Privacy Policy

PRIVACY POLICY

UPDATED ON 8 MAY 2025

This Privacy Policy (“Privacy Policy/Policy”) discloses the privacy practices for SpiruTech

Aquacultures LLP (“SpiruTech”, “We/we” or “Us/us”) with regard to collection and use of

the Personal Information (defined hereunder) of the customers, vendors, employees and

the users (“You/you” or “Your/your”) and use of the online platform www.Spirutech.in

(“Website”). This Privacy Policy along with Terms of Use describes our practices

regarding, including your choices in relation to how we collect, store, use, share and

secure your Personal Information across our Website. It also describes your choices

regarding use, access and correction of your Personal Information and your rights in

relation to your Personal Information and how to contact us or supervisory authorities in

the event you have a complaint.

By providing your consent to this Privacy Policy and accepting the Terms of Use, you agree

to the collection, use and transfer of your Personal Information as set out in this Privacy

Policy. If you do not agree with the terms of this Privacy Policy, please do not use/access

this Website.

We will review this Privacy Policy from time to time to make sure it is up to date. If you are

just a visitor, then please note that this Privacy Policy is subject to change at any time

without notice. To make sure you are aware of any changes, please review this Policy

periodically. If you are our registered user, we will notify you before we make changes to

this Policy and give you the opportunity to review the revised Policy before you choose to

continue using our services.

By Personal Information, we mean any information that can either itself identify you as an

individual ("Personally Identifying Information") or that can be connected to you indirectly

by linking it to Personally Identifying Information. Please note that usage of the term

Personal Information in this Privacy Policy includes sensitive personal data or

information, wherever appropriate and/or mandated under applicable laws.

COLLECTION OF INFORMATION

As a visitor, you can browse our Website to find out more about our Website. You are not

required to provide us with any Personal Information as a visitor. When you visit the

Website, we collect and store certain information to improve security, analyze trends and

administer the Website with a view to assist us in improving customer experience. We

use this information to evaluate traffic patterns on our Website so that we can make it

more useful to our visitors.

We collect your Personal Information when you register with us, when you express an

interest in obtaining information about us or our products and services, when you

participate in activities on our Website or otherwise contact us.

We will only collect your Personal Information if we have a proper reason for doing so,

e.g.: to comply with our legal and regulatory obligations; for the performance of our

contract with you or to take steps at your request before entering into a contract; for our

legitimate interests (where permitted by law) or those of a third party; or where you have

given consent.

In some cases, we may also have a legal obligation to collect Personal Information from

you or may otherwise need the Personal Information to protect your vital interests or

those of another person (for example, to prevent payment fraud or confirm your

identity.)

Our primary goal in collecting your Personal Information is to provide you a safe, efficient,

smooth, and customized experience. This allows us to provide courses, study material,

tutorials that most likely meet your needs and to customize our Website to make your

experience safer and easier. We also use your Personally Identifiable Information

together with other information to help us better understand our users and to improve the

content and functionality of our Website. The information we learn from you helps us

personalize and continually improve your experience at our Website. We do not

voluntarily make this information available to third parties, nor do we use it for any other

purpose, except as set out herein.

When you visit our Website, as part of a purchase of one of our courses or registering on

our Website, we may collect a variety of Personal Information that you will voluntarily

provide to us via one of our contact forms, via a chat or phone session, such as:

• Contact Information, such as name, email address, display picture, mailing

address, phone number, IP address, geographic location, or phone number.

• Information to enable us to check and verify your identity, e.g., your date of birth,

mark-sheets, Passport/Aadhar/Voter ID details.

• Billing Information, such as debit card number, credit card number and billing

address.

• Unique Identifiers, such as username or password.

• Reviews or ratings, syllabus and course preferences, account settings, (including

preferences set in the " Account " section of our Website); and

• Information provided to us through our service, interaction with our customer

service, participation in surveys or marketing promotions.

