Privacy Policy

Effective Date: October 26, 2025
Last Updated: October 26, 2025
Version: 2.2

1. INTRODUCTION AND COMMITMENT TO PRIVACY
Straightegy Consulting ("company", "we", "us", or "our") is committed to protecting the privacy and personal data of all users of our digital educational platform at https://www.straightegy.com ("Platform") and our "Ready for the Real World" educational programs ("Services").
This Privacy Policy explains how we collect, use, process, store, and protect your personal information in compliance with the Digital Personal Data Protection Act, 2023 ("DPDP Act"), Consumer Protection Act, 2019, Information Technology Act, 2000, and other applicable Indian laws.
By accessing or using our Platform and Services, you acknowledge that you have read, understood, and agree to this Privacy Policy. If you do not agree, you may not use our Platform or Services.

2. DEFINITIONS
Personal Data means any data about an individual who is directly or indirectly identifiable.
Sensitive Personal Data includes passwords, financial information, health data, biometric information, and other data specified under applicable laws.
Child or Minor means any individual under the age of 18 years.
Data Principal means the individual to whom personal data relates.
Data Fiduciary means Straightegy Consulting, who determines the purpose and means of processing personal data.
Processing includes collection, recording, organization, storage, use, disclosure, and erasure of personal data.
Referral Partner means any party through which you may reach our platform, including schools, colleges, educational institutions, affiliate websites, social media influencers, and third-party business partners.
Referral Code means a unique identifier assigned to Referral Partners to track enrollment attribution.

3. DATA CONTROLLER INFORMATION
Data Fiduciary Details:
Name: Straightegy Consulting
Email: contact@straightegy.com
Grievance Officer: grievance@straightegy.com
Data Protection Officer: Contact details provided upon appointment as required under DPDP Act

4. INFORMATION WE COLLECT
4.1 Our Data Minimization Approach
We have adopted a parent-focused data collection model to simplify compliance and protect privacy:
We collect personal data primarily from parents/guardians purchasing and managing the educational program.
We do NOT routinely collect personal data from children under 18 years of age.
4.2 Personal Information Collected from Parents/Guardians
Account Information:
• First and last name
• Email address
• Phone number
• Date of birth (verified through India's DigiLocker system to confirm you are 18+ years)
Payment Information:
• Billing address (if required by payment processor)
• Payment method details (processed securely through Razorpay)
• Transaction history and purchase records
Educational Profile Information:
• Program tier purchased (Foundations, Explorer, Navigator, or Master)
• General age group or grade level information (no child identification required)
• Course preferences and learning objectives
Communication Data:
• Platform messages
• Customer service interactions
• Feedback and survey responses
Technical Information:
• IP address
• Device information, browser type, operating system
• Platform usage metrics and engagement data
4.3 Optional Child Information for Certificates
If you wish to receive a personalized certificate bearing your child's name, you may optionally provide:
• Child's first name
• Child's last name (optional)
Important: Providing your child's name is entirely optional. If not provided, we issue certificates addressed to you as the parent/guardian. This minimal child data is stored securely, used solely for certificate generation, and you can request deletion at any time.
4.4 What We Do NOT Collect from Children
• Personal identifying information (unless optionally provided for certificates)
• Email addresses or phone numbers
• Biometric information
• Precise location data or GPS coordinates
• Behavioral tracking data across platforms
• Social media account information
• Financial information
• Any sensitive personal data
4.5 Referral and Affiliate Referral Data
When you enroll through a Referral Partner:
Referral Source Information:
• Referral Partner name and unique code
• How you learned about our program
• Date and source tracking
Referral Program Tracking Data:
• Referral code applied at enrollment
• Aggregate enrollment counts per Referral Partner
• Commission calculation data (maintained separately from personal data)
Important Clarifications:
• Referral Partners do NOT process, store, or access your personal data
• They receive only aggregate counts (e.g., "25 enrollments via your code")
• You provide consent directly to Straightegy Consulting only
• Referral Partners act as referral sources, not data processors
• Your personal data remains exclusively with Straightegy Consulting
Technical Tracking Methods:
• Unique referral codes
• UTM parameters in links
• Coupon codes
• Cookie-based attribution (non-personally identifiable)

