Sampark Smart Class

Privacy Policy

This Privacy Policy details how Sampark Foundation (hereinafter referred to as "our", "us", "we" or "Sampark", which shall include a reference to our affiliates, associates, sister concerns and other related entities.), collects, stores, uses and/or processes information or data provided by you i.e. individual or entity accessing or using the Services as an end user as defined in clause 1(e) while accessing and/or using the Sampark SmartShala mobile application (hereinafter referred to as "Sampark SmartShala" or “App”) and any service offered on or through Sampark SmartShala and our related websites, services, applications and products (hereinafter referred to as "Services"). For the purposes of this Privacy Policy, "you" and "your" means the end user of the Services, whether a Student (including, where applicable, a parent or legal guardian acting on behalf of a minor child) or a Teacher (including any school, governmental body, or educational institution on whose behalf the Services are accessed or used), who is legally competent and has legal capacity under Applicable Law to enter into a binding agreement.

This Privacy Policy shall be read in conjunction with the Terms of Use available at http://samparksmartshala.org/terms. Your access to and use of Sampark SmartShala and the Services is conditional upon your acceptance of this Privacy Policy and the Terms of Use. All capitalized terms shall have the meaning ascribed to them as defined herein or under applicable law or under Terms of Use. By accessing and/or using Sampark SmartShala and/or the Services, you acknowledge and accept that you have read, understood and are bound by the Terms of Use and this Privacy Policy, and that you explicitly consent to your information and data being collected, stored, used and processed in the manner laid out in this Privacy Policy. It is clarified that Sampark uses You Tube’s API Services. By accessing and/or using Sampark SmartShala and/or the Services, you are agreeing to be bound by the You Tube’s Terms of Service which can be found at https://www.youtube.com/t/terms. Users (individuals or entities) can at their sole discretion and responsibility revoke the Sampark’s access to the API data via the Google security settings page at https://security.google.com/settings/security/permissions. Note that revocation will disable features reliant on this data. For requests to delete previously collected data, contact us at baithak@samparkfoundation.org. Google’s privacy practices are governed by its policies, and Sampark is not responsible for Google’s compliance with the Applicable Data Protection Laws as defined in clause 1.

Definitions
All capitalized terms in this Privacy Policy shall have the meanings assigned herein or in the governing Terms of Use. Any term not so defined shall be interpreted with reference to applicable law and construed contextually (in alignment with this Policy), commercially (in line with industry practice), and legally (in accordance with applicable law and judicial precedents). Defined terms include:
1. “Applicable Law” shall be the law of the territory of India.
2. “Applicable Data Protection Laws” means the Digital Personal Data Protection Act, 2023, as and when it comes into effect, together with the Information Technology Act, 2000 and the rules framed thereunder, and as each may be amended, replaced, or superseded from time to time, including any laws or rules implementing, replacing, or supplementing the foregoing.
3. “Child” means any person who has not attained the age of eighteen (18) years or such other age of majority as may be prescribed under Applicable Law in India.
4. “Legally Competent” means possessing the mental soundness, maturity, and qualifications required under Applicable Law, including the ability to understand the nature and consequences of actions and to validly undertake legal obligations.
5. “Legal Capacity” means meeting the statutory eligibility criteria to enter into, perform, and be bound by a legally enforceable agreement, including having attained the age of at least eighteen (18) years or such other minimum age as may be prescribed under Applicable Law in India, and not being disqualified from contracting by any law in force.
6. "Purposes" means the purposes for which Your Information is collected, used, stored, processed, or disclosed, as specified in Clause 3 of this Privacy Policy, and any related purposes that are reasonably necessary to perform the Services, in compliance with Applicable Data Protection Laws.
7. "Sampark SmartShala" or "App" means the Sampark SmartShala mobile application, including all its content, features, and functionalities, as well as any updates, upgrades, or enhancements thereto, through which the Services are made available.
8. "Sampark", "we", "us", or "our" refers to the Sampark Foundation.
9. “Services” means any service offered on or through Sampark SmartShala and its related websites, applications, platforms, and products, and includes, without limitation: (a) Teach-Easy Kits such as the Audio Box and Sampark Didi; (b) the SmartShala App; (c) Sampark TV; (d) the Sampark Dashboard; (e) Sampark Didi Ke Sawaal; (f) the AI-Driven Speak English Platform; and (g) the Sampark Didi Helpline, together with any updates, enhancements, or related services provided by Sampark Foundation in connection with these tools.
