Privacy Policy

1. Information We Collect

We may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly with you ("Personal Information") when you use our Services. The Personal Information we collect falls into three categories: (1) information you provide to us, (2) information we collect through automated methods, and (3) information we collect from other sources, each further detailed below. We will collect, use, and disclose such Personal Information pursuant to this Policy and applicable law.

Our AI-enabled Services allow you to upload various content (e.g., lecture or meeting audio, PDFs, textbooks, and other documents). You control what you upload. Please use discretion and do not upload sensitive or personal information (e.g., health/medical data, Aadhaar numbers, PAN numbers, passport numbers, financial account details, or passwords). This is for your protection, as nothing is 100% secure on the internet. Please upload with caution.

Information You Provide to Us

We collect Personal Information that you provide directly to us. This may occur in the following ways:

Account Registration: When you register for an account, we will collect your name, email address, and any other information you choose to provide. If you choose to login with your Google account, you will need to provide your log-in information for your Google account through the Services, including your email address and password. We do not retain the Google account credentials that you submit. We maintain only whether Google verifies your account credentials.

Subscription Information: In addition to account registration information, if you purchase a subscription, you will also be required to submit certain Personal Information to facilitate the purchase and use of the subscription.

Order & Payment Data: We use a PCI-compliant payment processor to help us facilitate payment for subscriptions. Snaplearn does not receive your full credit or debit card number or other financial information when you make a payment, and such information is provided directly to our payment processor. However, Snaplearn does receive information about your transaction, subscription purchased, and your contact information (e.g., name and billing address) to administer your subscription.

Service-Related Information: We collect Personal Information that you provide in the course of using the Services or seeking support, such as any Personal Information contained in the content you submit. This includes information submitted to our AI-powered chat bot.

Contacting Us: If you contact us, we will collect and use your name and contact information and any additional Personal Information you provide in your message, if applicable.

Feedback: When you provide comments or feedback about our Services, the content available via our Services, or our products, including reviews ("Feedback"), we will collect Personal Information that you submit along with your Feedback.

Data Automatically Collected

We may use automated technologies to collect Personal Information from your computer system or mobile device when you use our Services. This may include the following:

Cookies & Other Tracking Technologies: We may use cookies, web beacons, pixel tags and other tracking technologies (collectively "Tracking Technologies") on our Services. The types of Tracking Technologies we use, and their purposes are further detailed in the How We Use Your Personal Information section below. Most browsers automatically accept Tracking Technologies. You may be able to disable Tracking Technologies by changing your browser settings, depending on your browser, but disabling Tracking Technologies may impact your use and enjoyment of the Services. Not all features or functions of the Services may work properly if you disable Tracking Technologies. You cannot disable all Tracking Technologies, such as those that are essential to the functioning of the Services.

The Tracking Technologies on our Services may collect information such as:

• IP addresses assigned to the computers and other devices you use
• Your internet service provider
• Device ID number
• Approximate geographic location
• Browser type
• Site pages visited
• Websites you access before and after visiting the Services
• Data related to how and when you use the Services

Data from Other Sources

We obtain Personal Information about individuals from other sources, including third parties and existing users of the Services, and we may combine that Personal Information with other data we may already have. We also may receive your Personal Information when a user of the Services sends you content via the Services or when a user uploads content that contains your Personal Information.

2. How We Use Your Information

We use Personal Information that we collect for the following purposes:

As Stated or Agreed to at the Point of Collection: We may use Personal Information for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use Personal Information to respond to your questions, comments, or complaints. We may also use as otherwise requested or consented to by you.

Artificial Intelligence: We may use your Personal Information to further develop our artificial intelligence and improve our Service.

Administration: We use Personal Information for administrative purposes, such as facilitating transactions and subscriptions, managing accounts, to inform our business strategies, and to understand demographics and user preferences.

Management of the Services: We use Personal Information to manage the Services, such as troubleshooting problems, improving content and functionality, training and development (including for training AI tools), conducting statistical and other analyses, and to customize the Services to you and our users. We also use Personal Information to help detect and thwart fraudulent activities.

Feedback: We do not treat Feedback as confidential, and we may use Feedback for any purpose in our sole discretion so long as it does not personally identify you. Feedback may be used without attribution or compensation to you.

