1. Introduction

The India Genius Challenge (“we”, “us”, “our” or “IGC”) values your privacy and is committed to protecting personal information relating to you (“you”, “your” or “User”). Personal Data refers to information about you that can identify you, such as your name, location, date of birth or phone number (“Personal Data”). This Privacy Policy explains what Personal Data we collect and process, why we collect it, how we use it, with whom we may share your Personal Data, and your rights regarding your Personal Data.

This Privacy Policy applies to your interaction with us through our websiteindiageniuschallenge.com(“Platform”), in connection with your participation in the IGC, including the online and offline stages of the IGC, as well as any content, services, or features made available through the Platform.

Please note that this Privacy Policy applies only to Personal Data collected through the Platform. Personal Data collected during any in-person events conducted as part of Stage 2 of the IGC will be governed by a separate privacy policy or notice shared at the time of such collection in accordance with the applicable data privacy laws.

This Privacy Policy should be read together with our Terms of Use, and any other specific privacy notices provided when your Personal Data is collected. If there is a conflict between this Privacy Policy and a specific privacy notice, the terms of the specific privacy notice will prevail.

This Privacy Policy does not apply to our affiliates or partners, each of whom may have their own privacy policies. In situations where you interact with such partners, we strongly encourage you to review the applicable privacy policy for that particular site, service, or interaction.

2. What data do we process and why?

We collect limited Personal Data from and about you when you interact with or use the Platform in connection with your participation in the IGC. The types of Personal Data we collect depend on the nature of your interaction with the Platform and the stage of your participation. Here is an activity-wise description:

2.1. When you visit and attempt the Challenge without signing up

Anyone can visit the Platform and attempt the quizzes, questions, puzzles, etc. (“Challenge”) associated with the IGC. At this stage we do not collect or store any Personal Data. Your attempts of the Challenge and your subsequent scores are not retained beyond the active session, and are not linked to your identity.

2.2. When you choose to sign up on the Platform

When you choose to sign up with us on the Platform, we may collect and process the following Personal Data:

• Name
• Date of Birth or Age
• Location (City or Town, State)
• Phone number (Parent’s or Legal Guardian’s phone number if you are below 18 years of age)
• Parent name and OTP (if you are below 18 years of age and the submitted Phone number is of Parent or Legal Guardian)
• Your scores and participation records in IGC, post-registration on the Platform.
• Name, address and contact details of the school or institution

We process your Personal Data for the following purposes:

• To enable and manage your registration and participation in the IGC;
• To verify your age and obtain parental consent, if you are under 18 years of age;
• To track your progress and performance across different stages of the IGC and display rankings on a leaderboard;
• To determine eligibility for rewards, digital gifts, etc., and/or selection for Stage 2 of the Challenge;
• To contact you or your parent/guardian regarding your participation, if needed;
• To maintain records and analytics related to participation in the IGC;
• To improve our Platform; and
• To comply with legal obligations, cooperating with public authorities, courts, tribunals, regulatory bodies and supervisory authorities as required by law, responding to legal requests, resolving disputes, managing risks, seeking legal advice, enforcing our policies and contractual terms, and protecting our Platform.

When you participate in the Challenge after signing up on the Platform, we may display your performance on a public leaderboard (“Leaderboard”), which is accessible to all users of the Platform. The Leaderboard displays top-scoring participants and their relative performance based on city or town-level classifications.

We may process and publicly display the following limited Personal Data on the Leaderboard:

• Your username (or first name, as may be displayed on the Platform);
• Your city or town and state;
• Your score and rank (including daily, weekly, or monthly performance);
• Your school or institution name.

We process and display this information for the following purposes:

• To recognise and encourage top performers in the IGC;
• To foster a spirit of healthy competition among participants;
• To provide transparency and visibility into participant progress at the city or town level;
• To promote the IGC and its reach across different locations in India;
• To maintain records of participant performance as part of the structure of the IGC.

2.3. When you contact us to raise a grievance or complaint

When you contact our support team via email to raise issues or inquiries, we process:

• Name, username (if any), email address, and registered Phone number;
• Details of the issue or complaint;
• Communication logs, if any.

We collect the above information for the following purposes:

• For verifying your identity;
• To address and resolve your complaints or requests;
• To contact you via email, SMS or text message and providing you with the requested information, or resolution to your raised grievance or complaint;
• To improve our services; and
• To comply with legal obligations, cooperating with public authorities, courts, tribunals, regulatory bodies and supervisory authorities as required by law, responding to legal requests, resolving disputes, managing risks, seeking legal advice, enforcing our policies and contractual terms, and protecting our business and platforms.

