A. General

In addition to our Terms and Conditions of Service, Neuteon Ed-Tech Solutions respects your privacy and is committed to protecting it. This Privacy Policy (the “Policy”) explains the types of information collected by Neuteon when you use the Platform (as defined in Terms and Conditions) that references this Policy, how we collect, use, share, and store such information, and also explains the rationale for collection of such information, along with the privacy rights and choices you have regarding your information when you use the Services.

For ease of reference, use of the terms “Neuteon,” “we,” “us,” and/or “our” refer to Neuteon Ed-Tech Solutions and its affiliates, which have the license to host the Platform and offer Services. Similarly, use of the terms “you,” “yours,” and/or “User(s)” refer to all users of the Platform, including Learners and Content Providers (as more particularly defined under our Terms and Conditions).

The Services are governed by this Policy, the Terms and Conditions, and any other rules, policies, or guidelines published on the Platform as applicable to you. Please read this Policy carefully prior to accessing our Platform and using the Services. By accessing and using the Platform, providing your Personal Information (defined below), or by otherwise signaling your agreement when the option is presented to you, you consent to the collection, use, disclosure, sharing, and storing of information described in this Policy, Terms of Service, and any other rules, policies, or guidelines published on the Platform as applicable to you (collectively referred to as the “Platform Terms”), and Neuteon disclaims all liabilities arising therefrom.

If any information you have provided or uploaded on the Platform violates the Platform Terms, Neuteon may be required to delete such information upon informing you of the same and revoke your access to the Platform if required.

Capitalized terms used but not defined in this Policy can be found in our Terms and Conditions.

If you have any questions about this Policy, please contact us at privacy@neuteon.com.

B. Applicability

This Policy applies to all Users of the Platform.

Neuteon owns and/or manages several services and solutions in the field of education and technology, either directly or through affiliates and subsidiaries. Each of these services may publish their own privacy policies. Accordingly, this Policy applies specifically to the information collected through the Neuteon Platform.

Neuteon has taken reasonable precautions as per applicable laws and implemented industry standards to treat Personal Information as confidential and to protect it from unauthorized access, improper use or disclosure, modification, and unlawful destruction or accidental loss.

C. Access

You may be allowed to access and view the Platform as a guest without creating an account or providing any Personal Information. Neuteon does not validate or take responsibility for information, if any, provided by you as a guest, except as otherwise required under law or by a competent authority.

To have full access to features and benefits of our Platform, you are required to create an account. To create an account, you must provide certain Personal Information as required during registration. Other information requested on the registration page, such as the ability to receive promotional offers from Neuteon, is optional.

Neuteon may, in the future, request other optional information from you to help customize and improve your experience. Neuteon may keep records of telephone calls, emails, or messages received from you for enquiries, feedback, or support purposes, to render Services effectively.

D. Use of the Platform/Services by Children

As stated in our Terms and Conditions, to register on the Platform you must meet the defined Age Requirements. If you are a “Minor” or “Child” (i.e., you do not meet the Age Requirements), you may not register on the Platform. Only your Parent or Guardian may register on your behalf, agree to all Platform Terms, and enable your access under their supervision.

While some Services may involve collection of a Child’s Personal Information, Neuteon does not knowingly collect such information without parental consent. If you are a Parent/Guardian and become aware that your Child has provided Personal Information without consent, please contact us at privacy@neuteon.com.

If we become aware that we have collected Personal Information from a Child without required parental consent, we will take steps to remove such information from our servers.

If your Child faces any form of abuse or harassment while using our Services, please write to us at legal@neuteon.com, so that appropriate action can be taken.

E. Controllers

Neuteon is the controller of Personal Information that it collects and processes in connection with the use of the Platform and provision of Services. The types of information we collect are detailed below.

F. Personal Information

“Personal Information” includes information that identifies a User such as first and last name, identification number, email address, age, gender, location, photograph, and/or phone number provided at the time of registration or anytime thereafter.

“Sensitive Personal Information” includes but is not limited to:

1. Passwords and financial data (except the truncated last four digits of credit/debit card).
2. Health data.
3. Official identifiers (such as biometric data, Aadhaar number, passport, etc.).
4. Information about sexual life, orientation, race, ethnicity, political or religious beliefs.
5. Account details and credentials.
6. Any information categorized as sensitive or special under applicable Data Protection Laws (including GDPR, CCPA, and IT Rules 2011).

Use of the term Personal Information in this Policy includes Sensitive Personal Information where applicable.