5. HOW WE COLLECT INFORMATION
5.1 Direct Collection
• Registration forms
• Payment processing
• Customer support interactions
• Surveys and feedback
• Optional certificate name requests
5.2 Automatic Collection
• Platform analytics (aggregate only)
• Technical logs for platform improvement
• Security monitoring
• Referral tracking
5.3 Third-Party Sources
• Payment processors (Razorpay)
• Identity verification (Aadhaar via DigiLocker)
• Analytics services (Google Analytics and others)
• Referral partner platforms
5.4 Special Protections for Child Data
• No behavioral tracking
• No profiling
• No advertising use
• Full parental control and deletion rights
• Minimal collection (name only, if provided)
• Enhanced security measures

6. LEGAL BASIS FOR PROCESSING
6.1 For Parent/Guardian Data
• Consent: Explicit consent during registration
• Contract Performance: Providing purchased services
• Legitimate Interests: Platform improvement, fraud prevention, referral program operation
• Legal Obligations: Compliance with Indian laws
6.2 For Optional Child Data
• Explicit Consent: Specific consent for certificate personalization
• Limited Purpose: Certificate generation only
• Easy Withdrawal: Deletion available at any time
6.3 Consent Verification Process
• Age verification through DigiLocker (18+ years)
• Clear explanation of data processing
• Active consent required (no pre-checked boxes)
• Consent recording with timestamps
• Simple withdrawal mechanisms

7. HOW WE USE INFORMATION
7.1 Primary Educational Purposes
• Service delivery through parent account
• Progress tracking
• Parent communications
• Customer support
• Certificate issuance (if name provided)
7.2 Referral Program Operations
• Enrollment attribution (linked to parent account, not child)
• Commission calculation based on enrollment volume
• Aggregate reporting to Referral Partners
• Referral management communications
Data Use Limitation: Your personal data is NEVER used for commission calculation or shared with Referral Partners. Commission is based solely on aggregate enrollment counts tracked via referral codes.
7.3 Platform Improvement
• Course development based on aggregate patterns
• Technical improvements
• Quality assurance
• Security enhancements
7.4 Legal and Security Purposes
• Compliance with laws
• Fraud prevention
• Safety protection
• Record keeping per tax regulations
7.5 Marketing (Adults Only, With Consent)
• Educational updates
• Platform news
• Industry insights
• Referral program information
Limitation: No marketing communications sent to children. All communications directed to parent/guardian with opt-out available.

8. INFORMATION SHARING AND DISCLOSURE
8.1 No Sale of Personal Data
We do not sell, rent, or trade any personal information to third parties. This is absolute for all users.
8.2 Limited Sharing with Service Providers
Payment Processing (Razorpay):
Payment information, billing address, transaction details for processing payments and commission distributions. PCI-DSS compliant with secure encryption.
Platform Hosting (Wix):
Account information for platform functionality. Data processing agreements and security certifications in place.
Analytics (Google Analytics, Wix, Meta, Others):
Aggregate usage patterns only, no individual identification. IP anonymization and aggregate reporting only.
Affiliate Tracking:
Referral codes and aggregate enrollment counts only (NO personal data shared with Referral Partners). Encrypted transmission with access logs maintained.
Automated Commission Payment (Razorpay Route):
Referral Partner bank details, commission amounts, payment dates. Banking-grade encryption, no personal parent or child data included. Audit trail maintained for 7 years per tax law.
Influencer and Affiliate Platform Integration:
Referral codes and aggregate counts only. Secure API connections, encrypted transmission, no cross-sharing between partners.
8.3 Legal Disclosure Requirements
We may disclose information when required by law:
• Court orders or legal process
• Data Protection Board requirements
• Child safety reporting (if aware through your communications)
• Lawful government requests
8.4 Referral Partner Data Sharing
What Referral Partners Receive:
• Aggregate enrollment count
• Commission calculation details (aggregate only)
• Payment dates and transaction references
• General program metrics (aggregate)
What Referral Partners DO NOT Receive:
• Parent or child names
• Contact information
• Individual learning progress
• Any personal or identifying information
• Individual usage patterns
• Dashboard access
Referral Partner Legal Status:
Referral Partners are NOT Data Processors under DPDP Act. They do not determine processing purpose or means, cannot request or access personal data, and have no data processing relationship with Straightegy Consulting.
Data Separation:
Educational data → Straightegy Consulting only
Financial data (commission) → Aggregates only
Personal data → Straightegy Consulting only, never shared