10. “Student” means an individual end user accessing or using the Services for educational purposes, who may be a minor child. In the case of a minor, “Student” shall include and require the consent and representation of a parent or legal guardian who is legally competent and has legal capacity under Applicable Law to enter into a binding agreement on behalf of the child.
11. “Teacher” means an individual end user accessing or using the Services for instructional, training, or administrative purposes, who is legally competent and has legal capacity under Applicable Law to enter into a binding agreement, and where applicable, includes any school, governmental body, or educational institution on whose behalf the Services are accessed or used.
12. “You” or “Your” means the end user of the Services, whether a Student (including, where applicable, a parent or legal guardian acting on behalf of a minor child) or a Teacher (including any school, governmental body, or educational institution on whose behalf the Services are accessed or used), who is legally competent and has legal capacity under Applicable Law to enter into a binding agreement.
  Explanation A Child shall not be a valid end user of the Services in their own capacity; the Services may only be accessed or used on behalf of a Child by their parent or legal guardian, who shall be deemed the end user and shall bear full responsibility for such access and use.
13. "Your Information" means any information relating to you that is collected as specified in Clause 2 of this Privacy Policy, or that is otherwise necessary and limited to the purposes of performing the Services in accordance with this Privacy Policy and the Terms of Use, in compliance with Applicable Data Protection Laws.
Collection of Information
Sampark may collect the following information and data (hereinafter referred to as "Your Information") depending on the extent of use of Sampark SmartShala and/or the Services by you i.e. by both Students and Teachers or other related parties for the purposes set out in this clause and its sub-clauses, as well as for the purposes specified in Clause 3, and, more broadly, to facilitate and enhance the provision of the Services offered through Sampark SmartShala.
1. Phone number - To facilitate opening of a user account, operation and improvement of our Services offered through Sampark SmartShala as well as fraud prevention, security, compliance with the Applicable Laws and management of accounts maintained on the App.
2. Full name - To facilitate opening of a user account, operation and improvement of our Services offered through Sampark SmartShala as well as fraud prevention, security, compliance with the Applicable laws and management of accounts maintained on the App
3. User's Image – Providing the same is voluntary. It is to facilitate identification, operation and improvement of our Services offered through Sampark SmartShala as well as fraud prevention and management of accounts maintained on the App.
4. State - To facilitate operation and improvement of our Services offered through SamparkSmartShala and management of accounts maintained on the App.
5. Pin code - To facilitate operation and improvement of our Services offered through Sampark SmartShala and management of accounts maintained on the App.
6. School Education Board - To facilitate operation and improvement of our Services offered through Sampark SmartShala and management of accounts maintained on the App.
7. School code/ DISE code - To facilitate operation and improvement of our Services offered through Sampark SmartShala and management of accounts maintained on the App.
8. Designation - To facilitate operation and improvement of our Services offered through Sampark SmartShala and management of accounts maintained on the App.
9. Images and/or videos, if you upload any material to Sampark SmartShala - To facilitate operation and improvement of our Services offered through Sampark SmartShala and management of accounts maintained on the App. When you use the Service, we also automatically collect certain technical information about you such as the details of the device you used to access Sampark SmartShala. The information we automatically collect may include (where available) the type and model of device you use, the device's unique device identifier, to allow you to use the Service and for system administration purposes.
Where You (the user of Sampark SmartShala) are a Teacher deployed and utilizing the Services, Sampark Foundation may collect and retain certain additional categories of personal information, which includes:
1. Details of the school where you are employed, including the school's name, location, and your class assignments
2. Contact details such as phone number and email address;
3. School-related details such as school name, location, and class assignments;
4. Confirmation of receipt of kits, devices, or equipment provided by Sampark Foundation;
5. information generated through the use of Sampark-provided tools, including TV/Smart TV syncing status, lesson updates, and related usage logs.;
6. information relating to your presence and involvement in trainings, workshops, school visits, or other programs conducted by Sampark Foundation.;
7. Information submitted for awards or recognition programs (e.g., teacher’s name);
8. Recordings or logs of communications made through authorized third-party call centres, which may include interactions regarding technical support or usage of Sampark-provided tools.;
9. Information shared with vendors solely for delivery, installation, or confirmation of devices or equipment;
10. Photographs or video images captured during meetings, trainings, or functions conducted by Sampark Foundation, without attribution of names or contact details unless otherwise agreed.
