitor access at EuroKids preschools.
- Lead Management: Visitor details may be routed to our Lead Management System for sales follow-up and lead
nurturing.
- Communication: We may use your data to send updates, respond to inquiries, or provide notifications related
to your visit or interactions.
- Compliance: To meet legal requirements or protect our rights as outlined by applicable law.
- Sharing personal data with third parties as discussed in Clause 4 (Who We Share Your Personal Data With)
below.
4. Who We Share Your Personal Data With
The Company may share Your personal data with:
- Affiliates: As agreed, We may share Your personal data with Our affiliate entities who may need to
access Your personal data for operational and functional needs.
- Employees and consultants: We may share Your personal data with Our employees and consultants on a
need-to-know basis for providing services to You which improves Your experience in relation to the App.
- Franchises and Trusted third-party service providers: We may provide Your personal data to our
franchisees and Our trusted third-party service providers on a need-to-know basis for servicing You in
relation to Your use of or access to the App.
- Counsellors/experts: We may share Your personal data with the counsellors/ experts available on the
App to provide counselling or expert help to You.
- Business transfers: If We are acquired by, or merged with, another company, or if Our assets are
transferred to another company or as part of a bankruptcy, liquidation or insolvency proceedings, We may
transfer Your personal data to such other company.
- Law enforcement agencies: We may share Your personal data when compelled by any law enforcement
agency in compliance with applicable laws.
All Our third-party service providers and other entities in the group are required to take appropriate security
measures to protect Your personal information in line with Our policies and in accordance with the applicable
data protection laws in India. Our third-party service providers are not allowed to use Your personal data for
their own purposes. They only process Your personal data for specified purposes and in accordance with Our
instructions.
5. Legitimate Uses
Please note that We may process Your personal data without Your knowledge or consent for certain legitimate uses
which are required or permitted by law. The circumstances of such legitimate use include:
- Enforcing any legal right or claim;
- Processing by any court or tribunal or any other body in India which is entrusted by law with the
performance of any judicial or quasi-judicial or regulatory or supervisory function, where such processing
is necessary for the performance of such function;
- Processing in the interest of prevention, detection, investigation or prosecution of any offence or
contravention of any law for the time being in force in India;
- Fulfilling any obligation under any law for the time being in force in India to disclose any information to
the State or any of its instrumentalities;
- Complying with any judgment or decree or order issued under any law for the time being in force in India, or
any judgment or order relating to claims of a contractual or civil nature under any law for the time being
in force outside India;
- Responding to a medical emergency involving a threat to the life or immediate threat to the health of the
User(s) or any other individual;
- Taking measures to provide medical treatment or health services to any individual during an epidemic,
outbreak of disease, or any other threat to public health;
- Taking measures to ensure safety of, or providing assistance or services to, any individual during any
disaster, or any breakdown of public order.
6. Data Security
- We take security of Your personal data very seriously and have taken steps to implement appropriate and
reasonable safeguards and technical security measures to prevent any personal data breach, or unauthorized
access, use, modification, disclosure, or destruction of Your personal data that You entrust with Us.
- You should, however, take necessary steps at Your end as well to protect against unauthorized access to Your
passwords and devices. We will not be responsible for any lost, stolen, or compromised passwords, data or
for any unauthorized activities on Your account.
7. Data Retention
- We shall retain Your data for the purposes it was collected for and in compliance with applicable laws of
India. For further details on data retention, We request that You write to Us at
developer@lighthouse-learning.com.
- In some circumstances, We may anonymise Your personal data so that it can no longer be associated with You,
in which case We may use such information without further notice to You.
8. Rights of the User
We respect Your data and acknowledge Your rights in relation to it. Your rights in relation to Your data are
protected under law. You also have the following rights under this Policy:
- Right to access information about personal data processed. You can access and/or obtain
information related to Your personal data and its processing by writing to Us at
developer@lighthouse-learning.com.
- Right to correction, completion, and updating of the personal data for the processing of
which You have previously given Your consent. We assume that Your personal data as provided by You is
accurate, error-free and complete. We shall not be liable for any errors, inaccuracies, or incompleteness in
the personal data provided by You, or any direct or indirect consequences arising from such incorrect,
inaccurate or incomplete personal data. In case of changes to Your personal data, You can correct, complete,
or update Your personal data by writing to Us at developer@lighthouse-learning.com.