9. DATA SECURITY AND PROTECTION
9.1 Technical Safeguards
• Password-based authentication
• Firewalls and intrusion detection
• SSL/TLS encryption (transit and rest)
• Regular security updates
• Vulnerability testing
9.2 Organizational Safeguards
• Staff training on privacy and security
• Limited access to personal data
• Confidentiality agreements
• Incident response procedures
• Regular policy reviews
9.3 Enhanced Security for Child Data
• Stricter access controls
• Parental monitoring rights
• Immediate breach notification to parents
9.4 Data Breach Response
• Immediate assessment
• Authority notification within 72 hours
• User notification without unreasonable delay
• Parental priority for child data
• Remedial action and support services

10. DATA RETENTION AND DELETION
10.1 General Retention
• Active Accounts: Retained while active
• Inactive Accounts: Deleted after 2 years of inactivity
• Payment Records: 7 years (Indian tax law requirement)
• Support Records: 3 years
• Referral Records: 7 years (tax law requirement)
10.2 Child Data Retention
• Immediate Deletion: Upon your request at any time
10.3 Referral Data Retention
• Referral attribution: 7 years (Income Tax Act requirement)
• Commission records: 7 years (tax audit requirements)
• Partnership termination: Enrollment linkage anonymized after 7 years
Note: Referral data retention does NOT extend your personal data retention periods.
10.4 Deletion Process
• Secure deletion using industry-standard methods
• Backup removal
• Confirmation provided upon request
• Deletion activities logged
• Child data deletion prioritized

11. YOUR RIGHTS UNDER DPDP ACT 2023
11.1 Rights for All Users
• Right to Information: Know what data we collect and why
• Right of Access: Obtain copy of your data
• Right to Correction: Correct inaccurate data
• Right to Erasure: Request deletion
• Right to Nominate: Nominate representative for rights exercise
11.2 Enhanced Rights for Child Data
• Know what child information we hold
• Access any child data
• Delete child's name anytime
• Correct child's name if misspelled
• File complaints with Data Protection Board
11.3 How to Exercise Rights
• Contact: grievance@straightegy.com
• Identity Verification: Required for security
• Response Timeline: Within 30 days (faster for child data)
• No Charges: Most requests processed free
• Appeal Process: Available through regulatory authorities

12. PARENTAL CONTROLS AND DATA MANAGEMENT
12.1 Parental Rights
• Full consent management control
• Data access for parent and child information
• Profile management
• Communication control
• Account supervision
• Certificate personalization decisions
12.2 Account Management Process
1. Age verification (DigiLocker, 18+ years)
2. Account creation
3. Informed consent
4. Active acceptance of policies
5. Program selection
6. Optional certificate name (separate consent)
7. Ongoing access and control
12.3 Child-Friendly Privacy Measures
We design our services with child safety and privacy in mind:
• Minimal Data Collection: We collect minimal information about children (only optional name for certificates)
• Parent-Controlled Access: All course access managed through your parent account
• No Direct Child Contact: We do not communicate directly with children; all communications go to you
• No Tracking: Zero behavioral tracking of children across websites or platforms
• Educational Focus: All data processing limited to educational purposes
• Safe Dashboard Environment: The learning dashboard is free from direct marketing, advertisements, or promotional content targeted at children
• General Website Access: While the learning dashboard contains only educational materials suitable for children, other areas of our website (outside the dashboard) may contain general information, promotional content, or offers primarily intended for parents and adult audiences. We do not target children with marketing materials on our website, but we cannot control which member of your household browses different website areas while logged in.
• Parental Supervision Responsibility: You are responsible for supervising your child's use of our platform and ensuring they remain within the learning dashboard for their educational activities. We recommend guiding children to access only the dashboard and not other website areas that contain adult-oriented or promotional content.

