Privacy & Policy

This Privacy Policy is an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000 and the rules made thereunder, and does not require any physical, electronic, or digital signature.

This document is published, and shall be construed, in accordance with the provisions of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”) framed under the Information Technology Act, 2000, and the Digital Personal Data Protection Act, 2023 read with the Digital Personal Data Protection Rules, 2025 (together, the “DPDP Framework”), each as may be amended from time to time.

“We”, “Our”, or “Us”: refers to Nyasah Business Concepts Private Limited, a company incorporated under the Companies Act, 2013, operating the Reflections Gurukul journalism education initiative, together with its subsidiaries, affiliates, and their officers, directors, employees, agents, and authorised representatives.

“You”, “User”, “Student”, “Learner”, or “Intern”: refers to any individual who accesses or uses the Website or our services, including for the purpose of browsing, registering, enrolling in a course, mini-course, or internship, submitting coursework, or otherwise communicating with us, and includes any parent or lawful guardian registering, or providing consent, on behalf of a minor.

“Content”: includes, but is not limited to, course material, lecture videos and scripts, articles, assignments, quizzes, internship reports and logs, images, and all other forms of information or data made available on or through the Website.

“Your Content” or “User Content”: means Content that you create, upload, share, or submit to, through, or in connection with our services, such as assignments, quizzes, internship reports and logs, feedback, reviews, profile information, and any other material you submit in connection with a course or programme.

“Platform Content”: means Content that we create and make available in connection with our services, including course material, lecture scripts, visual interfaces, graphics, design, software, and reports, excluding Your Content and Third Party Content.

“Third Party Content”: means Content that comes from parties other than us or our Users and is made available on the Website.

“Personal Data” or “Personal Information”: means data about or relating to a Data Principal who is identifiable by or in relation to such data, as defined under the DPDP Act, 2023.

“Data Principal”: means the individual to whom the personal data relates, i.e., you.

“Data Fiduciary”: means the entity that determines the purpose and means of processing personal data, i.e., Nyasah Business Concepts Private Limited, in respect of the Website.

In accordance with the Information Technology Act, 2000, the SPDI Rules, and the DPDP Act, 2023, the details of our Grievance Officer, who you may contact with any queries, complaints, or grievances relating to the processing of your personal data, are as follows:

Name: Mukesh Harekar

Designation: HR Officer

Email: contact@reflectionsgurukul.com

Address: ‘B’ Wing, 6th Floor, 603, Satellite Gazebo, 167 Guru Hargovindji Marg, Chakala, Andheri (E), Mumbai, 400099.

Registration and enrolment: when you register on the Website, enrol in a course, mini-course, or internship programme, or subscribe to our updates, we may collect your name, email address, phone number, postal address, date of birth, educational qualifications, and a password of your choice.

Minors: if you are enrolling as a minor, that is, a person below 18 years of age, we require the name, email address, and contact details of your parent or lawful guardian, along with their verifiable consent, before we collect or process your personal data.

Payment information: when you purchase a course or programme, your payment is processed directly by our third-party payment gateway partner(s). We do not store your complete card, UPI, or net-banking credentials on our servers.

Coursework and internship records: as part of your enrolment, you may submit assignments, quizzes, writing samples, internship reports, and completion or activity logs. We collect this information to evaluate your progress and to issue certificates, performance letters, and completion logs.

Communications: if you contact us by email, through the Website, or via any feedback or contact form, we collect the information you choose to share with us.

Automatically collected information: we may collect technical information such as your IP address, browser type, device information, and pages visited, through cookies and similar technologies, as described in Section 16 below.

Third-party sign-in: if you choose to register or log in using a third-party account, such as Google, we may collect basic profile information from that account, such as your name and email address, in accordance with that platform's privacy settings. We do not control, and are not responsible for, the privacy practices of such third-party platforms.

We use your personal data for the following purposes:

• To create and manage your account and enrolment.
• To provide access to purchased courses, mini-courses, and the internship programme.
• To evaluate your coursework, assignments, and internship submissions.
• To issue certificates, performance letters, and completion logs, including hours completed, where applicable.
• To process payments for course or programme fees.
• To communicate with you about your enrolment, course updates, and support queries.
• To send you information about new courses, offers, or journalism-related content, where you have not opted out of such communication.
• To improve our courses, Website, and services, based on the feedback we receive.
• To comply with applicable law, regulatory requirements, or lawful requests from government or judicial authorities.

We will not use your personal data for any purpose other than the purpose or purposes for which you have provided consent, unless required or permitted by applicable law.

We process your personal data primarily on the basis of your consent, given for the specific and lawful purposes described in this Privacy Policy. Where applicable, we may also rely on other lawful grounds recognised under the DPDP Act, 2023, such as compliance with a legal obligation.

You may withdraw your consent at any time by writing to our Grievance Officer at the details mentioned in Section 8. Withdrawal of consent will not affect the lawfulness of processing carried out before such withdrawal, and may result in our being unable to continue providing certain services to you.

Under the DPDP Act, 2023, you have the right to:

• Access a summary of the personal data we hold about you and the processing activities carried out on it.
• Request correction, completion, or updating of your personal data.
• Request erasure of your personal data, unless we are required to retain it for a legal or regulatory purpose.
• Nominate another individual to exercise your rights in the event of your death or incapacity.
• Withdraw your consent at any time.
• Raise a grievance with our Grievance Officer, and, if unresolved, escalate the matter to the Data Protection Board of India.

To exercise any of these rights, please write to our Grievance Officer at the contact details mentioned in Section 8.

We implement reasonable security practices and procedures, including administrative, technical, and physical safeguards appropriate to the nature of the personal data we hold, in line with the SPDI Rules and the DPDP Act, 2023.

Payment transactions are processed through a secure, PCI-DSS compliant payment gateway. We do not store your complete card or banking details on our servers.

Access to your personal data is restricted to employees, agents, and service providers who need it to perform their functions, and who are contractually bound to keep it confidential.

Despite these measures, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee its absolute security.

We do not sell or rent your personal data. We may share your personal data with:

• Our employees, affiliates, and authorised representatives, on a need-to-know basis.
• Service providers who assist us in operating the Website and delivering our services, such as payment gateways, email and SMS service providers, cloud hosting providers, and analytics providers, who are contractually obligated to protect your data and to use it only for the purpose for which it was shared.
• Government, regulatory, judicial, or law enforcement authorities, where required by applicable law, or where we believe in good faith that disclosure is necessary to comply with legal process, protect our rights, or ensure the safety of our users.
• A successor entity, in the event of a merger, acquisition, or sale of all or substantially all of our assets, subject to that entity agreeing to honour this Privacy Policy, or providing notice of any material change.

Under the DPDP Act, 2023, a “child” means any individual below the age of 18 years.

We do not knowingly collect the personal data of any user below 18 years of age without the verifiable consent of a parent or lawful guardian.

If you are below 18 years of age, you may use our Website and enrol in our courses or internship programme only with the involvement and consent of your parent or lawful guardian, who will be treated as the person providing consent on your behalf.

We do not undertake tracking, behavioural monitoring, or targeted advertising directed at users we know to be children, and we do not process a child's personal data in any manner that is likely to cause harm to them.

If we learn that we have collected the personal data of a child without appropriate parental or guardian consent, we will take steps to delete such data, unless retention is otherwise required by law.