Business Analytics: We use Personal Information for business analytics purposes, including consumer and operations research, to assess the effectiveness of our Services, marketing and advertising, and to analyze market trends and customer demand.

Email Communications: We use Personal Information to send you service-related and transactional messages (for example, when your notes or summaries are ready), account or security notices, and updates about our Services, Terms of Service, or this Policy. We may use third-party service providers to deliver these communications. We do not currently send promotional or advertising emails. If we decide to do so in the future, we will provide any notices or obtain any consents required by law, and you may opt out at any time using the unsubscribe link in the email. Opting out of marketing emails does not affect your receipt of transactional or other non-marketing communications.

To Protect Our Rights: We may use Personal Information to protect our legal rights or interests, or those of other parties, including to bring a legal action against you or anyone who may be causing harm to us, our Services, or to other users of the Services. We may also use Personal Information to seek business, financial or legal advice, and to respond to other legal requests.

Create Aggregated and De-Identified Data: We may process Personal Information to create de-identified and aggregated data. Any such de-identified and aggregated data is no longer subject to this Privacy Policy. Snaplearn is the sole and exclusive owner of such de-identified and anonymized information.

How We Use Data Collected by Tracking Technologies

We use Tracking Technologies to: (i) make our Services function properly, (ii) provide personalized experiences, (iii) tailor our interactions with you, (iv) help with our marketing efforts, (v) provide us with valuable data and statistics about the usage and effectiveness of our Services, and (vi) to help us improve our Services. We also use Tracking Technologies and third-party Tracking Technologies as follows:

Google Analytics: We use Google Analytics to collect and process information about your use of the Services.

Google Ads: We use Google Ads to serve ads across various websites. To opt-out of this type of advertising by Google, to customize your ad preferences, or to limit Google's collection or use of such data, visit Google's Ad Settings and follow Google's personalized ad opt-out instructions.

Google Single Sign On: If you elect to use Google single sign on, these single sign-on features may require us to implement cookies, plug-ins, and application protocol interfaces (APIs) provided by Google to facilitate those communications. In addition, by using these single sign-on features, you allow us to disclose Personal Information with Google. We do not and cannot control any policies or terms of Google. All information you have provided to Google is subject to Google's privacy policy.

Online Behavioral Advertising: We use third parties and/or service providers to provide interest-based advertising services, including the Social Media platforms above. These services may serve advertisements on our behalf that are customized based on predictions about your interests generated from your visits to websites (including the Services) over time and across different websites. The data collected may be associated with your Personal Information. These advertisements may appear on the Services and on other websites and may be sent to you via email.

To change your preferences with respect to certain online ads or to obtain more information about online behavioral advertising, visit the National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads. Opting-out of targeted advertising does not opt you out of all ads on all devices, just those targeted to you on the devices that you opt-out. PLEASE NOTE: We do not operate or control these third party services, and there may be additional ways for you to opt out of online advertising. By opting out, you will continue to see ads, but ads may not be as relevant to your interests.

DNT Signals: Various browsers allow a "do not track" ("DNT") setting, which sends a signal to websites visited by an individual about their browser DNT setting. At this time, there is no general agreement on how companies should interpret DNT signals. Therefore, at this time our Services do not respond to "Do Not Track" signals transmitted by browsers.

3. Retention of Personal Information

We will keep Personal Information for the period necessary to fulfill the purposes described in this Policy, unless a longer retention period is permitted or required by law. We take reasonable steps to delete the Personal Information we collect when: (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, or (3) if you ask us to delete your Personal Information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We may also decide to delete your Personal Information if we believe it is incomplete, inaccurate, or that our continued storage of your Personal Information is contrary to our legal obligations or business objectives. When we delete your Personal Information, it will be removed from our active servers and databases; however, it may remain in our archives when it is not practical or possible to delete it.

4. Disclosure of Personal Information

We may disclose Personal Information to the following categories of parties, in compliance with applicable laws:

Affiliates: We may disclose Personal Information to our affiliates who have a need to know the information for our business purposes.

Customers: We may disclose Personal Information to organizations and educational institutions with whom you are affiliated in order to enforce our policies and terms.