12.4 What We Don't Do with Child Data
• No Marketing to Children: Zero marketing communications directed at children or using child data for marketing purposes
• No Profiling: No creation of behavioral profiles or personality assessments of children
• No Selling: Never sell or monetize any child information
• No Social Sharing: No integration with social media platforms for children
• No Location Tracking: No collection of children's location information
• No Biometrics: No collection of biometric data from children
• No Referral Partner Sharing: Referral Partners do not receive any child information
• Minimal Collection: Only optional name for certificates if you choose to provide it
• Dashboard Content: The learning dashboard accessed by children contains only educational materials and is free from marketing, advertisements, or promotional targeting directed at children
• Website Content Notice: Other areas of our website accessible while logged in may contain content intended for parents and adults. We do not monitor or restrict which household member accesses which website areas, and we are not responsible for content accessed outside the learning dashboard. Parents should supervise children's browsing and guide them to remain within the dashboard environment.

12.5 Platform Architecture and Content Separation
Learning Dashboard (Child-Appropriate):
• Contains only educational videos, quizzes, downloadable resources, and certificates
• Free from advertisements, banners, pop-ups, or promotional content
• Designed specifically for child users with parental supervision
• No external links or third-party content (except curated educational resources)
General Website Areas (Adult/Parent-Oriented):
• May contain program information, pricing details, promotional offers, and marketing content
• Intended for parents, guardians, educators, and adult decision-makers
• May include testimonials, case studies, partnership information, and enrollment details
• May feature general digital safety articles, blog posts, and educational resources for parents
Access and Responsibility:
• We do not technically restrict logged-in users from navigating between dashboard and general website areas
• We assume and require that parents supervise their children's platform use per our Terms and Conditions
• We are not responsible for content viewed outside the designated learning dashboard
• Parents should ensure children access only the dashboard and not promotional or adult-oriented website sections
No Targeted Marketing to Children:
• We do not use cookies, tracking, or behavioral analysis to market to children
• We do not serve advertisements within the learning dashboard
• We do not use child data to create marketing profiles or send promotional messages
• Any promotional content on our general website is not targeted at or intended for children

13. COOKIES AND TRACKING TECHNOLOGIES
13.1 Types of Cookies
Essential Cookies (Cannot be disabled):
• Session management
• Security tokens
• Load balancing
• Language preferences
Analytics Cookies (Can be disabled):
• Aggregate platform usage
• Performance monitoring
• Error logging
Referral Attribution Cookies (Can be disabled):
• Track Referral Partner source
• 30-day cookie lifespan
• Commission attribution only
• No personal data stored
• Cookies: utm_source, utm_medium, utm_campaign, referral_code, affiliate_id
Data Collected: Which Referral Partner link clicked, date/time, enrollment status
Data NOT Collected: Browsing history, personal information, location, child information
13.2 Cookie Management
• Browser settings configuration
• Platform account settings
• Analytics opt-out links available
• Parental control over all settings