We request you not to provide Neuteon with any Personal Information unless specifically requested. If you voluntarily share Personal Information not requested by us, Neuteon will not be liable in respect of such information.

G. Information We Collect

We only collect information about you if we have a reason to do so — for example, to provide our Services on the Platform, to communicate with you, or to make our Services better.

We collect this information from the following sources:

·  Information we collect from You:

1. Basic account information: In order to access certain features of the Platform, you will need to create an account and register with us. We ask for basic information which may include your name, an email address, state of residence country, and password, along with a username and phone/mobile number.
2. Know Your Customer (‘KYC’) information: If you are an Content Provider registered with us, then, we also collect the KYC information, which may include information pertaining to your PAN number, aadhaar number, driver’s license, passport, your entity details such as name, MOU/AOA, certificate of incorporation, list of directors/partners, social security number etc., along with the relevant documents. We collect this information and documents from you to complete our verification process including pursuant to any other arrangement / agreement executed with you.
3. Public profile information: If you are an Content Provider, we may also collect certain additional information from you to enable creation of your public profile, if any, on the Platform to help Learners and other Users know you better. We do not share your KYC information, documents or any such Personal Information on these public profiles. Your public profile will only contain Personal Information that are required for Learners or Users to know you (as applicable) viz., your username, a brief description of any content you have made available on the Platform, your educational qualifications, your past associations, your photo, and such similar information that may enable a Learner or other User to know you better. The information in your public profile will be based on the information you provide to us or as updated by you on such applicable sections.
4. Information when you communicate with us: When you write to us with a question or to ask for help, we will keep that correspondence, and the email address, for future reference; this may also include any phone/ mobile numbers if you have provided us the same as part of your communication either in writing (emails included), over a phone call or otherwise. When you browse pages on our Platform, we will track that for statistical purposes which may be to improve the Platform and the Services. You may also provide us your Personal Information or other information when you respond to surveys, enter any form of contests, tests, events, competitions, webinars, etc., hosted by Unacademy, either on the Platform or otherwise, or when you otherwise communicate with us via form, e-form, email, phone, or otherwise, we store a copy of our communications (including any call recordings or emails, if any, as permitted by applicable law).
5. Information related to location: You may also choose to provide location related information, including but not limited to access to GPS, which will enable us, with your consent, to offer customized offerings for specific services where location data is relevant and/or applicable such as informing you whether services on the Platform that you have expressed interest in may be availed of at or near your location.

·  Information we collect automatically:

1. Device and Log information: When you access our Platform, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Platform — for example, when you create or make changes to your account information on the Platform.
2. Usage information: We collect information about your usage of our Platform. We also collect information about what happens when you use our Platform (e.g., page views, support document searches, features enabled for your account, interactions with other parts of our Services) along with information about your Supported Device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to provide our Platform to you, get insights on how people use our Platform so that we can make our Platform better, and understand and make predictions about User retention.
3. Location information: We may determine the approximate location of your Supported Device from your Internet Protocol (IP) address. We may collect and use this information to calculate how many people visit from certain geographic regions or to improve our Platform Services.
4. Information from cookies & other technologies: We may collect information about you through the use of cookies and other similar technologies. A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. For more information on our use of cookies and similar technologies, please refer to our Cookie Policy.

·  Information we collect from other sources:

We might receive and collect information about you from other sources in the course of their services to us or from a publicly available sources, as permitted by law, which we may combine with other information we receive from or about you. For example, we may receive information about you from a social media site or a Google service if you connect to the Services through that site or if you use the Google sign-in

H. Basis of Collection and Processing of Your Personal Information

Basis for Collection:

We collect and process your Personal Information based on the following legal parameters depending upon the nature of Personal Information and the purposes for which it is processed:

Consent: We rely on your consent to process your Personal Information in certain situations. If we require your consent to collect and process certain Personal Information, as per the requirements under the applicable Data Protection Laws, your consent is sought at the time of collection of your Personal Information and such processing will be performed where consent is secured.

Compliance with a legal obligation: Your Personal Information may be processed by us, to the extent that such processing is necessary to comply with a legal obligation.

Processing of Your Personal Information:

We may process your Personal Information in connection with any of the purposes and uses set out in this Policy on one or more of the following legal grounds:

Because it is necessary to perform the Services you have requested or to comply with your instructions or other contractual obligations between you and us.

To comply with our legal obligations as well as to keep records of our compliance processes.

Because our legitimate interests, or those of a third-party recipient of your Personal Information, make the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms.

Because you have chosen to publish or display your Personal Information on a public area of the Platform, such as a comment area.

Because it is necessary to protect your vital interests.

