PRIVACY POLICY
Last Updated: September 6, 2026
Introduction
SeekhoABC (“SeekhoABC,” “we,” “us,” or “our”) offers and distributes a web-based structured literacy platform for educators, schools, and educational institutions in India. SeekhoABC holds the rights to market and sell the Platform in India.
This Privacy Policy explains how SeekhoABC collects, uses, stores, discloses, and protects personal data and personal information through the Platform and related websites, mobile applications, web portals, educational content, and services (collectively, the “Services”) in India.
This Privacy Policy also explains how you can ask us questions and make suggestions about our privacy practices and review and update such information.
1. DEFINITIONS
For the purposes of this Privacy Policy, the following definitions apply:
a) “Authorized User” means individuals, including students, educators, administrators, parents and legal guardians, that the Institution allows to access and use the Services as permitted in an Institution Contract;
b) “Data Fiduciary” means the person who determines the purpose and means of processing personal data under applicable Indian data protection law.
c) “Customer” or “you” means Direct Customers and Institutions that are subscribed to access and use the Services.
d) “Data Principal” means the individual to whom the Personal Information or personal data relates.
e) “Direct Customer” means an individual that subscribes to the Services for personal or household use.
f) “Direct Subscription” means a subscription to the Services purchased by a Direct Customer, including through the Apple App Store or Google Play or similar service.
g) “Consent” means consent given by a Data Principal for the processing of their Personal Information for a specified purpose, as required by applicable Indian data protection law.
h) “Digital Personal Data Protection Act” means the Digital Personal Data Protection Act, 2023, together with applicable rules, regulations, and amendments.
i) “Privacy Laws” means:
a. means the Digital Personal Data Protection Act, 2023, and applicable rules, regulations, and amendments made under it.
b. means applicable Indian laws relating to the protection, collection, use, disclosure, processing, retention, and handling of personal data and personal information.
j) “Institution” means a publicly funded school, school board or other third-party organization that subscribes to or enters into an agreement with SeekhoABC for access to or use of the SeekhoABC Platform.
k) “Institution Contract” means a purchase order, invoice, quote, or service agreement produced by SeekhoABC for an Institution relating to the Services.
l) “Institution Data” means Personal Information provided by an Institution or its Authorized Users.
m) “Consent Manager” means a person registered or recognized under applicable Indian data protection law to enable a Data Principal to give, manage, review, or withdraw consent, where applicable.
n) “Personal Information” means information about an identifiable individual, or information that is otherwise defined as “personal information,” “personal data” or an equivalent term under applicable Privacy Laws.
o) “Data Processor” means a person who processes Personal Information on behalf of a Data Fiduciary.
p) “Privacy Laws” means all applicable Indian laws relating to the collection, use, disclosure, processing, protection, retention, or other handling of Personal Information, including the Digital Personal Data Protection Act, 2023, the Information Technology Act, 2000, and applicable rules, regulations, and amendments made under them.
q) “Processor” has the meaning attributed to it under applicable Indian data protection law.
r) “Public Website” means the SeekhoABC website and any associated informational, marketing, or promotional webpages.
s) “Student Management Dashboards” means the cloud-hosted portal where educators administer classes, manage literacy modules, and track analytics, accessible through the SeekhoABC website and associated webpages.
t) “Services” has the meaning given in the Introduction.
u) “Personal Data” means data about an individual who is identifiable by or in relation to that data.
Any terms not described herein have the meanings given in our TERMS OF SERVICE AND LICENSE AGREEMENT available on our Public Website.
2. CONSENT TO COLLECTION, USE, DISCLOSURE
By accessing our Public Website, or by using the Services, you are providing your consent for us and our approved third-party agents to collect, use and disclose your Personal Information in accordance with this Privacy Policy and applicable laws.
No compensation is offered for sharing your information.
You may withdraw your consent at any time, subject to applicable laws. You may also withhold your consent to providing personal information, and you may consent to provide some but not all of any requested personal information. You do not have to provide us a reason for withholding consent.
If you are a parent or guardian of a minor learner who’s Personal Information is being collected, used, or disclosed in accordance with the terms of this Privacy Policy, you consent to the same.
All Institutions subscribing for the Services shall be responsible for obtaining consent of any Authorized Users to the terms herein and shall make these terms available to such Authorized Users.
3. THE DATA WE COLLECT
A. Learner Personal Information
SeekhoABC may receive the following, some of which may be considered Personal Information in respect of learners using our Services:
• learners’ first and last name (or alias);
• student ID;
• gender;
• date of birth;
• school and classroom;
• teacher name;
• learning progress (completed lessons and activities);
• assessment results;
• time spent on learning activities; and
• achievement information (such as stars earned).