2.4. When you engage with us on social media platforms

When you interact with us on social media (e.g. sharing comments on posts of our official page on any social media platform), we may process your Personal Data publicly available on these platforms. This includes:

• Your full name or username (as displayed on the social media platform), your profile picture (if publicly available) and location, such as city, town or country (if indicated on your profile); and
• Any comments or content you post publicly regarding us.

We process such data (which may include your Personal Data), for the following purposes:

• responding to your comments and posts about our Platform, IGC and Challenges;
• gathering feedback on our Challenges and IGC, and analysing the effectiveness of our social media posts;
• improving our Challenges and to provide you and others with a better user experience;
• analysing trends relating to the IGC and our Challenges, and developing new Challenges accordingly; and
• cooperating with public authorities, courts, tribunals, regulatory bodies and supervisory authorities as required by law, responding to legal requests, resolving disputes, managing risks, seeking legal advice, enforcing our policies and contractual terms, and protecting our business and platforms.

3. Where we collect your Personal Data from?

We may collect your Personal Data from several sources, including:

(i) Personal Data you provide directly: This includes any Personal Data you share with us through our Platform, or other means, such as social media channel, or directly communicate with our support teams.

(ii) Personal Data we collect automatically: When you visit our website or use our offerings, we may process certain technical and behavioural data via automated means, such as cookies, pixels, tags, web beacons, embedded scripts, and similar technologies. For more details on our use of cookies and tracking technologies, please see the 'Cookies and Other Tracking Technologies' section below. Typically, the information collected via automated means, includes:

• Your IP address, browser type, device operating system, referring website, general geographic location (based on IP address), web-browsing behaviour, and interactions with our Platform and/or our Challenges (e.g., pages or screens accessed, duration of visits, activity on a page or screen, access times, and length of access); and
• To the extent you have consented, we may collect your precise location data.

We use this data for:

• Administering our Platform and our Challenges, including internal operations like updating, testing, securing, and troubleshooting;
• Understanding how our Platform is being accessed and used;
• Improving the structure, content, and user experience of the Platform;
• Analysing engagement patterns for improving the design of the Challenge;
• Collecting statistics on your usage and interactions with our Platform and IGC, as well as gathering feedback on the Challenges;
• Maintaining and protecting the security and functionality of our Platform and systems, while preventing and detecting security threats, fraud, and other criminal or malicious activities; and
• Cooperating with public authorities, courts, regulatory bodies, and supervisory authorities as required by law, responding to legal requests, resolving disputes, managing risks, seeking legal advice, enforcing our policies and contractual terms, and protecting our business and platforms.

(iii) Personal Data we receive from third parties: We may receive Personal Data about you from third parties, such as analytics providers or social media channels, where such data is collected with your consent or as legally permitted.

4. Who we share your data with

We share your Personal Data with third parties in accordance with this Privacy Policy.

5. How long do we keep your Personal Data?

We keep your Personal Data for as long as necessary for the activity for which it was collected and to fulfil the purposes outlined in this Privacy Policy. Once the data is no longer needed for these purposes or to meet legal, regulatory, or business requirements, we will securely delete it.

You may request deletion of your account information and Personal Data by contacting us at the email address provided below (How to contact us) in this Privacy Policy.

While we work to fulfil such deletion requests, we may need to retain certain Personal Data for a while longer for the following reasons: (a) to perform any of our contractual obligations to which you are subject, or to respond to your questions or provide necessary support; (b) to prevent fraud, resolve any complaints or queries, address inquiries, or exercise/defend legal claims, including providing evidence in legal proceedings; (c) to comply with legal obligations, exercise our rights, resolve disputes, or for security and safety reasons, as permitted under the law (such as adhering to applicable statutes of limitations or regulatory investigations).

We may also retain anonymized data, aggregated with other anonymized information, for analytics, research, or other purposes in relation to the IGC.

6. Your rights

You have certain rights over your Personal Data: (a) Right to access information about your Personal Data: You can ask us for a summary of your Personal Data, the processing activity, and the recipients with whom we have shared your Personal Data, along with a description of the Personal Data we shared.

(b) Right to seek correction and erasure of Personal Data: If you believe that the Personal Data we hold is inaccurate, incomplete or outdated, you can write to us. You may also request deletion of your data; however, in certain cases, we may need to retain it for legal or regulatory reasons (See Clause 5 (How long we store your data) above).

(c) Right to grievance redressal: If you wish to file a grievance, you may contact our Data Protection Officer / Grievance Redressal Officer in accordance with this Privacy Policy. If your grievance remains unresolved, please be informed that you have the right to escalate it to the competent supervisory authority i.e., Data Protection Board.

(d) Right to Nominate: You can designate another individual to exercise your rights under this Privacy Policy on your behalf, in the event of your death or incapacity.