Because it is necessary in the public interest.

Because you have expressly given us your consent to process your Personal Information in a particular manner.

We do not use Personal Information for making any automated decisions affecting or creating profiles other than what is described in this Policy.

Where the processing of your Personal Information is based on your consent, you have the right to withdraw your consent at any point in time in accordance with this Policy. Please note that should the withdrawal of consent result in us not being able to continue offering our Services to you, we reserve the right to withdraw or cease from offering our Services to you upon your consent withdrawal. You may withdraw consent by contacting us with a written request to the contact details provided in the ‘Grievances’ section below. Upon receipt of your request to withdraw your consent, the consequences of withdrawal may be communicated to you. Upon your agreement to the same, your request for withdrawal will be processed.

I. How We Use and Share the Information Collected

We use/process your information in the following manner:

To provide Services on our Platform: We use your information to allow you to access the Platform and the Services offered therein, including without limitation to set-up and maintain your account, provide customer service, fulfil purchases, verify User information, and resolve issues.

To improve our Platform and maintain safety: We use your information to improve and customize the Platform and Services, provide updates, create new features, and ensure security by detecting and preventing fraud, misuse, or threats.

To market our Platform and communicate with You: We use your information to develop targeted marketing, communicate offers, products, services, and receive your feedback.

To establish, exercise, or defend legal claims: We may process Personal Information to protect and assert legal rights in courts, administrative, or other proceedings.

To manage risk and obtain professional advice: We may use Personal Information to manage risk or obtain professional advice.

To better understand our Users: We may use data to analyze usage patterns to improve our Services.

With your consent: We may otherwise use your information with your consent or at your direction.

Sharing of Information

We share information only as described below, and never sell Personal Information for monetary or other valuable consideration:

Affiliates and Subsidiaries: We may share information with Neuteon’s affiliates, subsidiaries, and controlled entities, ensuring they adhere to this Privacy Policy.

Third-party vendors/service providers: We may share information with vendors (e.g., consultants, payment processors, cloud services, support teams) strictly for service-related purposes.

Third-party platforms for additional offerings: To enable interactive features such as learning forums, with limited data shared and always subject to your consent.

Legal Disclosures: We may disclose information to comply with applicable laws, regulations, government or law enforcement requests, protect Neuteon’s rights, prevent fraud, or enforce policies.

Business transfers: In the event of a merger, acquisition, restructuring, or transfer involving Neuteon, user data may be transferred while remaining subject to this Privacy Policy.

Advertising and Analytics Partners: Usage data may be shared with third-party analytics or advertising platforms via cookies and similar technologies.

With Your Consent: Information may be shared if you authorize us to do so.

J. Cross-Border Data Transfer

Your information, including any Personal Information, is stored, processed, and transferred in and to the Amazon Web Service (AWS) servers and databases located in Singapore, India, and the USA. Neuteon may also store, process, and transfer information in other countries where its affiliates or service providers operate.

Please note: these countries may have differing privacy laws, and data may be subject to disclosure under applicable laws or government processes.

By accessing our Platform or otherwise providing us information, you consent to such transfer of data across borders. If you are located in the EU/EEA/UK, the legal basis for processing and transfers includes performance of contracts, compliance with legal obligations, and Neuteon’s legitimate interests (such as fraud prevention and improving services).

K. Duration for Which Your Information is Stored

Mostly, when you delete any of the information provided by you or when you delete your account on the Platform, the same will be deleted from our servers too. However, in certain cases, we will retain your information for as long as it is required for the purposes stated hereinabove, including for complying with legal obligations or business compliances.

Further, please note that we may not be able to delete all communications or photos, files, or other documents publicly made available by you on the Platform (for example: comments, feedback, etc.). However, we shall anonymize your Personal Information so that you can no longer be identified as an individual in association with such information. We will never disclose aggregated or de-identified information in a manner that could identify you.

Note: If you wish to exercise any of your rights (as specified in the ‘Your Rights’ section below) to access, modify, or delete any or all information stored about you, then you may do so by using the options provided within the Platform or by contacting us at privacy@neuteon.com.

L. Your Choices

Limit the information you provide: You always have the option to choose what information you share with us, including the ability to update or delete your information. However, lack of certain information may limit your access to the Platform or its features.

Limit communications you receive from us: You may select the type of communications you wish to receive, or opt out entirely, though some communications (e.g., legal or security notices) may still be mandatory.

Reject cookies and similar technologies: You may disable or remove cookies through your web browser settings. However, some Services offered on the Platform may not function properly when cookies are rejected or disabled.