B. Institution Personal Information
When an Institution subscribes to the Services, we may collect the following information related to the educators, administrators and other authorized representatives of the Institution, some of which may be considered Personal Information:
• first and last name;
• job title;
• School Board affiliation;
• school name;
• professional email address;
• institutional phone number;
• reports and performance data; and
• financial billing data.
C. Cookies
As you navigate through and interact with the Services, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns for session persistence, system performance, and application security, some of which may be considered Personal Information including:
• Details of your visits to our Website, including traffic data and other communication data and the resources that you access and use on the Website; and
• Information about your computer and internet connection, including your IP address, operating system, and browser type.
D. Subscription Information
When individuals subscribe to the SeekhoABC Platform directly through the Apple App Store or Google Play, we process limited subscription information necessary to manage access to the platform and provide customer support.
This information may include:
• subscription status (e.g., Trial, Active, Expired, or Cancelled);
• purchase platform (Apple App Store or Google Play);
• subscription start and expiry dates;
• first and last name; and
• transaction or purchase identifiers provided by the applicable app store.
4. USE OF PERSONAL INFORMATION
A. Uses of your Personal Information
To the extent of applicable Privacy Laws, you agree and hereby consent that we may use your Personal Information:
• To provide the Services, including your use of the SeekhoABC Platform and/or presenting our Public Website and its contents to you. This includes:
• creating a learner’s account;
• saving learning progress between sessions;
• providing lessons at the appropriate level;
• allowing teachers to monitor progress; and
• generating reports that help teachers support student learning
• to investigate and prevent errors, defects, performance and security issues;
• to generally enhance your experience with the SeekhoABC Platform;
• to contact you about changes or similar notices related to the SeekhoABC Platform or other services that we feel may be of interest to you;
• to assist with the investigation or prevention of unlawful activity, fraud, security incidents, or other matters as required or permitted by applicable Indian law;
• in the course of any merger, acquisition, financing, or sale of all or a portion of the Services, provided that any purchasers or transferees are contractually obligated to keep Personal Information confidential, use it only for the purposes for which we disclose it to them, and to process the Personal Information with the same standards set out in this policy;
• for the purposes of research and program evaluation, provided that any use of learner Personal Information will be anonymized in any such research;
• for other such purposes as may be required by applicable law; or
• for any other purpose with your consent.
B. No commercial monetization
SeekhoABC processes Personal Information exclusively for the prescribed uses above, and for greater certainty:
• We never sell, rent, lease, or monetize student data.
• We never build marketing profiles, track cross-site behaviours, or target commercial advertising to child or youth users.
• We never reuse or repurpose student performance data for independent product research and development unless the data is stripped of all administrative links and fully and permanently anonymized in accordance with global best practices.
C. Use of Financial Information
Financial billing data provided by Institutions is transmitted securely and handled strictly through an industry-standard, PCI-compliant payment gateway.
All such financial and billing data provided to such third-party payment processor shall be subject to its applicable privacy practices.
For Direct Customers, SeekhoABC does not collect, receive, or store payment card numbers, banking information, or other financial payment credentials. All payment processing is handled directly and securely by Apple or Google through their respective app store payment systems.
5. DISCLOSURE OF PERSONAL INFORMATION
We may disclose Personal Information that we collect, or you provide as described in this Privacy Policy:
• to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Public Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy;
• to fulfill the purpose for which you provide it;
• for any other purpose disclosed by us when you provide the information; or
• with your consent.
6. RELATIONSHIP & ROLES
The way in which your Personal Information is processed, and the corresponding level of control that we maintain, depends on whether you access the SeekhoABC Platform as a Direct Customer or as an Institution:
A. Institution processing
The Institution shall retain custody and control over all Institution Data and shall be responsible for determining the purposes and means for which Institution Data is collected, used and disclosed in accordance with privacy laws applicable to the Institution.
In this arrangement, SeekhoABC will only process the personal information to the extent, and in such a manner, as is necessary to deliver curriculum programming services in accordance with the Institution’s instructions.
For Institution accounts, the Institution determines the purposes and means of processing Institution Data. SeekhoABC processes such data on the Institution’s documented instructions and in accordance with applicable Indian data protection law.
B. Direct Customer and Public Website processing
For Direct Customers that have purchased a Direct Subscription, SeekhoABC shall be responsible for determining how Personal Information associated with those Direct Customer accounts and use of the SeekhoABC Platform is collected, used, disclosed and stored.
In these circumstances, SeekhoABC shall be responsible for such Personal Information in accordance with this Privacy Policy.
All Direct Customer account information is managed separately from Institution customer information and such accounts are maintained in separate databases with independent access controls to support data segregation and security.
SeekhoABC is responsible for determining how Personal Information is collected, used, disclosed and stored when adult educators browse our Public Website, download marketing brochures, or request pricing sheets.
Such collection, use, disclosure and storage shall be in accordance with this Privacy Policy.