If you are an employee of SpiruTech, we collect the following Personal Information:

• name

• address

• email address

• contact number

• date of birth

• gender

• Pan card number

• Aadhar number

• Passport number

• marital status

• nationality

• details of family members and dependants

• bank account details

• education details

• blood group

We collect information about you and your use of our service, your interactions with us

as well as information regarding your computer or other device used to access our

service. This information includes your activity on our Website, such as classes, study

materials, courses and search queries; details of your interactions with customer service

, such as the date , time and reason for contacting us, transcripts of any chat

conversations, and if you call us , your phone number and call recordings; device IDs or

other unique identifiers, device and software characteristics (such as type and

configuration), connection information, statistics on page views , referring source (for

example, referral URLs), IP address (which may tell us your general location), browser

and standard web server log information, information collected via the use of cookies,

web beacons and other technologies.

With the help of backend applications, we aim at providing better services and better

interaction with teachers, depending on the beneficiary’s line of interest. We also may

ask for this information at other times, such as when you enter contests or other

promotions sponsored by us and/or our partners.

If you use a feature that requires payment of a fee options like NEFT, or Card will appear.

In case of payments via credit or debit card, we will redirect you to registered payment

gateways such as phonepe, razorpay, ccavenue, payubiz and other such registered

gateways. You may store and save your payment details like card numbers with the

gateway. We do not have access to this data. All payment transactions are processed

through secure payment gateway providers. We do not store any card information (other

than the last 4 digits of your card) in our servers.

When you use one of our paid products, we track the web pages, and information that

has been accessed by you, and store it on our servers. This enables us to track items that

you have completed, and those that you need to see.

The user's full name and his/her display picture can be publicly displayed on the Website.

Depending on what profile and what services they are seeking, SpiruTech can ask for

more information relating to address, billing information, certificates, past employment

information etc.

SpiruTech can use technologies such as cookies, clear gifs, log files, and flash cookies

for several purposes, including to help understand how you interact with our Website and

services, to provide a better experience.

USAGE AND RETENTON OF INFORMATION

We use the Personal Information we collect, where it is necessary to deliver the services

you have requested, where it is necessary to exercise or comply with legal rights or

obligations or for normal business purposes of the kind set out in this Policy.

We will use your Personal Information to provide, analyze, administer, and improve our

services, to provide you with a personalized experience on our Website (especially, by

offering you services that is best suited for you), to contact you about your account and

our services, to provide you customer service, to provide you with personalized marketing

and to detect, prevent, mitigate and investigate fraudulent or illegal activities.

We further use your Personal Information to determine your general geographic location,

provide localized courses and classes, provide you with customized and personalized

study material, recommendations, determine your internet service provider, and help us

quickly and efficiently respond to inquiries and requests and enforcing our terms (such

as determining free trial eligibility) and communicate with you concerning our service

(for example by email, push notifications, text messaging ,and online messaging

channels), so that we can send you details about new features and content available on

the Website, special offers, promotional announcements, surveys, and to assist you with

operational requests such as password reset requests.

If you are an employee, we use your Personal Information for purposes of payrolling and

recording attendance, deduction of taxes, payment of remuneration, providing employee

benefits (including making contributions to the provident fund, procuring medical

insurance, etc.).

If you are a vendor/supplier, we use your Personal Information and for the purpose of

making payments and deducting taxes.

SpiruTech is a community. We offer several features that allow members to connect and

communicate in public or semi-public spaces, such as Forums and Teams. Please be

sensible and judge before posting in these community spaces or sharing your Personal

Information with others on SpiruTech. Be aware that any Personal Information you submit

there can be read, collected, or used by others, or could be used to send you unsolicited

messages.

SHARING AND DISCLOSING PERSONAL INFORMATION

We use other companies, agents, or contractors ("Service Providers") to perform services

on our behalf or to assist us with the provision of services to you. We engage Service

Providers to provide marketing, advertising, communications, infrastructure, and IT

services, to personalize and optimize our service, to process credit card transactions or

other payment methods, to provide customer service, to collect debts, to analyze and

enhance data (including data about users’ interactions with our service), and to process

and administer consumer surveys. In the course of providing such services, these Service

Providers may have access to your Personal Information or other information. We do not

authorize them to use or disclose your Personal Information except in connection with

providing their services.