(e) Right to opt out: If we are processing your Personal Data based on your consent, you may withdraw your consent at any time. Should you do so, you may not be able to access some of the features on the Platform or Challenges.

To exercise any of these rights or seek further information, you can write to us at igc@webveda.com. We reserve the right to verify your identity before processing your request, and not to respond to enquiries or complaints that we believe are manifestly false, unfounded, or frivolous. Additionally, these rights may be limited in certain cases, where we are legally required to process or retain your Personal Data.

7. How we protect your personal data?

We are committed to ensuring the security of the Personal Data we process, protecting it from unauthorized access, alteration, disclosure, or destruction. Based on the type and sensitivity of the data, we implement a variety of technical and organizational measures to safeguard your Personal Data from such loss, misuse, unauthorized disclosure, and alteration. We require our employees, agents, contractors, and third parties with access to your Personal Data to perform business functions, to process your Personal Data in accordance with this Privacy Policy. While we make every effort to protect your Personal Data, we understand that no system can guarantee complete security. If you have any concerns, need assistance, or suspect that your interaction with us is no longer secure, please contact us immediately using the instructions under the How to Contact Us section below.

8. Third Parties and Links

Our Platform may contain links to third-party websites or services not under our control. Your data shared there will be governed by their policies. We are not responsible for their content or data handling practices.

9. Cookies and other tracking technologies

We use cookies and similar tracking technologies to enhance your experience on our Platform, improve the Challenges and/or features of our Platform, and better understand how you interact with our content. Cookies are small data files stored on your device via your web browser based on your consent, when you access any of our Platform. These files help in ascertain your preferences, track trends, and enable faster logins, among other purposes. They collect data such as your IP address, browser type, and device type (e.g., PC, smartphone), and identify your subsequent visits to our Platform and tailor our offerings and the Challenges more precisely to you, the stage of the IGC and other relevant factors. We utilize cookies to accumulate information on your use of the designated portions of our Platform and facilitate the analysis of our offering, Challenges, user engagement, and measurement of effectiveness of the IGC and our communications. For example, these cookies help us see which features on our Platform are popular or to customize user experience with the Challenges.

We use both session cookies and persistent cookies. Session cookies are deleted when you close your browser, while persistent cookies remain on your device until they expire or you delete them.

You can control how cookies are used through your browser or device settings, where you can disable or delete all or some cookies. However, disabling or rejecting cookies may limit your access to all or certain features of our Platform or Challenges, for which we require the use of cookies.

10. Children's Privacy

IGC and the Platform are intended primarily for students aged between 13 and 18 years. IGC is aimed at finding, recognizing the merit and rewarding students, specially from tier 2 and 3 cities in India, and providing them the financial, intellectual and emotional support required for their holistic growth.

We recognize the importance of safeguarding children's Personal Data and are committed to complying with applicable data protection laws, including those relating to the collection and use of children's data.

We do not knowingly collect or process Personal Data of children under the age of 18 without verifiable parental or legal guardian consent. Where a user is below the age of 18 years, and wishes to register with the Platform, we require:

• The phone number (or WhatsApp number) of parent or legal guardian of the user at the time of registration; and
• The parent or legal guardian to authenticate and provide consent through an OTP (one-time password) verification mechanism.

This consent mechanism ensures that the participation of minors in IGC is authorized by their parent or guardian, and that their Personal Data is processed with appropriate consent and safeguards. If we become aware that we have collected Personal Data of a child without the required parental consent, we will delete such data promptly.

Parents or legal guardians who wish to review, correct, or delete the Personal Data of their child, or withdraw consent previously provided, may contact us using the details provided under the How to Contact Us section below.

11. How to contact us?

You may contact us to exercise your rights or for notifying discrepancies / raising grievances with respect to your Personal Data you provide to us or on any other aspect of this Privacy Policy, by contacting our Grievance Redressal Officer/Data Protection Officer as set out below:

If you have any questions about this Policy, wish to exercise your rights, concerns about privacy or grievances, please write to us with a thorough description via email to igc@webveda.com

Grievance redressal timeline: As per the applicable laws, we aim to acknowledge your grievance or complaint within 24 hours and resolve it within 15 days.

12. Updates to this Privacy Policy

We reserve the right to modify, add, or remove portions of this Privacy Policy, at our sole discretion. We will make reasonable efforts to notify you of any material changes. Once the revised Privacy Policy is published on our website and/or other platforms, the changes will take effect immediately unless stated otherwise. Your continued use of our Platform, offerings and features on the Platform, after such update constitutes consent to the updated Privacy Policy to the extent permitted by law. Please take the time to periodically review this Privacy Policy for the latest information on our privacy practices.