7. PRIVACY & CORRECTION RIGHTS
Individuals may request access to, correction of, or deletion of their Personal Information where permitted by applicable Privacy Laws.
• For Institutions: Requests relating to Personal Information provided to or by Institutions should be directed to the applicable Institution that is responsible for the student’s account, as that organization determines the purposes for which the information is collected and used.
• For Direct Customers: If you want to review, correct, update, or withdraw consent for the use of your Personal Information, including information relating to a child for whom you are a parent or guardian, please contact SeekhoABC through the support contact published on the SeekhoABC website.
If you would like to confirm whether SeekhoABC holds your Personal Information, withdraw consent, or make a privacy-related comment or request, please contact SeekhoABC through the support contact published on the SeekhoABC website..
We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We may charge you a fee to access your Personal Information; however, we will notify you of any fee in advance.
8. SECURITY SAFEGUARDS & DATA LOCALIZATION
SeekhoABC maintains reasonable technical and organizational security measures designed to safeguard personal data against loss, unauthorized access, misuse, alteration, or disclosure.
• Encryption & Data Localization: Data is protected using appropriate safeguards, including encryption in transit and at rest where appropriate. SeekhoABC requires service providers and sub-processors that process Personal Information on its behalf to maintain confidentiality and implement security measures appropriate to the nature of the data and processing.
• Data Storage and Processing: SeekhoABC may process and store Personal Information using trusted service providers and cloud infrastructure. Where data is transferred or processed outside India, SeekhoABC will take measures required by applicable Indian law to protect Personal Information.
• Breach Notification: In the event of a personal data breach, SeekhoABC will take steps required by applicable Indian law, including notifying affected persons and relevant authorities where legally required.
You are also responsible for helping ensure the security of your Personal Information.
For example:
• Registered educators and School Board administrators are responsible for maintaining the confidentiality of their platform credentials. In accordance with educational data protection best practices, accounts must be monitored to ensure student users do not gain unauthorized access to administrative or educator-facing dashboards. Creating accounts using false identities or unauthorized aliases is strictly prohibited.
• Registered educators and administrators are advised that while SeekhoABC provides enterprise-grade data protection, the endpoint connection remains an active vector. Authorized platform users must employ a secure, authenticated internet connection when interacting with student profiles and explicitly avoid accessing student literacy reports or phonics screening tools over unencrypted public Wi-Fi networks (e.g., airport, library, or café networks) where unauthorized data sniffing risks are structurally heightened.
9. DISPOSITION & RETENTION
Personal Information shall be retained for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Archival Copy Retention Policy: When an educator account or student information profile is flagged for correction or erasure at the direction of the Institution or a parent or guardian where applicable, SeekhoABC will take appropriate steps to delete or de-identify the information, subject to applicable legal and operational retention requirements.
To ensure continuous application availability and infrastructure backup integrity, a secure, unrevised archival copy may be temporarily held within encrypted database backups for the minimum duration required to maintain operational backup synchronization, settle system errors, or fulfill underlying legal framework timelines.
Once these isolated backup rotation windows expire, the information is completely and irreversibly scrubbed or unidentifiably aggregated.
10. INDEPENDENT RECOURSE & REGULATORY OVERSIGHT
If you believe your Personal Information has been handled improperly, you may submit a complaint to SeekhoABC through the support contact published on the SeekhoABC website. You may also have the right to raise concerns with the appropriate authority under applicable Indian law.
11. CHILDREN AND MINORS
Our Public Website is not intended for any user under the age of majority.
The Platform may be made available to students, including children, through an Institution or Direct Customer that subscribes to the Platform.
In those circumstances, Personal Information about students may be provided to SeekhoABC by the Institution or its Authorized Users or collected through a student’s use of the Platform.
SeekhoABC does not knowingly collect Personal Information directly from children except where permitted by applicable law and supported by verifiable consent from a parent or legal guardian, or where an Institution has the appropriate authority to provide the information for educational purposes.
If SeekhoABC learns that Personal Information relating to a child has been collected without the consent or authority required by applicable law, SeekhoABC will take appropriate steps to delete or de-identify that information. Parents or legal guardians may contact SeekhoABC through the support contact published on the SeekhoABC website.
12. CHANGES TO THIS PRIVACY POLICY
We may from time to time change our Privacy Policy in our sole discretion. Changes will be effective when a new version is made available through our Public Website. If you continue to use the SeekhoABC Platform after the changes have been posted, you are accepting these changes. It is your responsibility to read, understand and agree to the terms of this Privacy Policy and any changes made. If you do not agree to this Privacy Policy or any changes, it is your responsibility to cancel your subscription to cease use of our Public Website and the Services.
CONTACT SEEKHOABC PRIVACY OFFICE
For any clarifying structural questions regarding our data architecture or to request compliance documentation for school board evaluations, please contact us: the support contact published on the SeekhoABC website