14. INTERNATIONAL DATA TRANSFERS
14.1 Data Hosting and Global Data Flows
Straightegy Consulting uses trusted global service providers for hosting and processing. Some personal data may be transferred and processed outside India due to global infrastructure requirements.
Service providers include:
• Wix.com (website hosting, multiple global regions)
• Google LLC (analytics, email, cloud integrations)
• Meta Platforms (advertising, audience analytics)
• Razorpay Software Pvt. Ltd. (payment processing, India)
• Other global SaaS providers
14.2 Legal Safeguards for International Transfers
• Security-by-design measures (encryption in transit and at rest)
• Minimization of personally identifiable data shared
• Third-party processors limited to necessary service delivery only
• Continuous review of partner data practices
• Alignment with ISO 27001 and GDPR-equivalent standards
14.3 Data Localization for Payment Information
Payment data (Razorpay transactions) is processed and stored in India per Reserve Bank of India (RBI) and PCI-DSS standards. No payment or financial data is transferred internationally.
14.4 User Rights on Data Transfers
• Request clarification on data storage locations
• Withdraw consent by discontinuing services

15. MARKETING AND COMMUNICATIONS
15.1 Marketing to Adults
• Educational updates
• Platform news
• Industry insights
• Special offers
• Referral program information
• Affiliate opportunities (if applicable)
15.2 Parental Communications
• Progress reports
• Platform updates
• Course completions and milestones
15.3 Communications to Referral Partners
• Program updates
• Referral performance reports
• Marketing materials
• Partner announcements
• Business opportunities
Referral Partner personal data (name, email, bank details) used only for partnership administration and commission payments. Opt-out available for non-essential communications.
15.4 No-Marketing Policy to Children
We do not:
Direct Communications: Send any communications directly to children
Data for Marketing: Use any child data (if provided for certificates) for marketing purposes
Marketing Partners: Share any child information with marketing partners
Marketing Profiles: Create marketing profiles of children
Targeted Promotions: Target children with promotional content of any kind
Dashboard Marketing: Include any marketing, advertising, or promotional content within the learning dashboard
All communications related to your child's learning are sent to you as the parent/guardian.
Website Content Clarification:
While we do not market to children, our general website (accessible outside the learning dashboard) contains content intended for parents and adults, including promotional information about our programs, pricing details, partnership opportunities, and educational resources for parents. This content is not directed at or targeted toward children.
Parents are responsible for supervising their children's online activity and ensuring children remain within the appropriate dashboard environment for their educational experience. We recommend instructing children to access only the dashboard and not browse other website areas that may contain adult-oriented promotional or informational content.
Straightegy Consulting is not responsible for content accessed by children outside the dedicated learning dashboard when parental supervision is not adequately provided.
15.5 Communication Preferences
• Opt-in required for marketing
• Granular control over communication types
• One-click unsubscribe
• Essential communications continue (security, billing, updates)
• Preference management via account settings

16. THIRD-PARTY LINKS AND SERVICES
16.1 Educational Resource Links
• Curated for educational value and safety
• No personal data shared with linked sites
• Parental awareness of external resources
• Parental supervision recommended
16.2 Third-Party Privacy Policies
• Independent policies apply to third-party sites
• Your responsibility to review before sharing data
• No liability for third-party practices
16.3 Service Provider Integration
• Data processing agreements with all providers
• Regular security and privacy audits
• Minimal data sharing
• Termination rights for violations
16.4 Referral Partner Integrations
• Affiliate networks for commission tracking
• Social media platform connections (per platform policies)
• E-commerce platform integrations
• Direct referral links
• Secure protocols, no personal data shared (aggregate only)

17. BUSINESS TRANSFERS AND CHANGES
17.1 Business Ownership Changes
• Advance user notification about the ownership change
• Successor can maintain, modify or improve data protections
17.2 Service Changes
• Clear communication of changes through the updates of our Privacy Policy
• Opt-out and deletion options
• No reduction in child data protections

