Updated 19th May 2022

I. Introduction:

Bablr Ltd, UK T/A Bablr Early Learning  has appointed Neosap India Private Limited (“us” “we” “Bablr”) an entity registered under the Indian Companies Act 2013 is the operator of internet resources Bablr Early Learning System (Bablr Platform or Platform) in India which includes Bablr website  www.gobablr.com (Bablr Website, or Website or Bablr WebApp or WebApp) and reseller of  Bablr mobile applications (Bablr mobile applications or mobile applications) for Android and iOS, Bablr tablet applications (Bablr tablet applications or tablet applications) for Android and iOS and the provider of Bablr Materials Boxes which together constitute Bablr Early Learning System  (“Platform”) as well as the software, content and applications provided by Bablr, (collectively referred to as the “Services”). This privacy policy (“Privacy Policy“) explains how we collect, use, share, disclose and protect Personal information about the Platform Users and Product Users of the Bablr Platform and Bablr Product (as defined in the Bablr Terms and Conditions of Use (ToS) and the any other visitors of the website (jointly and severally referred to as “you” and all its grammatical forms or “Users” and all grammatical forms in this Privacy Policy). We have created this Privacy Policy to demonstrate our commitment to the protection of your privacy and your personal information. Your use and/or access to the Platform and/or Product and/or Services is subject to this Privacy Policy and Bablr ToS.  By using the services or by otherwise giving us your information, you will be deemed to have read, understood and agreed to the practices and policies outlined in this Privacy Policy and you agree to be bound by the same. By agreeing with our Privacy Policy, you consent to our collection, use and sharing, disclosure of your information as described in this Privacy Policy. We reserve the right to change, modify, add or delete portions of the terms of this Privacy Policy, at our sole discretion, at any time. If you use the services on behalf of someone else (such as your child) or an entity (such as your employer), you represent that you are authorised by such individual or entity to accept this Privacy Policy on such individual’s or entity’s behalf, and consent on behalf of such individual or entity to our collection, use and disclosure of such individual’s or entity’s information as described in this privacy policy.

II. Object of the Privacy Policy:

This Privacy Policy applies to the users making use of Bablr Website and WebApp is published in compliance with, inter alia:

1. Section 43A of the Indian Information Technology Act, 2000;
2. Regulation 4 of the Indian Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011;
3. Regulation 3(1) of the Indian Information Technology (Intermediaries Guidelines) Rules, 2011.

Please note that when you make purchases of Bablr Apps or any other related services from Apple App Store, Google Android Play Store or any other similar third party ecosystem, the developer account associated with such platforms may not belong to us. But irrespective of this, we shall be the custodians of your data as authorised by our principle Bablr Ltd. UK and this privacy policy shall apply.

This Privacy Policy states the following:

1. The type of information collected by us from the Users, including Personal Information (as defined in clause III & IV below) and Sensitive Personal Data or Information (as defined in clause III & IV below) relating to an individual;
2. The purpose, means and modes of collection, usage, processing, retention and destruction of such information; and
3. How and to whom Bablr will disclose such information.

III. Collection of Traffic Data:

Our Services require us to know who you are so that we can best meet your needs. When you access Bablr Platform we track and collect the information as mentioned hereinbelow. You hereby consent to the collection of such information by Bablr. Without prejudice to the generality of the above, information collected by us from you may include (but is not limited to) the following:

1. IP addresses;
2. domain servers;
3. types of computers accessing the Platform;
4. types of web browsers used to access the Platform;
5. referring source which may have sent you to the Platform; and
6. other information associated with the interaction of your device/browser and the platform (collectively “Traffic Data”).

IV. Collection of Personal Information:

In order for you to access certain areas of the Website or Mobile apps or Tablet apps or through any interaction with us via emails, telephone calls or other correspondence, certain Services where it is important for us to know who you are so that we can best meet your needs, we may require you to provide us with certain information that personally identifies you or could be used to personally identify you (“Personal Information”). Personal Information includes the following categories of information:

1. contact data (such as your name, e-mail address, phone number, billing and shipping addresses and Bablr passwords, one-time passwords);
2. demographic data (such as your or of child/ren that you represent- name, gender, date of birth, birth status);
3. other information that you voluntarily choose to provide to us (such as information shared by you with us through emails or letters).

The information collected from you by Bablr may constitute ‘Personal Information’ or ‘Sensitive Personal Data or Information’ under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011.

