India Privacy Policy

PRIVACY NOTICE FOR INDIA

Last Updated: July 10, 2025

INTRODUCTION

We at Owlyard Inc. and its affiliates (collectively, "Company" or "we" or "our" or "us"), consider privacy and protection of Personal Data entrusted and disclosed to us to be of high importance and are committed to protecting the privacy of information providers.

APPLICABILITY

This privacy notice ("Privacy Notice") applies to all individuals whose Personal Data is processed by us, including but not limited to customers, website visitors, employees, consultants, job applicants, service providers, partners, suppliers, and vendors ("you" / "your" / "yourself"). This Privacy Notice will familiarise you with the manner in which we may collect, process, use, share, transfer and disclose your Personal Data.

For purposes of this Privacy Notice, "Personal Data" means any data about an information provider / individual who is identifiable by or in relation to such data or any similar term defined in and governed by applicable laws.

SOURCES OF COLLECTION OF PERSONAL DATA

We collect your Personal Data through various channels, depending on your interaction with us. We usually collect your Personal Data when you contact us, apply for a job, respond to our communications, visit or use our website or other digital interfaces (collectively, "Digital Platforms"). If you avail our services offline or otherwise interact with us offline, such as visit or request our products or services through our offices or attend our events or seminars, we may receive certain Personal Data from those offline media as well. These collection of Personal Data are necessary to provide you with our services, improve our offerings, or respond to your requests.

During business engagements:

  • If you are a customer, service provider, supplier, vendor, or partner, we may collect your Personal Data at the time of initiating or performing a business relationship with you. This includes data collected during the onboarding process, execution of contracts, diligence exercises and while fulfilling our contractual or statutory obligations.
  • We may also collect information otherwise through usage of our Digital Platforms, correspondence, invoices, service delivery records, or usage of our other portals or systems (if applicable).

Employment and recruitment processes:

If you are an employee, consultant, or job applicant, we may collect your Personal Data through the application and recruitment process, either directly from you or via employment agencies, recruiters, or background verification providers.

Third-party sources:

In certain cases, we may obtain your Personal Data from third parties, including:

  • Credit reference agencies, for conducting credit checks;
  • Background verification agencies;
  • Sanctions screening databases and compliance databases;
  • Statutory authorities or public databases, where required; and
  • Medical professionals, in rare and limited cases, subject to applicable law.

Internal processes:

Where applicable, we may collect additional Personal Data in the course of your engagement with us, whether as an employee, service provider, vendor or partner, such as through internal communications, system logs, audit trails, performance records, or access to premises or Digital Platforms.

NATURE AND PURPOSES OF PROCESSING PERSONAL DATA

We broadly collect and process the following categories of Personal Data for the purposes mentioned below:

A. From Customers and other Digital Platform visitors:

BROAD PERSONAL DATA CATEGORYEXAMPLES OF PERSONAL DATAPURPOSES FOR COLLECTION / USE
Personal detailsName, age, contact number, email address, address, date of birth, subject preferences, information on areas of interest and/or special requests
  • To create and manage your user account / profiles on our Digital Platform.
  • To provide you with access to our devices, systems and services.
  • To protect your account from unauthorised access.
  • To process your membership and services requested on our Digital Platform.
  • To communicate with you regarding the status of your membership and/or any service-related updates.
  • To personalise your experience and recommend courses on your preferences.
  • To manage your special seminar/event bookings.
  • To invite you to our events, seminars or surveys.
Contact and communication informationEmail address, phone number and/or social media handles (if provided)
  • To contact you for service updates or feedback.
  • To respond to inquiries, complaints, or service requests.
  • To send marketing or promotional communications, subject to your consent or preferences.
  • To administer contests, loyalty programs, or referral initiatives.
Transaction and order informationService request history, course preferences, payment method and/or invoice data
  • To fulfil your service requests and maintain transaction records.
  • To improve operational efficiency and planning.
  • To manage refunds, complaints, or service-related disputes.
  • To generate aggregated analytics and reports for internal planning and service enhancement.
Feedback and survey dataReviews, ratings, feedback forms, course preferences and/or complaints or compliments
  • To improve our services and quality of courses offered.
  • To follow-up on issues raised or feedback provided.
  • To personalise marketing and promotional campaigns.
Online identifiers and technical dataIP address, browser type, device ID, cookies, session logs, browsing behaviour and/or referring pages
  • To operate, monitor, and improve the performance of our Digital Platforms.
  • To enhance your browsing experience and personalise content on our Digital Platforms.
  • To ensure website security and detect fraudulent or suspicious activity.
Marketing and engagement dataFor marketing, campaign engagement metrics, loyalty program activity and/or event participation
  • To run marketing campaigns, send promotional offers, discounts, and personalised content.
  • To track effectiveness of campaigns and customer engagement.
  • To manage opt-in and opt-out preferences.
Third-party platform dataData received from other websites and/or apps, including name, contact details, address, order details, allergy preferences, feedback
  • To fulfil any orders placed through third-party platforms.
  • To respond to feedback or service-related issues.
  • To analyse your behaviour and improve course offerings.
  • To comply with our contractual obligations to such platforms.