18. REFERRAL PARTNERSHIP PROGRAM TRANSPARENCY
18.1 How the Program Works
Partnership Establishment:
• Referral Partners sign partnership/affiliate agreement
• Receive unique referral codes/links
• Commission structure disclosed confidentially in agreement
Awareness/Promotion:
• Educational institutions may host sessions
• Affiliates/influencers promote via platforms
• Business partners feature via services
• No personal data collected during promotions
Direct Parent Enrollment:
• Enrollment directly on https://www.straightegy.com
• Consent provided to Straightegy Consulting only
• Referral code applied for discount
• Payment processed to Straightegy Consulting via Razorpay
Automated Commission Payment:
• Enrollment tracking via secure system
• Monthly automated commission calculation
• Payment via Razorpay Route
• Aggregate reports only to Referral Partners
Privacy Protection: Direct consent to Straightegy Consulting, no Referral Partner data access, clear separation, DPDP compliance, zero personal data sharing.
18.2 Commission Reconciliation Without Sharing Data
Referral Code System:
• Unique codes per partner
• System records enrollment via code
• Personal information NOT attached to reports
Monthly Reports to Referral Partners Contain:
• Total enrollment count
• Cumulative count
• Commission calculation (aggregate)
• Payment confirmation
Monthly Reports DO NOT Contain:
• Names, emails, phone numbers
• Child information
• Addresses
• Progress data
Automated Reconciliation:
• Automatic count by code
• Automatic commission calculation
• Automatic payment processing
• Partner portal access (aggregates only)
• No manual personal data handling
18.3 Referral Partner Data Access
CAN See:
• Aggregate enrollment count
• Commission earnings
• Payment history
• General program metrics (aggregate)
• Geographic distribution (aggregate, optional)
CANNOT Access:
• Names
• Contact information
• Individual enrollments
• Progress or completion status
• Payment methods
• Login credentials
Legal Distinction: Straightegy Consulting = Data Fiduciary (all data). Referral Partners = Referral sources (aggregate reports only, no personal data access).
18.4 Commission Determination (Business Confidentiality)
Public Disclosure:
• Commission-based structure exists
• Based on enrollment numbers
• Percentage of program price
• Tiered by volume (higher volume = higher percentage)
• Discount provided regardless of commission rate
• Automatic payment via Razorpay Route
Confidential Information:
• Exact percentage rates
• Volume thresholds
• Competitive positioning
• Revenue sharing formulas
Protected as trade secrets under Indian contract law. Disclosed to Referral Partners under confidentiality agreements during partnership negotiation.
Legal Compliance: DPDP Act requires disclosure of data collection and use, not proprietary business terms. Personal data completely separate from commission calculations.

19. COMPLAINT AND GRIEVANCE PROCEDURE
19.1 Internal Process
1. Contact grievance@straightegy.com with concern description
2. Investigation within 15 days
3. Resolution within 30 days
4. Follow-up for satisfaction
19.2 Regulatory Complaints
• Data Protection Board of India (primary authority)
• Consumer Forums (district, state, national levels)
• State Consumer Commissions
• Cyber Crime Cells
19.3 Child Data Issues Support
• Priority handling (48-hour response)
• Parental support with clear explanations
• Faster action on deletion requests
• Policy improvements based on feedback

20. UPDATES TO THIS PRIVACY POLICY
20.1 Reasons for Updates
• Legal changes
• New features
• Privacy practice improvements
• Technology changes
• Referral program enhancements
20.2 Notification Process
• Email notification for material changes
• Regular changes are updated on the Privacy Policy page (we encourage you to check the page regularly)
20.3 Consent for Changes
• Active acceptance required for material changes
• Granular consent where applicable

21. CONTACT INFORMATION
General Privacy Questions:
Email: contact@straightegy.com
Response: Within 48 hours
1. Grievance Officer:
Email: grievance@straightegy.com
Languages: English and Hindi
Response: 15 days (Investigation), 30 days (resolution)
Data Protection Officer:
Details provided upon appointment
Child Data and Certificate Support:
Email: contact@straightegy.com
Subject: "Child Data Privacy" or "Certificate Name Request"
Priority Response: Within 24 hours
Emergency Contacts:
For urgent security incidents: contact@straightegy.com (Subject: "URGENT: Security Incident")