V. Use of Personal Information:

1. The Personal information gathered for providing Services may be used for the following purposes:
   1. for internal record keeping.
   2. for processing your orders.
   3. to analyse the use of the Platform, for example: when you visit our Platform, we may record when and how you interact with our Platform. This information is retained and used to note your interest in our Platform, improve customer journeys and personalise your experience where possible.
   4. to improve our products and services.
   5. to contact you about leaving a review on a product once your order has been completed. If you do not wish to be contacted for this purpose, please click the unsubscribe button you will find on the review email.
   6. to send you survey and feedback requests to help improve our Services. If you do not wish to be contacted for this purpose, please click the unsubscribe button you will find on the survey email.
2. You consent to be sent promotional e-mail about new products, special offers and services or other information unless you have asked us not to do so when you registered as a user on this Platform and/or where you update your marketing and communication preferences. We shall ask you for specific consent to send you information about rewards provided by selected third party companies which we think you may find interesting as.
3. Your personal information may be disclosed to selected third party companies which will help us to handle our warehousing and shipping logistics, process your order, to comply with our obligations, to manage and store data, to run our marketing campaigns and/or provide data analytics and where you choose to use certain payment services to pay us for Bablr Product and Services. In order to be able to offer you payment options, we will pass certain aspects of your personal information, such as contact and order details, in order to assess whether you qualify for the payment options and to tailor the payment options for you.
4. We will use the personal information we hold about you (as well as pseudonymised or anonymised information generated from your personal information) to carry out analysis and research, including:
   1. data analytics, whereby we combine information (such as personal information and/or sensitive personal information we have obtained through the use of Bablr’s Platform or from your browsing history) we hold on a large scale in order:
   2. to learn more about your preferences;
   3. to identify patterns and trends amongst all Platform users like you;
   4. to enhance user experience on our Platforms;
   5. to provide information, content and offerings tailored to your needs;
   6. for general research and statistical purposes;
   7. for aggregated reporting purposes within Bablr;
   8. develop new products and services;
   9. monitor performance of our products and services and/or improve our technology;
   10. to be able to send you personalized marketing messages; and
   11. to display online ads to you.
   12. If we are requested by the police or any other regulatory or government authority investigating suspected illegal activities to provide your Personal Information and /or User Information, we are entitled do so.
5. When you use the Platform, you are agreeing that we may use your personal information for the purposes set out in this statement.

 VI. Cookies:

The Platform uses temporary cookies to store certain (that is not ‘Sensitive Personal Data or Information’) that is used by Bablr for the technical administration of the Platform, research and development, and for User administration. In the course of serving advertisements or optimizing services to its Users, Bablr may allow authorised third parties to place or recognise a unique cookie on the User’s browser. The cookies however, do not store any Personal Information of the User. You may adjust your internet browser to disable cookies. If cookies are disabled you may still use the Platform, but the Platform may be limited in the use of some of the features.

VII. Web Beacons:

In limited circumstances, we also may use tiny graphic image files imbedded in a web page or email that provide a presence on the web page or email and send back to its home server information from the user′s browser (“Web Beacons”) to collect anonymous, non-Personal Information about your use of our Services and the sites of selected sponsors and advertisers, and your use of emails, special promotions or newsletters we send to you. The information collected by Web Beacons allows us to statistically monitor how many people are using the Services and selected sponsors’ and advertisers’ sites, or opening our emails, and for what purposes.

VIII. Platform Analytics:

We may use third party web analytics services in connection with the Services, for example, to record mouse clicks, mouse movements, scrolling activity, as well as any text that you type into the Platform. These Platform analytics services do not collect Personal Information that you do not voluntarily enter into the Platform. These services do not track your browsing habits across Platforms which do not use their services. We use the information collected from these services to find usability problems to make the Services easier to use. The recordings will never identify you or your account; they only record anonymous user information.

IX. Privacy Statements:

All Users note: This section applies to all users.