B. From employees, consultants, job applicants, service providers, partners, suppliers, and vendors:

BROAD PERSONAL DATA CATEGORYEXAMPLES OF PERSONAL DATAPURPOSES FOR COLLECTION / USE
Personal detailsName, age, gender, date of birth, nationality, marital status, signature, residential address, email address, contact details and evidence of your right to work in the U.S.A.
  • To verify your identity and credentials.
  • To communicate with you in relation to our business operations and managing your employment / retainership relationship.
  • To invite you to our events or webinars.
  • To fulfil our contractual and legal obligations toward you.
  • For security purposes, such as crisis preparedness and emergency notifications, or for the protection of your health or the safety of others.
  • For compliance with internal policies and statutory requirements, such as record keeping and reporting for public health care, pension programs and tax purposes.
  • To create aggregated reports for human resources' analytics and diversity reports.
Health information and medical dataInformation related to physical or mental health, medical payment, medical claims data, medical history, medical reports, medical condition, products, or equipment used, health plan beneficiary and medical treatment.
  • To ascertain your fitness to work.
  • To provide medical / first aid assistance when required.
  • To communicate with healthcare providers.
  • To enable procuring insurance policies / plans and to process insurance settlement / claims.
  • To comply with legal and / or regulatory requirements.
Authenticating informationDevice passwords, personal identification numbers (PIN), biometric information, fingerprints and facial scans.
  • To authenticate your identity and grant you access to our systems.
  • To record your attendance and participation.
  • To improve the security of our systems and services.
Financial informationBank account information, bank statements, compensation data, and other financial-related details such as income, investments, benefits and tax status.
  • To provide service related payments and other compensations to consultants.
  • To process payroll and provide employee benefits (including insurance and pensions) to employees.
  • To process any claims or settlements, if any.
Employment informationBenefits and entitlements data, contract type, hours of work, job title, salary/wage, workers compensation claims, start date, end date, reason for termination, employee performance results, record of absence, time tracking, annual leave, office location, previous work history, grievances and complaints, health and safety-related information and reporting, job application details, disciplinary action, exit interview, accident book, first aid records, injury at work and third party accident information
  • To comply with legal requirements.
  • To provide you with the benefits and services to which you are entitled.
  • To compute salary / retainer pay, manage and analyse work hours.
  • To administer benefits and entitlements and manage compensation claims.
  • To ensure compliance with labour laws, health and safety regulations, and other legal obligations related to employment, including maintaining accurate records of absence and health and safety-related information.
  • To assess employee performance, manage disciplinary actions, and support professional development.
  • To determine office location assignments.
  • To maintain accurate records for compliance, internal audits, and historical reference, including previous work history and job application details.
  • To manage and resolve employee grievances, complaints, and any related legal claims.
Background check informationCriminal history, criminal records and driving related citations
  • To prevent fraud and abuse.
  • To verify your identity and qualifications.
  • To assess your suitability for the position.
Education and skills informationAcademic transcripts, educational degrees, education training and history, languages and/or letters of recommendation
  • To verify your qualifications.
  • To assess your suitability for the position/courses.
  • To provide training and development opportunities for employees / consultants.
Family and dependant informationParent's name, dependents, and other household information and/or details of children and spouses
  • To contact your family members in the event of an emergency.
  • To provide benefits that they are entitled to in case of your death of permanent ailment.
Travel and expense informationExpense details, travel booking details and/or travel history
  • To reimburse your travel expenses.
  • To track your travel expenses.
  • To ensure you are complying with our travel policies.
User account informationEmail address and username
  • To create and manage your work account / profiles.
  • To provide you with access to our devices, systems and services.
  • To protect your account from unauthorised access.
  • To monitor employee activity and electronic communications in the workplace in accordance with our internal policies and applicable law, for security, prevention of misconduct or crime.
Referral informationName of referral, contact information of referral, relationship of referral
  • To verify your identity and credentials.
  • To evaluate your qualifications for employment.
  • To communicate with the referral about your employment.
Business relationship dataName, contact details, designation, official email address, identification documents, tax and regulatory registration numbers (e.g., PAN), bank account details, business address, authorised signatory details and/or compliance certificates.
  • To conduct diligence, background verification and onboarding.
  • To evaluate business proposals and capabilities.
  • To enter into and administer contracts and commercial arrangements.
  • To process payments and manage invoices.
  • To maintain business continuity and service delivery records.
  • To ensure compliance with legal and regulatory obligations, including tax, anti-bribery, anti-money laundering and sanctions screening.
  • To communicate with you regarding service delivery, quality standards, audits, or operational requirements.
  • To monitor ongoing compliance with contractual and legal requirements.