If you are an employee, vendor/supplier of SpiruTech, your Personal Information may be

shared internally with the relevant departments on a need-to-know basis.

If you are a user of SpiruTech services, your personal information such as information

related to name, testimonials, scores obtained and all the relevant details pertaining to

the competitive examination(s) pursued or to be pursued in future by user, may be shared

in any and all forms of media, including but not limited to Social media, TVC, Digital

space, hoardings, interviews, LIVE talks and in our mobile app and websites. The parent/

guardian for and on behalf of the user, consents to share and disclose personal

information mentioned hereinabove, for promoting user’s success and for the purpose of

commercial, promotional publicity, business plan/strategy of SpiruTech.

Note to our customers in Europe: We transfer your Personal Information from the

European Economic Area and Switzerland to India. By submitting your data and/or using

our services, you consent to the transfer, storing, and processing of your Personal

Information in India.

SECURITY

We shall try to take all precautions to protect the Personal Information both online and

offline. We will try to protect your information using technical and administrative security

measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and

alteration. We have standard SSL certification which basically helps us create a secure

connection between our server and user to render any information or action. Some of the

safeguards we use are firewalls and data encryption, physical access controls to our data

centers and information access authorization controls. Only user passwords are

encrypted in 64-bit encryption and stored because generally users use the same

password on multiple sites, to prevent any kind of theft, piracy, or unauthorized access.

If you believe your account has been abused or hacked, please contact us by sending us

an email at grievance@Spirutech.in.

We do not sell, transfer, or rent your Personal Information to third parties for their

marketing purposes without your explicit consent and we only use your information as

described in the Privacy Policy. We view protection of your privacy as a very important

community principle. We understand clearly that you and your Personal Information is

one of our most important assets.

We store and process your Personal Information on computers located in India that are

protected by physical as well as technological security devices. We use third parties to

verify and certify our privacy principles. If you object to your Personal Information being

transferred or used in this way, please do not accept this Privacy Policy.

Under no circumstances, we rent, trade, transfer or share your Personal Information that

we have collected with any other company for their marketing purposes without your

consent. We reserve the right to communicate your Personal Information to any third

party that makes a legally compliant request for its disclosure.

KEEPING YOUR PERSONAL INFORMATION SECURE

We have appropriate security measures to prevent your Personal Information from being

accidentally lost or used or accessed unlawfully. Processing your Personal Information

will be done only in an authorized manner and subject to a duty of confidentiality. We also

have procedures in place to deal with any suspected data security breach. We will notify

you about any applicable regulator of a suspected data security breach where we are

legally required to do so.

Notwithstanding anything contained anywhere in this Policy; we cannot assure absolute

security to your Personal Information and by entering or by logging into our Website, you

explicitly agree not to sue us for any data breach.

COOKIES

We transfer cookies, which are small files containing a string of character, to your IP

address, giving the browser distinct identification, to keep track of the user’s preferences.

Furthermore, these files also help in logging-in faster and they act as a mechanism to

determine user trends. The data thus retrieved from the user’s IP address, enables us to

enhance our offers, including but not limited to more content in areas of greater interest

to most users.

Our Website uses "Cookies" to identify the areas of our Website that you have visited. A

Cookie is a small piece of data stored on your computer or mobile device by your web

browser. We use Cookies to personalize the Content that you see on our Website. Most

web browsers can be set to disable the use of Cookies. However, if you disable Cookies,

you may not be able to access functionality on our Website correctly or at all. We never

place Personally Information in Cookies.

THIRD PARTIES AND LINKS

We may pass your details to other companies in our group. We may also pass your details

to our agents and subcontractors to help us with any of our uses of your data set out in

our Privacy Policy. For example, we may use third parties to assist us with delivering

services to you, to help us to collect payments from you, to analyse data and to provide

us with marketing or customer service assistance.