1. Accordingly, each User’s use of and/or access to the Platform amounts to their acceptance of the Terms of Use, which also involves acceptance of the terms of this Privacy Policy. Any User that does not agree with any provisions of the same has the option to discontinue the use of Bablr Platform and Services immediately.
2. All the information provided to Bablr by a User, including Personal Information or any Sensitive Personal Data or Information, is voluntary. You understand that Bablr may use certain information of yours, which has been designated as Personal Information or ‘Sensitive Personal Data or Information’ under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (i) for the purpose of providing you the Services, (ii) for commercial purposes and in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, (iii) for sale or transfer of such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates (v) debugging customer support related issues. Bablr also reserves the right to use information provided by or about the End-User for the following purposes:
   1. Publishing such information on the Platform.
   2. Contacting Users for offering new products or services.
   3. Contacting Users for taking product and Service feedback.
   4. Analysing software usage patterns for improving product design and utility.
   5. Analysing anonymized practice information for commercial use.
      1. If you have voluntarily provided your Personal Information to Bablr for any of the purposes stated above, you hereby consent to such collection and use of such information by Bablr.
3. Collection, use and disclosure of information which has been designated as Personal Information or Sensitive Personal Data or Information’ under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 which requires your express consent. By affirming your assent to this Privacy Policy, you provide your consent to such use, collection and disclosure as required under the applicable law.
4. Bablr does not control or endorse the content, messages or information found in any Services and, therefore, Bablr specifically disclaims any liability with regard to the Services and any actions resulting from your participation in any Services, and you agree that you waive any claims against Bablr relating to same, and to the extent such waiver may be ineffective, you agree to release any claims against Bablr relating to the same.
5. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. If your personal information changes, you may correct, delete inaccuracies, or amend information by making the change on our Platform User Profile page or by contacting Bablr Customer Support. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable. If you provide any information that is untrue, inaccurate, out of date or incomplete (or becomes untrue, inaccurate, out of date or incomplete), or Bablr has reasonable grounds to suspect that the information provided by you is untrue, inaccurate, out of date or incomplete, Bablr may, at its sole discretion, discontinue the provision of the Services to you. There may be circumstances where Bablr will not correct, delete or update your Personal Data, including (i) where the Personal Data is opinion data that is kept solely for evaluative purpose; and (ii) the Personal Data is in documents related to legal proceedings and if such proceedings have not been completed.
6. If you wish to cancel your account or request that we no longer use your information to provide you Services, contact us through the Grievance Officer by accessing the contact details here. We will retain your information for as long as your account with Bablr is active and/or as long as needed to provide you our Services and Product Usage. We shall not retain such information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force. After a period of time, your data may be aggregated, and then may be held by us as long as necessary for us to provide our Services effectively, but our use of the aggregated data will be solely for analytic purposes. Please note that your withdrawal of consent, or cancellation of account may result in Bablr being unable to provide you with its Services or to terminate any existing relationship Bablr may have with you.
7. If you wish to opt-out of receiving non-essential communications such as promotional and marketing-related information regarding the Services, you can click on the unsubscribe link in the communication which is always provided there.
8. Bablr may require the User to pay with a credit card, wire transfer, debit card or cheque for Services for which subscription amount(s) is/are payable. Bablr and/or its Payment Gateway provider will collect such User’s credit card number and/or other financial institution information such as bank account numbers and will use that information for the billing and payment processes, including but not limited to the use and disclosure of such credit card number and information to third parties as necessary to complete such billing operation. Verification of credit information, however, is accomplished solely by the User through the authentication process. User’s credit-card/debit card details are transacted upon secure sites of approved payment gateways which are digitally under encryption, thereby providing the highest possible degree of care as per current technology. However, most third-party gateways provide you an option not to save your payment details. User is advised, however, that internet technology is not full proof safe and User should exercise discretion on using the same.
9. Due to the communications standards on the Internet, when a User visits the Platform, Bablr automatically receives the URL of the site from which anyone visits. Bablr also receives the Internet Protocol (IP) address of each User’s computer (or the proxy server a User used to access the World Wide Web), User’s computer operating system and type of web browser the User is using, email patterns, as well as the name of User’s ISP. This information is used to analyse overall trends to help Bablr improve its Service. The linkage between User’s IP address and User’s personally identifiable information is not shared with or disclosed to third parties. Notwithstanding the above, Bablr may share and/or disclose some of the aggregate findings (not the specific data) in anonymized form (i.e., non-personally identifiable) with advertisers, sponsors, investors, strategic partners, and others in order to help grow its business.
10. The Platform uses temporary cookies to store certain (that is not sensitive personal data or information) that is used by Bablr and its service providers for the technical administration of the Platform, research and development, and for User administration. In the course of serving advertisements or optimizing services to its Users, Bablr may allow authorized third parties to place or recognize a unique cookie on the User’s browser. The cookies however, do not store any Personal Information of the User. You may adjust your internet browser to disable cookies. If cookies are disabled you may still use the Platform, but the Platform may be limited in the use of some of the features.
11. User may have limited access to the Platform without creating an account on the Platform. In order to have access to all the features and benefits on our Platform, a User must first create an account on our Platform. To create an account, a User may be required to provide the following information, which such User recognizes and expressly acknowledges is Personal Information allowing others, including Bablr, to identify the User: Name, User ID, email address, address, city, country, ZIP/postal code, age, phone number, password chosen by the User and valid financial account information. Other information requested on the registration page, including the ability to receive promotional offers from Bablr, is optional. Bablr may, in future, include other optional requests for information from the User to help Bablr to customize the Platform to deliver personalized information to the User.
12. This Privacy Policy applies to Services that are owned and operated by Bablr. Bablr does not exercise control over the sites displayed as search results or links from within its Services. These other sites may place their own cookies or other files on the Users’ computer, collect data or solicit personal information from the Users, for which Bablr is not responsible or liable. Accordingly, Bablr does not make any representations concerning the privacy practices or policies of such third parties or terms of use of such Platforms, nor does Bablr does not guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphics, videos, messages or other materials available on such Platforms. The inclusion or exclusion does not imply any endorsement by Bablr of the Platform, the Platform’s provider, or the information on the Platform. If you decide to visit a third party Platform linked to the Platform, you do this entirely at your own risk. Bablr encourages the User to read the privacy policies of that Platform.
13. Bablr does not collect information about the visitors of the Platform from other sources, such as public records or bodies, or private organisations, save and except for the purposes of registration of the Users (the collection, use, storage and disclosure of which each User must agree to under the Terms of Use in order for Bablr to effectively render the Services).
14. Bablr maintains a strict “No-Spam” policy, which means that Bablr does not intend to sell, rent or otherwise give your e-mail address to a third party without your consent.
15. Bablr has implemented best international market practices and security policies, rules and technical measures to protect the personal data that it has under its control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. However, for any data loss or theft due to unauthorised access to the User’s electronic devices through which the User avails the Services, Bablr shall not be held liable for any loss whatsoever incurred by the User.
16. Bablr implements reasonable security practices and procedures and has a comprehensive documented information security programme and information security policies that contain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of Bablr’s business.
17. Bablr takes your right to privacy very seriously and other than as specifically stated in this Privacy Policy, will only disclose your Personal Information in the event it is required to do so by law, rule, regulation, law enforcement agency, governmental official, legal authority or similar requirements or when Bablr, in its sole discretion, deems it necessary in order to protect its rights or the rights of others, to prevent harm to persons or property, to fight fraud and credit risk, or to enforce or apply the Terms of Use.