M. Your Rights

Depending on your location, you may have certain rights regarding your Personal Information under applicable Data Protection Laws.

If you are a User, you may exercise any of these rights by using the Platform’s available options or by contacting us via the details in the ‘Grievances’ section.

Right to Confirmation and Access – Access the Personal Information we hold about you.

Right to Correction – Rectify inaccurate or outdated information.

Right to be Forgotten – Restrict or prevent continued disclosure of your Personal Information under certain circumstances.

Right to Erasure – Request deletion of your Personal Information (except as required for compliance).

Please note, we may verify your identity before fulfilling your request.

N. Information Security

We use TLS/SSL encryption, electronic safeguards, and procedural controls to protect your Personal Information as required under applicable laws.

All KYC information collected is encrypted and accessible only to designated authorized personnel at Neuteo.

No system is 100% secure; therefore, we cannot guarantee absolute security.

Users are responsible for protecting their account credentials. If you suspect unauthorized access, change your password immediately and notify us.

We also ensure that third-party service providers follow adequate security standards in line with our policies.

O. Promotional Communications

You may opt out of promotional communications at any time via Platform settings, unsubscribe links in emails, or by contacting us at help@neuteon.com.

You may still receive transactional or legal notices (e.g., service updates, account alerts).

We do not sell your Personal Information to third parties.

Advertisers may use cookies or other technologies to deliver ads, but we do not control their practices. Please check their privacy policies separately.

P. Interest-Based Ads

Neuteon may display interest-based advertising using information you make available when interacting with our Platform and Services.

Ads may be tailored based on your interactions, but we never share your Personal Information directly with advertisers.

Advertisers may use cookies or IP addresses for personalization.

Our practices comply with applicable digital advertising laws, including the Advertising Standards Council of India and international self-regulatory principles.

Q. Modification to Privacy Policy

Neuteon may update this Policy from time to time. We encourage you to review it periodically on the Platform. Any material changes that reduce your privacy rights will not be implemented without your consent.

R. Privacy Grievances

If you have questions, concerns, or grievances about this Policy, please contact us:

�� privacy@neuteon.com

�� Grievance Officer: [Name/Title Placeholder]

Neuteon

[Official Registered Address Placeholder]

S. Country-Specific Additional Privacy Terms

If You Are an Indian Resident:

You may have rights under the forthcoming Personal Data Protection Bill (PDPB), including confirmation, correction, portability, erasure, and the right to be forgotten.

If You Are a UK/EU/EEA Resident:

You may exercise your rights under the GDPR, including access, rectification, erasure, restriction, objection, portability, and the right to lodge complaints with your local Supervisory Authority.

If You Are a California Resident:

You may exercise rights under the CCPA, including:

The right to know what information we collect.

The right to request deletion of Personal Information.

The right to opt in/out of marketing and analytics.

The right to equal services without discrimination.

Requests may be made through privacy@neuteon.com.

T. CCPA NOTICE AT COLLECTION

For purposes of the CCPA, in collecting the information described above, Neuteon Ed-Tech Solutions (“Neuteon”, “we”, “our”, “us”) collects the categories of Personal Information listed below from you:

Identifiers:

We may collect your name, email address, mobile number, username, unique personal identifier, and Internet Protocol (IP) address. We use Identifiers as set forth in the “How We Use and Share the Information Collected” section of this Policy, such as your name, contact information, and device/online identifiers.

Characteristics of Personal Information described in the California Customer Records statute:

We may collect your name, email address, username, unique personal identifier, and gender. We use this information as set forth in the “How We Use and Share the Information Collected” section of this Policy.

Internet or other electronic network activity information:

We collect cookies as described in our Cookie Policy. We automatically receive information from your browser and device, which includes the date and time of your visit to the Neuteon Platform, your location, IP address, domain server, browser type, access time, and details about which pages you visit.

Geolocation data:

We may collect your IP address (for example, to estimate approximate location).

Audio, electronic, visual, or similar information:

We may collect your profile picture or other audio/visual information uploaded as content to the Neuteon Platform.

Inferences:

We may make inferences based on the Personal Information collected (such as likelihood of retention or attrition).

U. CCPA DATA PRACTICES DURING THE LAST 12 MONTHS

Personal Information collected:

As described in this Policy, Neuteon has collected the categories of Personal Information listed below during the preceding 12 months:

Identifiers

Characteristics of Personal Information described in the California Customer Records statute

Internet or other electronic network activity information

Geolocation data

Commercial information

Audio, electronic, visual, or similar information

Inferences

Categories of sources:

We have collected the Personal Information identified in this Policy from you directly and through our payment processors.

