1. Consent

Orange Education Pvt Ltd (“Company” or “We” and their connotations) operates a learning portal – (URL: https://www.thetouchcode.com/) (together called as “Online Platform”) which offers online Teaching-Learning services for children ages 5-14 years , Parents in the Parent-Child Learning Programs and Teachers for Teacher Training.  Together these are to be defined and to be referred as (‘Online Users’).

The Portal is also for individuals keen on learning more about us and might share their information which might or might not end up is them being our Online Users. All such individuals are to be  defined and to be referred as (‘Visitors).

Our Online User’s privacy and its protection is of utmost importance to us. We are cognizant of privacy concerns of the online Users and the Visitors. This document lists a detailed privacy policy to provide safe and secure experience on our Online Platform.

Users are Requested to read the same before sharing their data with us.

2. The Privacy Policy:

  1. Introduction
    This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.
    We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how Orange uses your data; for example how we combine data to build a picture of you.
    We hope the following sections will answer any questions you have but if not, please do get in touch with us.
    It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.
  1. Explaining the legal bases we rely on
    The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
    Consent
    In specific situations, we can collect and process your data with your consent.
    For example, when you tick a box to receive email campaigns
    When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
    Contractual obligations
    In certain circumstances, we need your personal data to comply with our contractual obligations.
    For example, if you order an item from us for home delivery, we’ll collect your address details to deliver your purchase, and pass them to our courier.
    Legal compliance
    If the law requires us to, we may need to collect and process your data.
    For example, we can pass on details of people involved in fraud or other criminal activity affecting Orange to law enforcement.
    Legitimate interest
    In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
    For example, we will use your purchase history to send you or make available personalised offers.
    We also combine the shopping history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services.

  1. When do we collect your personal data?
    • When you visit our website, and use your account to buy products, or redeem vouchers from.
    • When you make an online purchase and check out as a guest (in which case we just collect transaction-based data, such as email, name, and address).
    • When you create an account with us.
    • When you engage with us on social media.
    • When you sign up to ‘My Account’ you will be given access to an area on orangeava.com which will collect and store all of your receipts for you when you make a purchase from Orange.
    • When you contact us by any means with queries, complaints etc.
    • When you enter prize draws or competitions.
    • When you choose to complete any surveys we send you.
    • When you comment on or review our products and services.
    • When you’ve given a third party permission to share with us the information they hold about you.

 What sort of personal data do we collect?

  • If you have a web account with us: your name, date of birth, job title, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password.
  • Details of your interactions with us through online or by using one of our apps. For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, voucher redemptions, products you show interest in, web pages you visit and how and when you contact us.
  • Details of your shopping preferences.
    For example, which of our products and web pages you prefer to visit and where you redeem your vouchers or discount codes.
  • Details of your visits to our websites or apps, and which site you came from to ours.
  • Information gathered by the use of cookies in your web browser.  Learn more about how we use cookies and similar technologies.
  • Personal details which help us to recommend items of interest.
    For example, you might share information on your topic preference which allows us to recommend appropriate technology area eBooks.
    We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us. Of course, it’s always your choice whether you share such details with us.
  • Payment card information, which is stored with a Payment Card Provider in a PSI-DSS Compliant Manner.
  • Your comments and product reviews.
  • To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered. 
  • Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

How and why do we use your personal data?


We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.
We then use this to offer you promotions and products that are most likely to interest you.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ in section 11 below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.

3.What information we collect and how do we use it:

In order to provide Services, we require certain user information and may obtain the same through user-provided data or automatic data collection.