X. Children’s and Minor’s Privacy:

Bablr strongly encourages parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although the Bablr Platform and Services are not intended for use by minors, Bablr respects the privacy of minors who may inadvertently use the internet or the mobile application.

XI. Storage of Information:

Your information collected through the Platform, including your Personal Information, may be transferred and stored and processed in India and/or other countries outside of India. Your information, including personal information, may be transferred to jurisdictions that do not have data protection laws which are substantially similar to or serve the same purpose as the laws of your jurisdiction.

By registering for and using the Service You consent to the use and disclosure of information about You as described in this Privacy Policy as well as transfer of information to India or to any other country as explained in the preceding clause.

We use commercially reasonable safeguards to help keep the information collected through the Service secure and take reasonable steps (such as requesting a unique password or one time password) to verify your identity before granting You access to your account. However, we cannot ensure the security of any information You transmit to us or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed.

We use a variety of generally accepted security technologies and procedures for the purpose of preventing loss, misuse, unauthorised access or disclosure of Information – for example, we use encryption technology (such as SSL) to protect certain sensitive Information provided by You to us. Please be aware that despite our efforts, no data security measures can guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed. We do not warrant or guarantee the security of our Services or any information You provide to us through our Services.

It is further agreed that in the event that, Bablr sells any of its business or assets to any third party, it may disclose your personal data to the prospective buyers of such business or assets. The same shall also be applicable if Bablr or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

XII. Managing Your Information:

If You would like to manage, change, limit, or delete your information, we allow You to do that through the following tools:

1. Access and Updates: We strive to let you access and update most of the personal information directly through our Website and/or mobile apps and/or tablet apps. You can access and update most of your basic account information right in our Platform. However, we may reject a request for a number of reasons, including, for example, that the request risks the privacy of other users, requires technical efforts that are disproportionate to the request, is repetitive, or is unlawful. If You need to access, update, or delete other personal information that we may have, You can put in a request to our Grievance Officer by accessing the contact details here. Since your privacy is important to us, we may ask You to verify your identity or provide additional information before we let You access or update Your personal information. We will try to update and access your information for free, but if it would require a disproportionate effort on our part, we may charge a fee. We will of course disclose the fee before we comply with your request.
2. Revoking Permissions: If You change your mind about our ongoing ability to collect information from certain sources that You have already consented to, such as your phonebook or location services, You, can simply revoke your consent by changing the settings on your device if your device offers those options. Of course, if You do that, certain services may lose full functionality either partially or completely.
3. Deletion of Your Account: You may delete your account at any time (including if You want to revoke your consent to our use of your information) by contacting our Customer Service on contact details provided here. Please remember that when You delete Your account, it does not affect the information other users have relating to You, such as their copy of the messages You sent them.