22. COMPLIANCE CERTIFICATIONS
22.1 Legal Compliance
• Digital Personal Data Protection Act, 2023
• Consumer Protection Act, 2019
• Information Technology Act, 2000
• Consumer Protection (E-commerce) Rules, 2020
• Indian Contract Law
22.2 International Standards Alignment
• GDPR principles
• COPPA principles
• ISO 27001
• NIST Cybersecurity Framework
22.3 Regular Audits
• Annual privacy audit
• Quarterly data review
• Security assessments
• Legal updates review
• Referral partnership compliance review
22.4 Third-Party Certifications
• PCI-DSS (through Razorpay)
• ISO 27001 (planned)
• SOC 2 (planned)

23. ACKNOWLEDGMENT AND CONSENT
23.1 Your Acknowledgment
By using our Platform, you acknowledge:
• You have read and understood this Privacy Policy
• You are 18+ years with authority to enroll your child
• You agree to data collection and processing as described
• You understand your rights under Indian laws
• You understand the data minimization approach
• You understand optional certificate name provision
• You understand Referral Partner source does not affect data protection
23.2 Your Consent as Parent/Guardian
By creating an account and enrolling your child in our Services, you confirm that:
You have the legal authority to enroll child
You have a clear understanding of data minimization approach
You are giving explicit consent if providing child's name
You agree to supervise child's platform use, including ensuring children access only the learning dashboard and not other website areas containing adult-oriented or promotional content
You have a clear understanding of ongoing rights
You have the ability to withdraw consent anytime
23.3 Referral Enrollment Acknowledgment
• Referral Partner is referral source only, not data processor
• Aggregate counts only shared with Referral Partner
• Consent directly to Straightegy Consulting
• Discount reflects partnership; specific commission rates confidential
• Data protections unchanged by referral source
• No Referral Partner access to personal information
23.4 Optional Child Name Consent
• Entirely optional, not required
• Used solely for certificate generation
• Stored securely and separately
• Deletion available anytime
• Never shared with third parties
• Enhanced security protections apply
23.5 Consent Recording and Withdrawal
• Recorded with timestamp, IP address, policy version, consent method
• Withdrawal via grievance@straightegy.com (Subject: "Withdraw Consent")
• Account deletion option (30-day completion)
• Specific data deletion option

24. CERTIFICATE ISSUANCE AND CHILD NAME HANDLING
24.1 Certificate Options
Option 1 (No Child Name): Addressed to parent/guardian
Option 2 (Personalized): Addressed to child's name (requires explicit consent)
24.2 Personalized Certificate Process
1. Separate consent form
2. Name collection (first name required, last name optional)
3. Automatic certificate generation upon completion
4. Immediate deletion available upon request
24.3 Security
• Separate database storage
• Restricted access
• Encrypted at rest and in transit
• No secondary use
• Never shared with Referral Partners
• Audit trail maintained
24.4 Deletion Request
• Email: contact@straightegy.com (Subject: "Delete Child Name")
• Verification of account ownership
• Deletion within 48-72 hours
• Confirmation with audit trail reference

25. REFERRAL PARTNER PROVISIONS
25.1 Schools and Educational Institutions
Responsibilities: Distribute codes per own policies, accurate representation, no data collection on our behalf, direct families to our platform, inform of no data access
Our Commitments: Aggregate counts monthly, automatic payments, confidentiality, marketing support, no individual family information
25.2 Awareness Sessions
No personal data collected during sessions. Enrollment occurs later via website. Attendees anonymous unless they enroll. Aggregate counts only to institution.
25.3 Affiliate Websites
Provide links, earn commissions, access aggregate data, standard marketing practices. No personal data received, aggregate reports only, secure transmissions.
25.4 Social Media Influencers
Unique codes, commission earnings, performance tracking, promotional support. No follower personal data, aggregate counts only, privacy protected.
25.5 Business Partner Integration
Integrate referral system, distribute codes, earn commissions, access portal. No customer data beyond referral attribution, commission on aggregates only, customer privacy maintained.
25.6 Partnership Inquiries
Contact us, sign confidentiality agreement, review commission structure (confidential), sign partnership agreement, receive code and materials. Data protection provisions: referral partner status, no data collection on behalf, direct families to platform, confidentiality, law compliance.