Third Parties and/or Service Providers: We may disclose Personal Information to third parties and service providers that support our Services (e.g., hosting, management, analytics, troubleshooting, security, advertising, and marketing). We do not operate in-house AI models; instead, we utilize external AI providers (currently OpenAI®, Grok®, Anthropic®, and Modal Labs) to host and process content that powers certain features. When you use our AI-enabled Services, your content (which may include Personal Information) is transmitted to and processed by these providers to fulfill your requests. We take commercially reasonable steps to ensure our vendors, contractors, and business partners provide at least the same level of protection for Personal Information as we do.

Government Officials / Law Enforcement: We will cooperate with law enforcement and other governmental agencies in India, and may disclose Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose Personal Information by our legal counsel, (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Snaplearn or any other party, or (iv) as otherwise appropriate under applicable Indian law including the Information Technology Act, 2000 and the Digital Personal Data Protection Act, 2023.

Professional Advisors: We may disclose Personal Information to our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to Snaplearn.

Subsequent Owner or Operator: We may transfer your Personal Information to a successor entity or an operator upon a merger, consolidation, acquisition, bankruptcy, dissolution, liquidation or other corporate reorganization, to a purchaser of all or a portion of our assets, or pursuant to a financing arrangement or co-promotional agreement.

Others: We may disclose Personal Information to third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure.

5. Children's Information

The Services are not directed at children under 16 years of age. We do not knowingly collect, sell, use, or share Personal Information from children under 16. If we obtain actual knowledge that any Personal Information has been provided by a child under the age of 16, we will promptly delete that information. If a parent or legal guardian learns that their child provided us with Personal Information without his or her consent, please contact us and we will make commercially reasonable attempts to delete such Personal Information.

6. Data Security

We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. Our security practices are aligned with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 issued under the Information Technology Act, 2000.

You understand that no data transmission over the internet can be guaranteed to be 100% secure. While we strive to protect Personal Information, we do not guarantee the security of Personal Information and you provide Personal Information at your own risk.

7. Cross-Border Data Transfers

If you access the Services from outside India, please be aware that Personal Information may be transferred to, stored in, and processed in India and in other countries where our service providers operate. These countries may have data protection laws that differ from those of your jurisdiction. By using the Services, you consent to such transfers. We take commercially reasonable steps to ensure that your Personal Information is treated securely and in accordance with this Policy wherever it is processed.

Where Personal Information is transferred outside India, we ensure such transfers are carried out in compliance with applicable Indian law, including the Digital Personal Data Protection Act, 2023, and any rules or regulations issued thereunder.

8. Third-Party Websites

The Services may link to, or be linked from, websites not controlled by us. We are not responsible for third parties' privacy policies or practices. This Policy does not apply to any third-party websites or to any data that you provide to third parties. You should read the privacy policy for each website that you visit.

We are active on social media, including Instagram®, TikTok®, and YouTube® ("Social Media"). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Services and our Social Media pages any comments or content that you post on our Social Media pages. Your use of Social Media is governed by the privacy policies and terms of the providers that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.

9. Contact Us

If you have questions or concerns regarding this Policy, contact us at:

Shree Mahaveer Synthetics (operating as Snaplearn)
Address: 207, Vastugram Apartment, Vesu, Surat - 395007, Gujarat, India
Phone: +91 8769457647 / +91 97126 00676
Email: [email protected]
Legal / Privacy Notices: [email protected]

India Privacy Exhibit

This India Privacy Exhibit contains additional information for users who are residents of India. In the event of a conflict between this Exhibit and the remainder of this Policy, this Exhibit shall take precedence for Indian residents.

This section is governed by the Digital Personal Data Protection Act, 2023 ("DPDP Act") and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("IT SPDI Rules"), as applicable.

A. Categories of Personal Data We Collect

In the course of providing the Services, we collect the following categories of Personal Data as defined under the DPDP Act:

• Identifiers: name, email address, username, IP address, device ID, and similar identifiers.
• Contact Information: email address, phone number, and billing address.
• Payment & Transaction Data: subscription details and transaction records (not full card numbers — these are handled by our PCI-compliant payment processor).
• Usage Data: pages visited, features used, session duration, and interaction data.
• User-Generated Content: content you upload to the Services, including audio, PDFs, text, and other documents.
• Technical Data: browser type, operating system, approximate location, and device information.
• Communications: messages and feedback you send to us.