We may exchange information with third parties for the purposes of fraud protection and

credit risk reduction. We may transfer our databases containing your Personal

Information if we sell our business or part of it. Other than as set out in this Privacy Policy,

we shall NOT sell or disclose your Personal Information to third parties without obtaining

your prior consent unless it is necessary for the purposes set out in this Privacy Policy or

unless we are required to do so by law. The Website may contain advertising of third

parties and links to other sites or frames of other sites. Please be aware that we are not

responsible for the privacy practices or content of those third parties or other sites, nor

for any third party to whom we transfer your data in accordance with our Privacy Policy.

Our Website may contain links to other websites that are not under our direct control.

These websites may have their own policies regarding privacy. We have no control of or

responsibility for linked websites and provide these links solely for the convenience and

information of our visitors. You are accessing such linked websites shall be at your own

risk. These websites are not subject to this Privacy Policy. You should check the privacy

policies, if any, of those individual websites to see how the operators of those third-party

websites will utilize your personal information. In addition, these websites may contain a

link to websites of our affiliates. The websites of our affiliates are not subject to this

Privacy Policy, and you should check their individual privacy policies to see how the

operators of such websites will utilize your personal information.

CONSULTING

We use third parties to help us provide services to You including the fulfilment of service,

processing of payments, monitoring site activity, conducting surveys, maintaining our

database, administering emails, and administering contents, and to provide aggregate,

comparative information on the performance of our Website to us and a select group.

CHOICE

It is open for you to customize our usage of your personal information to communicate

with you, to send you marketing information, how we provide you with customized and

relevant advertising, and whether you want to stay signed into your account.

If you do not wish to receive marketing communications from us, you can unsubscribe

from the link in the email you would receive or change your communication preferences

or indicate your communication preferences. You can also reach us via chat, WhatsApp,

call or email to block promotional communication to you. Keep in mind, we do not sell or

rent your personal information to third parties for their marketing purposes without your

explicit consent.

OWNERSHIP OF RIGHTS

All rights, including copyright, in this Website are owned by or licensed to us. Any use of

this Website or its

contents, including copying or storing it or them in whole or part, other than for your own

personal, non-commercial use is prohibited without our permission. You are prohibited

from modifying, copying, distributing, transmitting, displaying, printing, publishing,

selling, licensing, creating derivative works or using any content available on or through

our Website for commercial or public purposes. You may not modify, distribute or re-post

something on this Website for any purpose.

The Site contains copyrighted material, trademarks, and other proprietary information,

including, but not limited to, text, software, photos, video, graphics, music, sound, and

the entire contents of SpiruTech is protected by copyright as a collective work under the

applicable copyright laws. SpiruTech owns a copyright in the selection, coordination,

arrangement, and enhancement of such content, as well as copyright or license to use in

the content original to it. You may not modify, publish, transmit, participate in the transfer

or sale, create derivative works, or in any way exploit, any of the content, in whole or in

part. You may download / print / save copyrighted material for your personal use only.

Except as otherwise expressly stated under copyright law, no copying, redistribution,

retransmission, publication, or commercial exploitation of downloaded material without

the express permission of SpiruTech is permitted. If copying, redistribution, or

publication of copyrighted material is expressly permitted by SpiruTech, then no changes

in or deletion of author attribution, trademark legend or copyright notice shall be made.

You acknowledge that you do not acquire any ownership rights by downloading

copyrighted material. Trademarks that are located within or on our Website or a website

otherwise owned or operated in conjunction with SpiruTech shall not be deemed to be in

the public domain but rather the exclusive property of SpiruTech, unless such site is

under license from the trademark owner thereof in which case such license is for the

exclusive benefit and use of SpiruTech, unless otherwise stated.