26. EDUCATIONAL CONTENT AND WEBSITE USE DISCLAIMER
Educational Purpose:
"Educational content only. This program builds skills in recognition, verification, decision-making, and critical thinking across digital, social, emotional, and academic contexts. The content is for educational and informational purposes and does not constitute professional advice. Parents should supervise their children's learning and consult appropriate professionals (educators, counselors, legal advisors, law enforcement) for help with real-life situations requiring expert guidance."
Platform Use and Supervision:
Learning Dashboard: The learning dashboard contains only age-appropriate educational materials free from marketing, advertisements, or promotional content directed at children.
General Website Areas: Other areas of the Straightegy Consulting website (accessible outside the learning dashboard) may contain content, information, and promotional materials primarily intended for parents, guardians, and adult audiences. This may include program details, pricing information, partnership opportunities, testimonials, blog posts, and marketing content.
Parental Responsibility: Parents and guardians are solely responsible for supervising their children's use of our platform and website. We strongly recommend that parents ensure children access only the designated learning dashboard and do not browse other website sections that may contain adult-oriented or promotional content.
No Liability for Unsupervised Access: Straightegy Consulting is not responsible for content accessed by children outside the learning dashboard or for any consequences arising from inadequate parental supervision of children's online activity on our website.

27. LIMITATION OF LIABILITY
We Cannot Guarantee: Absolute security, prevention of all unauthorized access, complete elimination of data breach risk.
We Commit To: Industry-standard security, legal compliance, prompt breach notification, continuous security improvements.
Your Responsibility: Maintain credential security, use strong passwords, enable multi-factor authentication, report suspicious activity, supervise child's use.
Our Liability Limited To: Extent permitted under Indian law, the actual amount you’ve paid to us for the program, or actual demonstrable damages, whichever is lower. We are not liable for consequential or indirect damages, subject to Terms and Conditions.

28. GOVERNING LAW
Applicable Laws: Digital Personal Data Protection Act 2023, Consumer Protection Act 2019, Information Technology Act 2000, Indian Contract Act 1872, other applicable Indian laws.
Jurisdiction: Courts of Faridabad, Haryana, India (exclusive). Subject to Data Protection Board and consumer forum rights.
Dispute Resolution: Internal grievance procedure first, mediation/arbitration if mutually agreed, regulatory complaints, court proceedings as last resort.

29. EFFECTIVE DATE AND VERSION HISTORY
Current Version: 2.2
Effective Date: October 2025
Last Updated: October 26, 2025
Key Changes in Version 2.2:
• Streamlined content, removed repetitions
• Eliminated specific pricing references
• Strengthened business protections while maintaining compliance
• Clarified data minimization approach
• Enhanced Referral Partner sections
• Improved readability and structure
Previous Versions: Available upon request
Future Updates: Current version always at https://www.straightegy.com/privacy-policy

CERTIFICATION
This Privacy Policy is effective as of October 2025 and complies with Digital Personal Data Protection Act 2023, Consumer Protection Act 2019, Information Technology Act 2000, and all applicable Indian privacy and consumer protection laws.
We are committed to protecting your privacy and your child's safety through our data minimization approach and strong security measures. Regardless of how you find us, your personal data protections remain identical and absolute.
For questions, concerns, or feedback, contact us anytime at contact@straightegy.com.
© 2025 Straightegy Consulting. All rights reserved.

Quick Links:
Programs: https://www.straightegy.com/online-programs
FAQ: https://www.straightegy.com/faq
About: https://www.straightegy.com/about
Contact: https://www.straightegy.com/contact-us
Terms: https://www.straightegy.com/terms-and-conditions
Refund Policy: https://www.straightegy.com/refund-policy
Referral Partnerships: https://www.straightegy.com/referral-partnerships
Contact:
Email: contact@straightegy.com
Grievance: grievance@straightegy.com

END OF PRIVACY POLICY