It is clarified that as per the Terms of Use, the above information is intended to be provided only by those who are legally competent, to enter into a contract and give consent for their personal information to be collected. All information requested from the user of services for the purposes of logging into, registering on, and/or accessing or using Sampark SmartShala and/or the Services is required to be filled in by those who have the Legal Capacity to enter into a contract and give consent for their personal information to be collected. No personal information is collected with respect to any person below the age of eighteen years who is a child. Parents who log into, register and/or access or use Sampark SmartShala and/or the Services to assist their children who are minor students (i.e. students below the age of eighteen), should enter their own details such as phone number, full name, state and pin code when these details are requested. The responsibility is upon the parents to enter their own credentials to protect the identity of their child. We do not intend or attempt in any manner the collection of personal data of minors.
Use of Information
Sampark shall use Your Information collected in accordance with Clause 2 of the Privacy Policy for the following purposes:
1. Enabling logging in to Sampark SmartShala and providing relevant and useful content to you;
2. Operating, providing and/or improving Sampark SmartShala and our Services and all acts incidental to the same;
3. Debugging errors in Sampark SmartShala and our Services;
4. Analysing and increasing usage of Sampark SmartShala and of the Services;
5. Identifying users of Sampark SmartShala and communicate with them and sharing usage information with third parties as specified in Clause 5 below.
6. To confirm your identity in order to determine your eligibility to access and use Sampark SmartShala and avail the Services;
7. To notify you about any changes to the App, Services, and this Privacy Policy;
8. For the purpose of sending administrative notices, Service related alerts, marketing communications and similar communication from time to time;
9. For internal operations such as market research, troubleshooting, project planning, and devising strategies against fraud and other criminal activity;
10. To enforce the provisions of this Privacy Policy and Terms of Use;
11. To disclose your Personal Information to any of our affiliates or related entities in connection with the operation and management of the Sampark SmartShala and Services in accordance/compliance with applicable laws including the Applicable Data Protection Laws; and
12. To comply with Applicable Laws and legal processes, cooperate with government or law enforcement, protect the safety, rights, property, and security of the Sampark, Sampark SmartShala, our Services, the public, or any third party, and stop or mitigate any illegal, unethical, or legally actionable activities.
13. Where You, the end user of the Sampark SmartShala application, are a Teacher, your information may be collected and utilized for additional purposes connected with the effective delivery of Services. Such purposes include:
  1. To confirm dispatch and receipt of kits or learning materials by checking with teachers directly.
  2. To enable and track syncing of TVs/Smart TVs so that lesson updates and usage of Sampark tools are accurately recorded.
  3. To facilitate school visits by Sampark representatives for conducting trainings, monitoring program delivery, and providing on-ground support.
  1. To include teacher names for award nominations or recognitions, ensuring that only necessary details are shared without personal contact information.
  2. To provide assistance and follow-up support through our authorized thirdparty call centre, which may contact teachers regarding syncing or technical issues and/or take feedback and comments or wishing you on certain special occassions.
  3. To coordinate with vendors responsible for delivery, installation, or confirmation of TVs and related equipment supplied to schools.
  4. To share teacher names with funders, where required under specific programs, limited to confirming their school association and without disclosing sensitive personal details.
  5. To use photographs taken during meetings, trainings, or events for reporting and communication purposes, both internally and externally, with or without attributing names or other identifiers.
  6. To study behaviour of the Students and Teachers to improve the App and Sampark Content, enhance functionality, analyze usage patterns, and personalize your experience. The App may have cookies for the above purposes. While you may disable cookies via app settings, you acknowledge that certain features of the app may become unavailable.
Storage of Information
1. Sampark shall store Your Information collected in accordance with Clause 2 of the Privacy Policy for the duration necessary to fulfil the purposes described in Clause 3. It is clarified that some of these purposes may require Your Information to be stored permanently, such as to facilitate analysis of usage.