  • By choosing to visit and/or avail any Services provided by Company, you agree to this Privacy Policy (as may be amended from time to time). Please read the following information carefully. If you are a parent or guardian and you provide your consent to your Child’s use of the Platform, you agree to be bound by this Privacy Policy in respect to their use of the Platform. By your continued access or use of the Platform, you signify your agreement to be legally bound by Privacy Policy set forth herein. If you do not agree to the Privacy Policy of this agreement, promptly exit this page and stop accessing the Services.
  • We collect information that may be used to identify you or your Child (“Personal Information”) including, but not limited to,
    • Name of the Child
    • Age
    • Location/Address
    • Contact Details
    • Phone Number
    • Email ID
  • We also collect certain information either when you provide it using the Platform or Services and/or automatically as you or the Child navigate through the Platform (which may include usage details, IP address, device ID and type, your browser type and language, the operating system used by the device, access times, and information collected through cookies, web beacons and other tracking technologies). You agree that we may use such information to do internal research on our Users’ demographics to better understand, protect and serve our Users.
  • We also collect information from your user ID associated with any social media account (such as your Facebook and Google account) that users use to sign into the Platform or connect with or use of our Services. When you sign in with your social media account information, or otherwise connect to your social media account with the Platform, you consent to our collection, storage, and use, in accordance with this Privacy Policy, of the information that you make available to us through the social media interface. This includes, without limitation, any information that you have made public through your social media account, information that the social media service shares with us or information that is disclosed during the sign-up and sign-in processes.
  • In furtherance of your usage of our Platform, we require the parents to create a G-mail account on behalf of the Child. This account is created in order to enable the Child to sign into and access other various coding programs available across the internet as listed on the Platform. We shall collect information from this G-mail account that you use to connect with or use our Services and access other coding programs made available through our Platform. When you sign in with this G-mail account, you consent to our collection, storage, and use, in accordance with this Privacy Policy, of the information that you make available to us through the internet.
  • If any of the Users allows us to collect information from his or her device phonebook—and you or the Child’s are one of that User’s contacts—we may combine the information we collect from that User’s phonebook with other information we have collected about you. We may also obtain information from other sources and combine that with the information we collect through the Platform.
  • We use data collection devices such as “cookies” on certain pages of the Platform to help analyse our web page flow, measure promotional effectiveness, and promote trust and safety. Cookies are small files placed on your hard drive that assist us in providing our Services. We offer certain features that are only available using a cookie. Cookies can also help us provide information that is targeted to your interests.
  • Online training sessions are recorded and used for quality audits and teacher training.
  • Users shall grant the Company a non-exclusive, transferable, sub-licensable, royalty-free, worldwide license for content that is covered by intellectual property rights, like photos and videos (IP License). This IP License shall end when you delete your IP content or your account unless your content has been shared with others, and they have not deleted it. When you delete IP content, it is deleted in a manner similar to emptying the recycle bin on a computer. However, you understand that removed content may persist in backup copies for a reasonable period (but will not be available to others).

4. How do we use the data Collected.

We collect personal information only necessary for the following purposes:

  • To create and maintain an account;
  • To enable you to avail of our Services, and ensure efficient customer care experience and develop new features;
  • To determine the current age of the Child;
  • To send surveys or marketing communications to inform you of new products or Services or other information that may be of interest;
  • To dispatch transaction-related communications such as welcome letters, billing reminders, and purchase confirmations;
  • To notify the necessary information related to the Platform and Services and your or the Child’s account on the Platform from time to time;
  • To maintain records and provide you and the Child with an efficient, safe and customized experience while using the Platform;
  • To analyse overall trends to helps us improve the Platform and Services;
  • To perform quality audits and teacher training;
  • To furnish your information to service partners and providers only to the extent necessary for delivering the relevant services (e.g. scheduling service and maintenance, providing emergency assistance);
  • Verify your identity and prevent fraud or other unauthorized or illegal activity;
  • To comply with applicable laws, rules, and regulations;
  • And In any other way consistent with this Privacy Policy.