C. From other sources

Additionally, we may process your Personal Data in certain circumstances where you have provided your consent, for example, when you choose to participate in customer satisfaction surveys, promotional campaigns, loyalty programs, pilot initiatives, or other marketing or feedback-related activities conducted by us. If you fail to provide certain Personal Data when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers). Further, by providing us with information belonging to an individual other than you, you are confirming that you have the authority of such individual to provide us with their information.

In addition to the above, your Personal Data may be used by us for lawful purposes or for legitimate purposes as permitted under applicable laws, including the following purposes:

  1. Complying with any legal process, whether local or foreign;
  2. Detecting and preventing identity theft, fraud or any other potential illegal acts;
  3. Responding to requests from public and governmental authorities, including public and governmental authorities outside your country of residence; and/or
  4. For obtaining professional services from advisors such as lawyers and chartered accountants, which may require them to process your Personal Data and in connection with business transactions undertaken by us.

YOUR RESPONSIBILITIES

You represent that the Personal Data you provide to us is true, accurate, current, and complete. You are required to periodically review and update your Personal Data that we retain about you to ensure that it is always accurate and correct. We will rely on the last updated version of the Personal Data as updated by you. While providing your Personal Data, you agree to ensure not to impersonate another person, and to furnish only such information as is authentic.

SHARING OF PERSONAL DATA WITH THIRD PARTIES

Your Personal Data may be shared by us with the following service providers:

  1. Third party service providers (such as server operators) for the purposes of storing, maintaining and processing Personal Data.
  2. Third party service providers for the purposes of processing employees' payroll payouts / retainer payments, claims and benefits, technical support, insurance and medical services, background verification, etc.
  3. Marketing and communication service providers for managing customer communications, running loyalty programs, customer surveys, email campaigns, and targeted advertisements, subject to your consent and preferences.
  4. Payment gateways and financial institutions to facilitate secure payments, refunds, and processing of financial transactions.
  5. Public and governmental authorities, including public and government authorities outside your country of residence, enforcement authorities and agencies for complying with any legal process, responding to requests from public and government authorities.
  6. Credit reference agencies and similar institutions to report or ask about your financial circumstances.
  7. Our affiliates, group entities, related parties, subsidiaries, and advisors such as lawyers, chartered accountants and financial advisors, in connection with business transactions and for legitimate purposes as permitted under applicable laws.

We may share, disclose or transfer your Personal Data to third parties in connection with, or during negotiations of, any merger, acquisition, reorganisation, sale of assets, or similar corporate transaction involving our Company. Such third party will have the right to continue to use your Personal Data in accordance with this Privacy Notice (as amended from time to time) and applicable laws.

SECURITY PRACTICES AND PROCEDURES

We implement reasonable security safeguards, including appropriate technical and organisational measures, to protect your Personal Data. Your Personal Data is stored on secure servers, and access is restricted to authorised personnel on a need-to-know basis. While we are committed to ensuring the ongoing integrity, availability, and confidentiality of your Personal Data, and take all reasonable steps to secure it, we must caution that no method of transmission over the internet or method of electronic storage is entirely secure. Accordingly, we cannot guarantee absolute security and acknowledge that some risk may persist despite our best efforts.