- Right to erasure of Your personal data for the processing of which You have previously
given Your consent. You can request us to erase Your personal data processed by Us, by writing to Us. We
will also erase Your personal data if (i) We recognize that the specified purpose for which Your personal
data was collected is no longer being served; and/or (ii) You withdraw Your consent vis-a-vis the personal
data. However, erasure of Your personal data may not be done in cases where (i) retention of Your personal
data is necessary for the specified purpose for which Your personal data was collected; or (ii) for
compliance with any applicable law for the time being in force. Erasure of data is also subject to Our
retention policy. Any erasure of Your data may impact the service we provide/ or may provide to You.
- Right to opt-out of receiving marketing and promotional materials, newsletters, and other
non-essential messages by using the 'unsubscribe' function included in all such communications.
- Right to withdraw consent: To the extent Your consent forms the basis of processing Your
personal data, You have the right to withdraw Your consent at any time, without affecting the legality of
processing Your personal data based on such consent before its withdrawal. Any and all consequences of Your
withdrawal of consent resulting in, inter alia, disruption, or unavailability of services, will be borne
entirely by You.
- Right to grievance redressal to redress Your grievances in respect of any act or omission
by Us in relation to the performance of Our obligations in relation to Your personal data. We have also
appointed a Grievance Officer who will expeditiously redress any grievance(s). Please see Clause 13
(Redressal of Grievances) of this Policy for details of the Grievance Officer.
- Right to nominate, in the prescribed manner, any other individual who shall, in the event
of Your death or incapacity, exercise Your rights in accordance with the applicable law and Our policies.
To exercise any of Your rights above, please contact Us in writing, by emailing Your relevant Grievance Officer
at developer@lighthouse-learning.com.
9. Transfer of Personal Data Outside India
- Presently, We only store the personal data that We collect about You in India.
- If We have to transfer Your personal data outside India in the future, We will do it in compliance with
applicable law.
10. Reporting of Data Breach
In the event, We come to know of any personal data breach, We will expeditiously, in compliance with the
applicable laws, inform the relevant authorities of such personal data breach. In the event You come to know of
any personal data breach, You are required to inform the same to us within 2 hours of having such knowledge of
breach.
11. Modifications
This Policy may be updated by Us from time to time. The updated version of the Policy can be accessed at any time
on the App. You are advised to regularly review the Policy. We will notify You of any updates to this Policy
that might materially affect the purpose of collecting Your personal data, prior to the change becoming
effective by means of a notice on the App. You will be required to review the updated Policy. Your continued use
of the App after any changes to this Policy will be deemed as Your acceptance of such change(s). If You do not
accept the updated Policy, You may exercise Your right of withdrawal of consent as per Clause 8 (Rights of the
User) above. However, We may not be able to provide You access to the App in such case.
12. Governing Law and Jurisdiction
- This Policy shall be construed in accordance with the applicable laws of India subject to the arbitration in
clause 12(b) below, disputes under or arising out of the Terms shall be subject to exclusive jurisdiction of
courts at Mumbai, India.
- All disputes arising from or in connection with this Agreement shall be referred to, and finally settled by,
arbitration in accordance with the Indian Arbitration and Conciliation Act, 1996, presided over by a sole
arbitrator jointly appointed by the Parties. The arbitration proceedings shall be held at Mumbai and shall
be conducted in the English language. The award of the arbitral tribunal shall be binding on the Parties.
The arbitration proceedings shall be kept confidential
13. Redressal of Grievances
If You have any queries regarding the App or find any discrepancies in relation to the processing of personal
data under this Policy, You may write to the Grievance Officer, the details of which are provided below:
Name: Rakesh Bhat
Email: rakesh.bhat@lighthouse-learning.com, with cc to legal@lighthouse-learning.com.
Phone: 9819283336
Address: Windsor, 801, Off Vidyanagari Marg, Kalina, Santacruz East, Mumbai, Maharashtra 400098.
Our Grievance Officer will attempt to redress Your queries and concerns expeditiously or in accordance with the
timelines prescribed under the applicable laws.
Date updated: 12th February 2025