2. The collecting agency in respect of Your Information is Sampark. However, Your Information may be stored/retained by Sampark and/or Enzu/AWS infrastructure which offers comprehensive security features, including robust firewall protection, SSL encryption for data in transit, and SHA-256 password encryption, to safeguard such information against potential threats. While such information may be stored on AWS servers, it shall at all times remain the property of, and under the effective control of, Sampark in accordance with Applicable Data Protection Laws and by using the Services, you expressly consent to such collection, storage, retention, processing, and protection measures.
Consent
1. By accessing and/or using Sampark SmartShala and/or the Services, or by otherwise giving us your information you represent that you have read, understood and are bound by the Terms of Use and this Privacy Policy, and that you expressly consent to Your Information being collected, stored, processed and used in the manner laid out in this Privacy Policy and further signify your agreement to this Privacy Policy. If you do not agree to this Privacy Policy, kindly do not use our Services and the Sampark SmartShala, or share any of your information in any manner whatsoever with us.
2. You may:
  1. Review Your Information as provided by you to Sampark;
  2. Send a request to Sampark to correct, complete, amend or update Your Information
  You may do so by contacting us via email at baithak@samparkfoundation.org. We will provide you with further assistance in this regard and guide you through the process. If you contact us, we may keep a record of that correspondence for our internal reference and archival purposes. We will not retain a record of that correspondence for longer than is reasonably necessary as per the Applicable Law and further such retention shall be compliant with the Applicable Data Protection Laws. We reserve the right to seek further details from you in order to ascertain the exact nature of your request. Your request shall not be treated as effective unless the communication is made in the manner described above. Notwithstanding any amendment, update, or correction made pursuant to your request, we may retain Your Information, as it existed prior to and after such amendment, for such period as is necessary to comply with Applicable Law, enforce our rights, resolve disputes, or maintain business records in accordance with lawful retention requirements in a manner compliant with Applicable Data Protection Laws.
3. You may choose to delete your account and/or withdraw your consent for the subsequent use of your personal data by Sampark, by contacting us via email at baithak@samparkfoundation.org. We will provide you with further assistance in this regard and guide you through the process. We reserve the right to seek further details from you in order to ascertain the exact nature of the withdrawal of consent or request for deletion of your account. Withdrawal of consent and/or request for deletion of account shall not be treated as effective unless the communication is made in the manner described above. Once you choose to delete your account or withdraw consent for subsequent use of your personal data by Sampark, you will not be able to reactivate your account or retrieve any of the content you may have uploaded. Further, this may result in Sampark being unable to provide the Services to you. Subject to Applicable Law, if you delete your account or withdraw your consent for the collection, use, storage, processing and disclosure of your Information, we may retain your information as needed to comply with our legal and regulatory obligations, resolve disputes, conclude any activities related to the deletion of an account, to investigate or prevent fraud and other inappropriate activity, to enforce our agreements, and for other business reasons.
Disclosure and Transfer of Information
Sampark may disclose and/or transfer Your Information to its development team in order to fulfil the purposes described in Clause 3 of this Privacy Policy. Other than as provided elsewhere in this Privacy Policy, Sampark does not disclose or transfer Your Information to any other third parties without your consent, unless such disclosure or transfer is:
1. Required in order to comply with any applicable law or court order or direction; or
2. Requested by any appropriate Governmental agency as per applicable law for the purpose of, inter alia, verification of identity, prevention, detection, investigation, prosecution or punishment of any offences or incidents.
3. Is otherwise necessary for the purposes set out in this Privacy Policy (including the performance of the Services), such as to external vendors to fulfil uses as highlighted in clause 3, in which case such disclosure or transfer shall be limited to what is reasonably necessary and shall be carried out in compliance with Applicable Data Protection Laws.
4. We will take reasonable and necessary steps to ensure that your information is treated securely and in accordance with this Privacy Policy; however, we shall not be liable for any transfer or disclosure of Personal Information resulting from failure of third-party service providers, cyber-attacks, acts of terrorism, or any other events beyond the Sampark’s reasonable control.
Security
1. Sampark complies with reasonable security practices and procedures as required by the Applicable Data Protection laws. Specifically, the database containing Your Information is hosted on a separate server with a firewall.