YOUR RIGHTS

Your exercise of the rights mentioned herein will be subject to applicable law and conditions stipulated therein and pursuant to the rules and regulations of the Company.

Right to withdraw consent:

Where we have relied on your consent to process your Personal Data, you have the right to withdraw your consent at any time in the manner provided under this Privacy Notice. Please note that withdrawal of your consent will not be retrospective in nature and shall be applicable prospectively. Further, you will be responsible for any consequences of withdrawal of your consent, but such withdrawal of consent will not affect the legality of any Personal Data processing done by us based on your consent before it was withdrawn.

Right to access:

Subject to certain conditions, and where we have relied on consent to process your Personal Data, or where you have voluntarily provided your Personal Data for a specified purpose, you have the right to obtain information from us as below, as well as such information as may be further prescribed under applicable law:

  • Summary of Personal Data and processing activities: You have the right to receive a summary of the Personal Data that is being processed by us, along with details regarding the processing activities undertaken by us with respect to such Personal Data.
  • Identities of other entities: You have the right to know the identities of all other entities with whom your Personal Data has been shared by us. This includes a description of the Personal Data shared with these entities.

Right to correction, completion and updation:

Subject to certain conditions, you have the right to correction, completion, and updating of your Personal Data for which you have previously given consent or voluntarily provided your Personal Data for a specified purpose, in accordance with any requirement or procedure under any law for the time being in force.

This includes the right to:

  • Correct any inaccurate or misleading Personal Data.
  • Complete the incomplete Personal Data.
  • Update your Personal Data.

Right to erasure:

Subject to certain conditions, and where we have relied on consent to process your Personal Data, or where you have voluntarily provided your Personal Data for a specified purpose, you have the right to request the deletion of your Personal Data under certain circumstances, such as when the Personal Data is no longer necessary for the purposes for which it was collected or when you withdraw your consent. Please note that the withdrawal of consent or exercise of right to erasure may impact our ability to perform the contract we have entered into with you (including our ability to provide continued employment to concerned employees, or engagement with our service providers, franchisee partners, suppliers, vendors, etc.) and we may be prevented from complying with our legal obligations.

Right to nominate an individual for exercising rights:

You have the right to nominate any other person to exercise the rights mentioned above in case of your death or incapacity.

HOW TO EXERCISE YOUR RIGHTS?

You may exercise your rights under the Privacy Notice by writing to us, with sufficient details of the right that you wish to exercise, at info@owlyard.com. Please ensure your request includes sufficient information to verify your identity as well, such as your registered phone number, customer reference number, employee code or vendor ID, as applicable. The Company may take reasonable steps to authenticate your identity before acting on your request. We may decline to process requests that are frivolous or unreasonably repetitive or burdensome or risks the privacy or impacts the rights of others.

RETENTION OF YOUR PERSONAL DATA

We will retain your Personal Data in accordance with applicable law and will erase / delete your Personal Data, which is in our possession, when:

  • (i) It is concluded that such Personal Data is no longer needed, and we are not under any statutory / legal obligation to retain the same anymore.
  • (ii) Subject to (i) above, when you request for erasure of your Personal Data or withdraw your consent for your Personal Data, in accordance with the process set out in this Privacy Notice.

Contact:

If you have any grievances, queries or issues in relation to processing of your Personal Data by the Company or regarding exercise of your rights under this Privacy Notice, you may contact our Grievance Officer, Debasrita Bhakta, COO of Owlyard, at info@owlyard.com.

We will endeavour to respond to your requests within 30 days. However, if additional time is required due to the nature of the request or query, we will keep you appropriately informed.

Data Protection Board of India

If you are aggrieved with our decisions as part of our grievance redressal process available to you under this Privacy Notice, you have the right to complain to the Data Protection Board of India ("Board"), as and when the applicable law in this regard is in effect and the Board has been formed. However, you should contact us in the first instance to remedy any grievances / complaints.

Changes to the Privacy Notice

The Company reserves the right to revise and update this Privacy Notice at its sole discretion. Any such revisions will be effective on and from the date of posting the same on the Company's Digital Platforms. We recommend that you review this Privacy Notice periodically to ensure that you are aware of the current privacy and data protection practices of the Company.