DATA PRIVACY AND CHILD SAFETY AGREEMENT (INDIA REGION)
Last Updated: September 2026
Welcome to our online education platform (the “www.pathati.com”). This Data Privacy and Child Safety Agreement (“Agreement”) is a legally binding contract between you and the Platform.
- For Users Aged 18 and Over: By checking the acceptance box, you agree to these terms.
- For Users Under 18: A parent or legal guardian must review, accept, and complete the registration process on your behalf. Under Indian law, minors are not permitted to register without Verifiable Parental Consent.
📌 1. Scope and Compliance under Indian Law
This Platform strictly operates in compliance with India’s Digital Personal Data Protection (DPDP) Act, 2023 and its corresponding Rules, alongside the Information Technology (IT) Act, 2000. We act as a Data Fiduciary, ensuring that student data is processed lawfully, transparently, and with enhanced safety guardrails mandated for children (individuals under the age of 18).
📌 2. Verifiable Parental Consent (VPC) & Onboarding
Pursuant to Section 9 of the DPDP Act, processing a child’s personal data requires lawful consent from their parent or lawful guardian.
- Verification Architecture: Accounts for students under 18 require a parent or guardian to verify their identity and relationship through secure onboarding mechanisms, such as DigiLocker verification, Aadhaar-based OTP validation, or a nominal credit card/banking transaction.
- Right to Erase: Parents retain the absolute right to withdraw consent at any time. Upon withdrawal, the Platform will permanently delete the child’s personal data from all active databases and third-party vendor pipelines.
📌 3. Data Collection & Interactive Feature Policies
We practice strict data minimization. We only collect information required to power our specific interactive features:
- Live Sessions: We process student video feeds, audio streams, and real-time chat logs exclusively to deliver live classes. Live sessions are recorded on secure, encrypted servers for student review, safety audits, and quality assurance.
- Automated Quizzes: Performance scores, response times, and academic metrics are processed solely to evaluate student learning curves and generate progress reports.
- Public Discussion Forums: Any text, image, or media posted by students on public forums will be stored and displayed. Forums are strictly monitored to ensure a safe learning environment.
- Strict Prohibitions (DPDP Act Compliance): The Platform is strictly prohibited from tracking or monitoring the behavior of children and will never engage in targeted advertising directed at minors.
📌 4. Interactive Safety Guardrails
To ensure a secure digital environment across our interactive features, we enforce the following technical controls:
| Feature / Category | Implemented Safety Guardrail |
| Live Virtual Classrooms | Instructors retain complete control over student video/audio feeds. Direct, unmoderated peer-to-peer messaging inside live rooms is disabled by default. |
| Public Forums | Automated AI Content Moderation continuously scans discussion walls for profanity, cyberbullying, inappropriate images, or shared phone numbers/URLs. |
| Educator Vetting | Every instructor undergoes mandatory identity verification and background screening before hosting a live session. |
| Grievance Redressal | In accordance with Indian regulations, a designated Grievance Officer is appointed to resolve privacy or safety issues within statutory timelines. |
📌 5. Third-Party Vendor Management & Security Breaches
We utilize reliable third-party cloud infrastructure (e.g., AWS India nodes), video hosting infrastructure, and analytics engines to power our features.
- Data Processing Addendums (DPAs): All third-party providers are contractually bound to the same data safety standards outlined in this agreement.
- Breach Notification: In the event of a personal data breach involving a minor, the Platform is legally obligated to immediately notify the Data Protection Board of India (DPBI) and the affected parents.
➡️ 6. User and Parent Acknowledgement
By checking “I Accept”, you acknowledge and agree that:
- You are either the user (if over 18) or the parent/legal guardian of the minor user.
- You consent to the processing of live video/audio recordings and quiz data for educational delivery.
- You agree to abide by the Platform’s community guidelines on public forums, understanding that any cyberbullying or inappropriate behavior will result in immediate account suspension.
Global Template: Data Privacy & Child Safety Agreement (International Regions)
Last Updated: September 2026
This version of the Agreement applies to users accessing the Platform from outside India. By checking the acceptance box, you agree to these jurisdiction-specific terms.
1. Verifiable Parental Consent (VPC) by Region
We enforce age-gating based on your local jurisdiction. If you are under the legal age threshold, your parent or guardian must provide consent before account activation:
- United States (COPPA): If the student is under 13, parents must provide consent via a signed consent form, a nominal credit card transaction, or via a verified school-issued single-sign-on (SSO) under FERPA “School Official” exceptions.
- European Union & UK (GDPR): If the student is under 16 (or the respective age threshold set by your EU member state), parental consent must be explicitly obtained before any data processing begins.
2. Specific Protections for Interactive Features (Global)
- Live Sessions: In compliance with global child safety laws, video and audio data streams are heavily encrypted in transit and at rest.
- Public Forums: To comply with the EU’s “Right to be Forgotten” (Article 17 GDPR) and California’s “Erasure” laws, students and parents can request the immediate, permanent deletion of any forum posts, comments, or media uploaded by the minor.
- No Behavioral Ads: We strictly adhere to the global ban on serving targeted, behavioral advertisements to users recognized by our system as minors.
3. International Privacy Rights
Depending on your residency, you possess specific statutory rights regarding your student data:
- GDPR Rights: The right to data portability, the right to object to processing, and the right to lodge a complaint with a local European Data Protection Authority (DPA).
- California (CCPA/CPRA) Rights: The right to know what personal information is collected, the right to delete it, and the explicit right to prevent the sharing or selling of a minor’s data (Right to Opt-Out/Opt-In).