XIII. Confidentiality and Security:

1. Your Personal Information is maintained by Bablr in electronic form on its equipment, and on the equipment of its employees. Such information may also be converted to physical form from time to time. Bablr takes all necessary precautions to protect your personal information both online and off-line and implements reasonable security practices and measures including certain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of Bablr’s business.
2. No administrator at Bablr will have knowledge of your password. It is important for you to protect against unauthorized access to your password, your computer and your mobile phone. Be sure to log off from the Platform when finished. Bablr does not undertake any liability for any unauthorised use of your account and password. If you suspect any unauthorized use of your account, you must immediately notify Bablr by contacting the Customer Service on contact given here. You indemnify Bablr due to any loss suffered by it due to such unauthorized use of your account and password.
3. Bablr makes all User information accessible to its employees, agents or partners and third parties only on a need-to-know basis and binds only its employees to strict confidentiality obligations.
4. Notwithstanding the above, Bablr is not responsible for the confidentiality, security or distribution of your Personal Information by our partners and third parties outside the scope of our agreement with such partners and third parties. Further, Bablr shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond the reasonable control of Bablr including but not limited to, acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the User etc.
5. Except as otherwise provided in this Privacy Policy, we will keep your Personal Information private and will not share it with third parties, unless we believe in good faith that disclosure of your Personal Information or any other information we collect about you is necessary to:
   1. comply with a court order or other legal process;
   2. protect the rights, property or safety of Bablr or another party;
   3. enforce our Terms of Use; or
   4. respond to claims that any posting or other content violates the rights of third-parties.

XIV. Public Information:

Any information that you may reveal in a review posting or other online discussion or forum is intentionally open to the public and is not in any way private. You should think carefully before disclosing any personally identifiable information in any public forum. What you have written may be seen and/or collected by third parties and may be used by others in ways we are unable to control or predict.

XV. Lost or Stolen Information:

You must promptly notify us if your contact data is lost, stolen, or used without permission. In such an event, we will remove that contact data from your account and update our records accordingly.

XVI. Amendment to Privacy Policy:

Bablr may update or make amendment to this Privacy Policy at any time, with or without any prior notice. In the event there are significant changes in the way Bablr treats User’s personally identifiable information, or in the Privacy Policy itself, Bablr will display a notice on the Platform or send Users an email, as provided for above, so that you may review the changed terms prior to continuing to use the Services. As always, if you object to any of the changes to our terms, and you no longer wish to use the Services, you may contact the Grievance Officer using contact details given here to deactivate your account. Unless stated otherwise, Bablr’s current Privacy Policy applies to all information that Bablr has about you and your account. If a User uses the Services or accesses the Platform after a notice of changes has been sent to such User or published on the Platform, such User hereby provides his/her/its consent to the changed terms.

 XVII. Controlling Your Personal Information:

As a registered user of the Services, you can modify some of the Personal Information you have included in your profile or change your username by logging in and accessing your account. Upon your request, Bablr will use commercially reasonable efforts to delete your account and the Personal Information in your profile; however, it may be impossible to remove your account without some residual information being retained by Bablr. Registered Users who wish to close their account should contact the Grievance Officer on Contact details given here.

XVIII. Links to Other Platforms:

If the website contains links to third party Platforms to which Bablr has no affiliation to. Bablr does not share your Personal Information with those Platforms and is not responsible for their privacy practices. Some Platforms may have the look and feel of our Site. Please be aware that you may be on a different site and that this Privacy Policy only covers our Site. A link to a non-Bablr Platform does not constitute or imply endorsement by Bablr. Additionally, we cannot guarantee the quality or accuracy of information presented on non-Bablr Platforms. Should you decide to visit one of these third party Platforms, we suggest that you read its privacy policy.

XIX. Consent to Privacy Policy:

You acknowledge that this Privacy Policy is a part of the Terms & Conditions of Use (ToS)  of the Platform and the other Services, and you unconditionally agree that becoming a User of the Platform and  Product and Services signifies your (a) assent to this Privacy Policy, and (b) consent to Bablr using, collecting, processing and/or disclosing your Personal Information in the manner and for the purposes set out in this Privacy Policy. Your visit to the Platform and use of the Services is subject to this Privacy Policy and the ToS.

-End of Privacy Policy Document-