B. Legal Basis for Processing

We process your Personal Data on the following bases under the DPDP Act, 2023:

• Consent: Where you have given us your consent to process your Personal Data for a specific purpose, such as at account registration or when starting a free trial.
• Contractual Necessity: Where processing is necessary to perform our contract with you, including providing the Services you have subscribed to.
• Legitimate Uses: Where processing is necessary for legitimate purposes as recognized under the DPDP Act, including compliance with legal obligations, prevention of fraud, and protection of our legal rights.

C. Sensitive Personal Data or Information (SPDI)

Under the IT (SPDI) Rules, 2011, the following categories of information are classified as Sensitive Personal Data or Information: passwords, financial information (bank account, credit/debit card details), physical, physiological and mental health condition, sexual orientation, medical records and history, and biometric information.

We do not intentionally collect SPDI through the Services. You are advised not to upload any such information. If we inadvertently receive SPDI, we will handle it in accordance with the IT (SPDI) Rules, 2011 and delete it promptly upon becoming aware.

D. Your Rights as a Data Principal

As a Data Principal under the Digital Personal Data Protection Act, 2023, you have the following rights:

Right to Access Information
You have the right to request confirmation of whether we are processing your Personal Data, a summary of the Personal Data we hold about you, and the identities of all Data Fiduciaries and Data Processors with whom your Personal Data has been shared.

Right to Correction and Erasure
You have the right to request that we correct inaccurate or misleading Personal Data we hold about you, complete incomplete Personal Data, and erase Personal Data that is no longer necessary for the purpose for which it was collected, subject to our legal obligations to retain certain data.

Right to Grievance Redressal
You have the right to have your grievances addressed by us in a timely manner. If you have a complaint or concern about how we handle your Personal Data, you may contact our Grievance Officer at [email protected]. We will acknowledge your complaint within 48 hours and endeavour to resolve it within 30 days.

Right to Nominate
You have the right to nominate any other individual who shall, in the event of your death or incapacity, exercise your rights under the DPDP Act on your behalf.

Right to Withdraw Consent
You have the right to withdraw your consent to the processing of your Personal Data at any time. Withdrawal of consent will not affect the lawfulness of processing carried out prior to such withdrawal. To withdraw consent, please contact us at [email protected]. Please note that withdrawal of consent may affect your ability to use certain features of the Services.

E. Grievance Officer

In accordance with the Information Technology Act, 2000 and the IT (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, we have appointed a Grievance Officer to address complaints and concerns about our privacy practices:

Name: Saurav Chandawad
Designation: Grievance Officer
Organisation: Shree Mahaveer Synthetics (operating as Snaplearn)
Address: 207, Vastugram Apartment, Vesu, Surat - 395007, Gujarat, India
Email: [email protected]
Phone: +91 8769457647
Response Time: We will acknowledge complaints within 48 hours and resolve them within 30 days of receipt.

F. Data Localisation

We are committed to complying with applicable data localisation requirements under Indian law. Where required by law, Personal Data of Indian residents will be stored on servers located in India. Please refer to our current data processing arrangements by contacting us at the details provided in Section 9.

G. How to Exercise Your Indian Privacy Rights

To exercise any of the rights described in this Exhibit, you may submit your request to us by:

• Emailing us at [email protected] with the subject line "Privacy Rights Request — India"
• Writing to us at: 207, Vastugram Apartment, Vesu, Surat - 395007, Gujarat, India

We will contact you to confirm receipt of your request and may require sufficient information to verify your identity before processing your request. We will respond to verified requests within 30 days. We may deny a request if we are unable to verify your identity or if applicable law permits or requires us to do so.

H. Complaints to the Data Protection Board

If you are not satisfied with our response to your privacy complaint or request, you have the right to lodge a complaint with the Data Protection Board of India once it is established under the Digital Personal Data Protection Act, 2023. For updates on the Board's establishment and complaint procedures, please refer to the Ministry of Electronics and Information Technology (MeitY) website.