SpiruTech does not have any express burden or responsibility to provide you with

indications, markings, or anything else that may aid you in determining whether the

material in question is copyrighted or trademarked. You shall be solely liable for any

damage resulting from any infringement of copyrights, trademarks, proprietary rights or

any other harm resulting from such a submission. By submitting material to any public

area of the Website, you warrant that the owner of such material has expressly granted

SpiruTech the royalty-free, perpetual, irrevocable, non-exclusive right and license to use,

reproduce, modify, adapt, publish, translate and distribute such material (in whole or in

part) worldwide and/or to incorporate it in other works in any form, media or technology

now known or hereafter developed for the full term of any copyright that may exist in such

material. You also permit any other end user to access, view, store or reproduce the

material for that end user's personal use. You hereby grant SpiruTech, the right to edit,

copy, publish and distribute any material made available on the Website by you. If you

come across any abuse or violation of these Terms, please report to vcare@Spirutech.in

YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION COLLECTED BY US

You have the right to withdraw your consent at any time in writing by sending an e-mail to

us at info@spirutech.in, in accordance with the terms of this Privacy Policy. However,

please note that withdrawal of consent will not be retrospective in nature and shall be

applicable prospectively.

You may write to us at info@spirutech.in to access, review, modify or correct your

Personal Information or withdraw your consent to provide Personal Information. We are

not responsible for the authenticity of the information provided by you.

You agree and acknowledge that Your right to access, modify and/or withdrawing Your

consent to provide Personal Information as mentioned above may be denied or limited

by us, as may be required under any applicable law, law enforcement requests or under

any judicial proceedings.

CONDITIONS OF USE

Licensee does not warrant that this Website, its servers, or email sent by us or on our

behalf are virus free. We will not be liable for any damages of any kind arising from the

use of this Website, including, but not limited to compensatory, direct, indirect,

incidental, punitive, special, or consequential damages, loss of data, goodwill, business

opportunity, income or profit, loss of or damage to property and claims of third parties.

DATA PROTECTION OFFICER

Any discrepancies and grievances with respect to processing of Personal Information

shall be informed to the designated Data Protection Officer as mentioned below:

Name : Gaurav Kumar

Designation : Director Operations

Email ID : gauravkumar@spirutech.in

CONSENT TO THE POLICY

The Terms of Use Agreement is incorporated herein by reference in its entirety.

GENERAL

Modification:

We may at any time modify the Terms of Use of our Website without any prior notification

to you. Should you wish to terminate your account due to a modification to the Terms or

the Privacy Policy, you may do so email us at grievance@Spirutech.in. However, if you

continue to use the service you shall be deemed to have agreed to accept and abide by

the modified Terms of this Website.

Privileged/Exclusive Service:

By having a SpiruTech account, you have explicitly given consent for us to capture images

(followed by analysis), camera/mic permissions to make video calls and record the

same.

SpiruTech May Disclose Information:

• as required by law, such as to comply with a subpoena, or similar legal process;

• to enforce applicable ToU (Terms of Use), including investigation of potential

violations thereof;

• when we believe in good faith (doctrine of uberrima fides) that the disclosure is

necessary to protect our rights, protect your safety or the safety of others,

investigate fraud, address security or technical issues or respond to a government

request;

• with our trusted service providers who work on our behalf and do not have an

independent use of the information we disclose to them and have agreed to and

adhered to the rules set forth in this

Policy:

• to protect against imminent harm to the rights, property or safety of the

Application/Website or our users or the public as required or permitted by law;

• with third party service providers in order to personalize the

Application/Website/Services/products for a better user experience and to

perform behavioral analysis;

• internally with the relevant departments to facilitate payments of salary,

deduction of taxes, procuring medical insurance, etc.

Governing Law and Jurisdiction:

In the event of any dispute arising between the parties with respect to this Agreement,

the same shall be referred to the Sole Arbitrator and the arbitration shall be in accordance

with Arbitration and Conciliation Act of 1996. The language of arbitration proceedings

shall be English. The seat and place of arbitration shall be Dehradun and the decision of

the Arbitrator shall be final and binding on both parties herein.

This contract shall be subject to the exclusive jurisdiction of courts in Dehradun,

Uttarakhand, India and shall be governed by the Indian laws.