Business and commercial purposes for collecting:

We have collected the categories of Personal Information listed above for purposes including:

Operating the Neuteon Platform;

Providing our Services to you;

Honoring our Terms and Conditions and contracts;

Ensuring privacy and security of our Platform and Services;

Managing our relationship with you;

Communicating with you;

Analyzing use of the Platform and Services;

Enhancing your user experience;

Tracking visits to the Platform;

Providing a more personal and interactive experience;

Usage analytics.

Personal Information sold:

Neuteon has not sold categories of Personal Information during the preceding 12 months.

Personal Information disclosed for a business purpose:

We may disclose categories of Personal Information to third parties for a business purpose, including:

Identifiers

Characteristics of Personal Information described in the California Customer Records statute

Internet or other electronic network activity information

Geolocation data

Commercial information

Audio, electronic, visual, or similar information

Inferences

These may be disclosed to:

Corporate parents, subsidiaries, and affiliates;

Advisors (accountants, attorneys);

Service providers (data analytics, storage, mailing, marketing, website/platform administration, technical support);

Operating systems and platforms.

V. CONSUMER RIGHTS AND REQUESTS UNDER THE CCPA

The CCPA gives consumers the right to request that we (1) disclose what Personal Information we collect, use, disclose, and sell, and (2) delete certain Personal Information that we have collected or maintained. You may submit these requests to us as described below, and we honor these rights where they apply.

If a request is submitted in a manner that is not one of the designated methods for submission, or if the request is deficient in some manner unrelated to our verification process, we will either (i) treat the request as if it had been submitted in accordance with the designated manner, or (ii) provide you with specific directions on how to submit the request or remedy any deficiencies with the request, as applicable.

Request to Know

As a California resident, you have the right to request:

The specific pieces of Personal Information we have collected about you;

The categories of Personal Information we have collected about you;

The categories of sources from which the Personal Information is collected;

The categories of Personal Information about you that we have sold and the categories of third parties to whom the Personal Information was sold;

The categories of Personal Information about you that we disclosed for a business purpose and the categories of third parties to whom the Personal Information was disclosed for a business purpose;

The business or commercial purpose for collecting, disclosing, or selling Personal Information; and

The categories of third parties with whom we share Personal Information.

Our response will cover the 12-month period preceding our receipt of a verifiable request.

Request to Delete

As a California resident, you have a right to request the erasure/deletion of certain Personal Information collected or maintained by us. As described herein, we will delete your Personal Information from our records and direct any service providers (as defined under applicable law) to delete your Personal Information from their records. However, we are not required to honor a deletion request if an exemption applies under the law.

Submitting a Request

You may submit a request to know or delete by contacting us at:

�� privacy@neuteon.com

�� Neuteon Ed-Tech Solutions

Regarding requests to delete, we may present you with the choice to delete select portions of your Personal Information, but a global option to delete all Personal Information will be offered and more prominently presented.

Verification Process

We are required by law to verify the identities of those who submit requests to know or to delete. To determine whether the individual making the request is the consumer about whom we have collected information, we will verify your identity by matching the identifying information provided by you in the request to the Personal Information that we already maintain about you. As a part of this process, you may be required to provide your name, email address, and mobile number (if the same have been voluntarily provided by you at the time of registering on the Platform or otherwise while using the Platform). We will inform you if we cannot verify your identity.

Please note:

If we cannot verify the identity of the person making a request for categories of Personal Information, we may deny the request. If the request is denied in whole or in part for this reason, we will provide a copy of, or direct you to, our Privacy Policy.

If we cannot verify the identity of the person making a request to delete, we may deny the request. If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response and explain why we have no reasonable method by which we can verify the identity of the requestor.

Authorized Agents

Authorized agents may submit requests via the methods identified in this Policy. If you use an authorized agent to submit a request to know or a request to delete, we may require you to:

Provide the authorized agent with signed permission to do so;

Verify your identity directly with us; and

Directly confirm with us that you provided the authorized agent permission to submit the request.

However, we will not require these actions if you have provided the authorized agent with power of attorney pursuant to the California Probate Code.

Excessive Requests

If requests from a User are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the User of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested.

CCPA Non-Discrimination

You have the right not to receive discriminatory treatment by us due to your exercise of the rights provided by the CCPA. We do not offer financial incentives and price or service differences, and we do not discriminate against Users/consumers for exercising their rights under the CCPA.

Privacy Policy – Version 2.1

Last Updated on 11 th June 2025