2. However, since complete security cannot be ensured by any entity, please note that Sampark does not guarantee the security of Your Information. Therefore, the use of the App and Services will be at your own risk, and we assume no liability for any collection, storage, use, disclosure etc. of your information due to errors in transmission, unauthorised third-party access or other acts of third parties, or acts or omissions beyond our reasonable control and you agree not to hold Sampark responsible for any breach of security.
3. In the event that Sampark becomes aware of any breach of security such that it affects Your Information, Sampark shall notify you, such as through a notice (for example, via in-app notification or disclaimer message) on Sampark SmartShala and/or other appropriate means, as required under Applicable Data Protection Laws. However, although in all circumstances we will attempt to provide you with a notice of any breach, you are also advised to review this Privacy Policy regularly and to stay informed raise relevant queries/grievances in a manner as detailed in Clause 9 of this Privacy Policy,
4. Sampark claims no responsibility for the security of any third-party links, websites or resources that you may access through or in connection with Sampark SmartShala and/or the Services.
Third Party Websites and Applications
The Service may include and link to features and services (such as social applications like Facebook, YouTube, WhatsApp ) that are provided by a third party. If you use these features and services, please understand that the third parties that operate them may collect information from you which will be used in accordance with their own privacy policy and terms of use, which may differ from ours.

Sampark may, prior to such redirection, display a prompt, pop-up, or disclaimer message informing you that you are leaving the Sampark SmartShala environment and will be subject to the third party’s privacy policy and terms of use. Such third-party policies may differ from ours, and we encourage you to review them carefully before proceeding.
We do not accept any responsibility or liability for these third party policies or for any personal data that may be collected by or through these websites or services. You should always read the privacy policy of any feature or service you access carefully in order to understand the specific privacy and information usage practices. Your Rights
You have the following rights regarding your personal information under the Digital Personal Data Protection Act, 2023 and other applicable privacy laws:
1. You may request confirmation about whether we are processing your personal information and obtain access to such data in our possession. This includes the right to review, correct, complete, or update inaccurate or incomplete information.
2. You may withdraw your consent for future processing of your personal information at any time, provided such withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.
3. Where applicable, you may request your personal data in a structured commonly used, and machine-readable format, and have the right to transmit this data to another entity where technically feasible.
4. In accordance with Section 12 of the DPDPA 2023, you may nominate a legal representative to exercise these rights on your behalf in case of death or incapacity.
5. You may request deletion of your personal information, except where we are required to retain such information to comply with legal obligations, resolve disputes, or enforce our agreements.
6. To exercise any of these rights, please contact our Grievance Officer
Grievance Officer
1. Pursuant to Applicable Data Protection laws ,Sampark has designated the following person as the Grievance Officer:
  Manish Chandak
  Address: B16, Sector-132, Noida-201304, UP
  Email: baithak@samparkfoundation.org
2. In the event that you wish to raise a query or complaint with us, please contact our Grievance Officer who shall acknowledge your complaint within 24 (twenty four) hours from the time of receipt of such complaint. Kindly note that once your complaint is received, we shall use our best efforts to redress it within a period of 15 (fifteen) days from the date of receipt of such complaint.
Changes to the Privacy Policy
We retain the right to amend this Privacy Policy from time to time, for instance when we update the functionality of our Services or when there are regulatory changes. We will undertake efforts to generally notify all users of any material changes to this Privacy Policy, such as through a notice on Sampark SmartShala application (for example, via in-app notification or disclaimer message) and/or other appropriate means, as required under Applicable Data Protection Laws.. However,it is advisable as a user of Sampark SmartShala and/or the Services, you should look at this Privacy Policy regularly to check for such changes. We will also update the "Last Updated" date at the top of this Privacy Policy, which reflects the effective date of this Privacy Policy. Your continued access or use of Sampark SmartShala and/or the Services after the date of the new Privacy Policy constitutes your acceptance of the new Privacy Policy. If you do not agree to the new Privacy Policy, you must stop accessing and/or using Sampark SmartShala and/or the Services. You hereby acknowledge that any collection, storage, processing or other use of Your Information shall be governed by the Privacy Policy as applicable at the time of such collection, storage, processing or other use.

Updated as on 09-09-2025