Tailwnd | Flow Learning Solutions LLP ("we," "us," or "our") is committed to protecting the privacy of our users, particularly K-12 students, in compliance with the Digital Personal Data Protection Act, 2023 (DPDPA) and the Student Privacy Pledge. This Privacy Policy explains how we collect, use, disclose, and protect personal data, including for the purpose of displaying non-sensitive, contextual advertisements. As our website is designed for children under 18, we take extra care to safeguard their data and obtain verifiable parental consent where required.
1. Scope
This Privacy Policy applies to all users of www.tailwnd.com ("Website"), including students, parents, and guardians, and covers personal data processed in India. Personal data refers to any information that identifies or can be linked to an individual, such as name, contact details, or device information.
2. Data We Collect
We collect the following personal data, either directly (e.g., during offline registration) or automatically (e.g., through website usage):
- Data Provided by Users
- Registration Information: Name, age, school details, parent/guardian contact information (e.g., email, phone number), provided during offline registration.
- Account Information: Username, password, and preferences for accessing the Website.
- Data Collected Automatically
- Device and Usage Information: IP address, device type, browser type, operating system, and pages visited, collected to deliver educational content and non-sensitive advertisements.
- Cookies and Similar Technologies: We use strictly necessary cookies for website functionality. For ad display, minimal data (e.g., IP address) is collected to serve contextual ads, with no behavioral tracking or profiling.
- Data from Parents/Guardians
- Consent forms, including parent/guardian name, contact details, and verification information (e.g., signed forms), collected offline to comply with DPDPA.
3. How We Use Your Data
We use personal data for the following purposes, in compliance with DPDPA and the Student Privacy Pledge:
- Educational Services: To provide access to educational content, manage user accounts, and deliver personalized learning experiences.
- Website Functionality: To ensure the Website operates smoothly, including authentication and performance monitoring.
- Non-Sensitive Advertisements: To display contextual, family-friendly ads via Google AdSense, based solely on page content, not user behavior or profiles.
- Compliance and Communication: To verify parental consent, respond to inquiries, and comply with legal obligations.
- Analytics: To analyze Website usage (e.g., page views, session duration) in a de-identified manner, ensuring no tracking of individual children.
We do not use personal data for behavioral advertising, targeted advertising, or building user profiles for commercial purposes.
4. Legal Basis for Processing
We process personal data based on:
- Verifiable Parental Consent: For users under 18, we obtain consent from parents/guardians for data processing, including ad display, as required by DPDPA Section 9.
- Legitimate Purposes: For data voluntarily provided (e.g., registration details) to access the Website, where processing is necessary and does not involve tracking or advertising.
- Legal Obligations: To comply with DPDPA and other applicable laws.
5. Disclosure of Personal Data
We share personal data only as necessary and with safeguards:
- Third-Party Service Providers: We share minimal data (e.g., IP address) with Google AdSense to serve contextual ads. Google acts as a data processor under our instructions, with no tracking or profiling permitted.
- Legal Requirements: We may disclose data to comply with court orders, law enforcement, or regulatory authorities.
- No Sale or Commercial Sharing: We do not sell or share personal data for commercial purposes beyond authorized educational or ad-serving functions.
6. Children’s Privacy
As a Website for K-12 students, we prioritize children’s privacy:
- Parental Consent: We obtain verifiable parental consent before processing personal data of users under 18, including for non-sensitive ads, via offline registration processes (e.g., signed consent forms).
- No Tracking: We prohibit behavioral tracking, targeted advertising, or profiling of children, using only contextual ads.
- Limited Data Collection: We collect only the minimum data necessary for educational services and ad display.
7. Parental Rights
Parents/guardians of users under 18 have the following rights under DPDPA:
- Access: Request details of your child’s personal data we hold.
- Correction: Request correction of inaccurate or incomplete data.
- Deletion: Request deletion of your child’s data, subject to legal retention requirements.
- Nominate: Designate a nominee to manage data rights in case of incapacity.
- Withdraw Consent: Revoke consent for data processing at any time, which may limit Website access.
- Grievance Redressal: Contact our Grievance Officer (details below) for concerns.
To exercise these rights, email [insert email, e.g., privacy@yourwebsite.com].
8. Data Security
We implement reasonable security safeguards, including encryption, access controls, and secure data storage, to protect personal data from unauthorized access, loss, or misuse, as required by DPDPA.
9. Data Retention
We retain personal data only as long as necessary:
- User Data: Retained while the account is active or as needed for educational purposes.
- Ad-Related Data: Temporary data (e.g., IP address) is retained only for ad delivery and deleted promptly.
- Consent Records: Parental consent forms are retained for 7 years to comply with legal obligations or until the user turns 18, whichever is longer.
10. Third-Party Links
The Website may contain links to third-party sites (e.g., educational resources). We are not responsible for their privacy practices. Review their policies before use.
11. International Data Transfers
As our servers and Google AdSense may process data outside India, we ensure compliance with DPDPA’s cross-border data transfer rules through standard contractual clauses or other safeguards.
12. Updates to This Privacy Policy
We may update this Privacy Policy to reflect legal or operational changes. Updates will be posted on the Website with the revised date. Continued use after updates constitutes acceptance, subject to your right to withdraw consent.
13. Contact Us
For questions, concerns, or to exercise your rights, contact our Grievance Officer:
14. Grievance Redressal
If unsatisfied with our response, you may contact the Data Protection Board of India (once established) or seek remedies under DPDPA.
Note: By using the Website, you acknowledge you have read and understood this Privacy Policy. For users under 18, we rely on parental consent to process personal data as described.