Additionally,

  • We may use your email address to seek parental consent of Child for registration of and to explain what information we are collecting, how we plan to use it, and how the parent can revoke consent or request at any time that we remove the account and delete any Personal Information collected from the Child (including the parental contact information).
  • We reserve the right to use or disclose your Personal Information in response to any statutory or legal requirements. We will use and disclose your Personal Information if we believe you will harm the property or rights of the Platform, its owners, or those of the Platform’s other users. Finally, we will use or disclose yours or the Child’s Personal Information if we believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person or property, violations of the Platform’s other policies, or as otherwise required by law when responding to subpoenas, court orders and other legal processes.
  • If we believe that disclosure is necessary or appropriate to protect our rights, property, or safety, our Users or others, we may in good faith share information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
  • You agree that we may use Personal Information about you to improve our marketing and promotional efforts, to analyse site usage, improve the Platform’s content and Service offerings, and customize the Platform’s content, layout, and Services. These uses improve the Platform and better tailor it to meet your needs, so as to provide you with an efficient, safe and customized experience while using the Platform.

5. Data Security

We always strive to keep your Personal Information safe, we have been taking many safety measures, including:

  • The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
  • Safety in the operating environment: we store your Personal Information in a safe operating environment and it can only be accessed by employees, representatives and service providers on a need-to-use basis. We comply with industry standards and the law to protect your Personal Information.
  • The payment information: confidentiality according to industry standards.
  • We strictly limit the Personal Information that is publicly viewable about a User who is known by us to be a Child. When a Child posts a review or comment on the Platform, only the Child’s age & name is posted, along with the content of the Child’s posting. Although the Child may create a profile for his/her account, no portion of the Child’s profile other than the Child’s age and name is publicly viewable. For posting the child accomplishments (project work) on social media a separate parental consent is sought. The posting includes Name, Age, School, City, Picture and key project details.

6. 3rd Party Sites

Our Platform may contain links to other 3rd Party websites. Please note that when you click on one of these links, you are entering another website over which we have no control and for which we will bear no responsibility. Often these websites require you to enter your Personal Information. We encourage you to read the privacy policies of all such websites as their policies may differ from our Privacy Policy. You agree that we shall not be liable for any breach of your privacy of Personal Information or loss incurred by your use of such websites or services.

7. Data protection Regulations

The information we obtain from or about you may be processed and stored in India and our other various servers located across the globe, which may provide for different data protection rules than the country in which you reside. We comply with generally accepted industry standard regulations regarding the collection, use, and retention of data under the Information Technology Act, 2000. By using the Platform and/or Services, you consent to the collection, transfer, use, storage and disclosure of your information as described in this Privacy Policy, including to the transfer of your information outside of your country of residence.

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Orange Education Pvt Ltd aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us on the details as given below.

8. Rights of the Data Subject.

You have the following data protection rights.

  • The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where Orange Education Pvt Ltd relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

9. Sharing of Personal Data

We may share your personal information with third party service providers (called ‘processors’) to perform certain processing activities on our behalf, such as Parties involved in hosting and enabling our Services. Please note that we will not share your Personal Information with third parties allowing them to use this information for their own purposes unless you have given explicit consent thereto. Categories of third party processors are:

Categories

Legal Requirement

Usage Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service

Online and Behavioral Marketing

We use remarketing services to advertise on third party websites to you after you visit our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service

Payment Processing and Discounting

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors)..

Collaboration and Location Service Providers

We collaborate with location service providers to send out emails, SMS’s and OTP’s to our customers, enable online live video classes for students and teachers and to also enable telephony across our students, teachers and support team.

10. Rights to Your Personal Information

  • You have the right to provide Personal Information to us and may change that decision at any time.
  • You have the right to check, update and adjust your Personal Information by logging into your account and editing personal information or asking us to do this.
  • You may also delete yours or your Child’s information at any time on the Platform. However, we may retain certain information as required by law or for reasonable business purposes
  • To sum up, you have the right to access, update, delete, rectify, object or restrict the Personal Information we have on you.

11. Updates to this Privacy Policy

This Privacy Policy will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website

12. Cancellation/Refund Policy

You can choose to opt out anytime, any day, any month! Yes, no questions asked. In such a case, you will be refunded on a pro-rata basis ie an amount equivalent to the number of unused Live classes. Simply drop an email on info@orangeeducation.in to cancel anytime.
It will take 7 Bank Working days to process and credit the amount to your bank account.