Privacy Policy for GrowX (Institutes)

Last Updated: July 24, 2025

This Privacy Policy (“Policy”) explains how GrowX, operated by Array Ventures Private Limited, collects, processes, stores, and protects personal and institutional information provided by coaching institutes and their authorized teams (“you”, “your”, “Institute”) when using the GrowX Platform to manage coaching operations and admissions on the Qompass network.

By registering your coaching institute or accessing the GrowX Platform, you agree to the terms of this Policy. If you do not agree, please do not use the Platform.

Scope and Applicability
This policy applies to:
- Coaching owners and administrators creating profiles on the GrowX Platform
- Team members of coaching institutes who are granted access for coaching profile, batch management, student enrolment, or counselling
- All data shared with GrowX as part of institute onboarding, operational usage, and payment processing
This Policy does not apply to end users or students directly using the Qompass portal. A separate student privacy policy governs those interactions.

Information We Collect from Coaching Institutes
GrowX collects the following categories of information during and after onboarding:
1. Coaching Institute Profile Information
  - Institute name, address, contact details
  - Coaching photographs, videos, and promotional content
  - Course offerings, fees, and infrastructure highlights
2. Teacher and Staff Details
  - Name, photo, role (e.g., Physics teacher, Counsellor)
  - Credentials or academic qualifications (optional)
  - Phone number and email for internal coordination
3. Student Information (Enrolled via GrowX or Walk-Ins)
  - Name, photograph, course enrolled, batch assignment
  - Admission source (Qompass or walk-in)
  - Payment details, fee structure, and status
4. Banking and Financial Information
  - Bank account details for disbursing collected fees
  - PAN, GSTIN, and other tax identifiers
  - Transaction history, reconciliation reports
5. Operational Details
  - Batches created (timing, course, capacity)
  - Counselling team profiles and responsibilities
  - Offers and discounts configured for student acquisition

Purpose of Data Collection
GrowX collects and processes this data for the following purposes:
- To create and maintain your coaching institute profile on the Qompass network
- To manage admissions, counselling, batch allocation, and walk-in student tracking
- To process payments and reconcile settlements with accurate records
- To display relevant institute details to prospective students on Qompass
- To enable coordination among coaching team members via dashboard tools
- To provide analytics, reports, and business insights for your institute
- To comply with legal, tax, and financial reporting obligations

Data Sharing and Access Control

GrowX may share your data in the following limited and controlled scenarios:
- With Prospective Students: Coaching profile, teachers, courses, and offers are displayed to students browsing Qompass. Internal team or financial data is never shared.
- With Platform Service Providers: Payment gateways, KYC verification vendors, and analytics tools may receive access to your data strictly for fulfilling GrowX's services.
- With Regulatory Authorities: Tax, audit, or legal data may be shared with government agencies as required by Indian laws.
- With Qompass Operations Team: Internal teams may access coaching information to resolve issues, support onboarding, or conduct audits.
GrowX ensures that all such disclosures are made under strict confidentiality, with appropriate access controls in place.

Data Security Measures
We take the protection of your data seriously. Measures include:
- Encrypted storage of sensitive data (e.g., bank accounts, PAN/GST)
- Role-based access for coaching staff and GrowX personnel
- Secure HTTPS connections and session timeouts
- Regular security audits and vulnerability assessments
You are responsible for maintaining the confidentiality of login credentials of your institute's GrowX dashboard.

Retention and Deletion
GrowX retains your institute's data for the duration of your association with the platform and as required by applicable financial and legal regulations. Upon termination of service:
- We archive your data for legal and audit purposes for a limited time
- You may raise a request to delete residual data (subject to statutory retention)

Compliance with Indian Data Protection Laws
GrowX complies with the Digital Personal Data Protection (DPDP) Act, 2023 and associated regulations. This includes:
- Obtaining valid consent where required
- Ensuring purpose limitation and data minimization
- Providing clear opt-out and deletion mechanisms
- Appointment of a Data Protection Officer to handle data-related grievances

Your Responsibilities as an Institute
As a coaching institute user of the GrowX platform, you agree to:
- Ensure your team members have authorized access only
- Collect and upload only valid and accurate student/teacher data
- Use the platform in compliance with applicable laws (e.g., tax, education norms)
- Notify GrowX immediately in case of any unauthorized access or data breach at your end

Modifications to this Policy
GrowX may update this Privacy Policy from time to time. We will notify you of material changes via email or platform notifications. Continued use of GrowX after such changes constitutes acceptance.

Grievance Redressal & Contact Information
For any concerns related to data use, access requests, or violations of this Policy, please contact:

Data Protection Officer (DPO)

Mr. Rajveer Meena

Array Ventures Private Limited (GrowX)

Email: dpo@growx.in

Governing Law
This Policy is governed by the laws of India. Any disputes shall be subject to the exclusive jurisdiction of the courts located in Jaipur, Rajasthan