Privacy Policy 

Effective Date: 24-Feb-2022

( Updated: 02-Mar-2023 ) 

Applicable to:

UptoSix Letter Formation Mobile App, UptoSix Phonics Mobile App, UptoSix Phonics PLUS Mobile App, UptoSix SpellBoard and uptosix.co.in Website

Article 1 – DEFINITIONS: 

a) APPLICABLE MOBILE APPLICATION: This Privacy Policy will refer to and be  applicable to the Mobile App listed above, which shall hereinafter be referred to as  “Mobile App.” 

b) EFFECTIVE DATE: “Effective Date” means the date this Privacy Policy comes into force and effect. 

c) PARTIES: The parties to this privacy policy are the following data controller: UPTOSIX  KIDS PRIVATE LIMITED (“Data Controller”) and you, as the user of this Mobile App.  Hereinafter, the parties will individually be referred to as “Party” and collectively as  “Parties.” 

d) DATA CONTROLLER: Data Controller is the publisher, owner, and operator of the  Mobile App and is the Party responsible for the collection of information described  herein. Data Controller shall be referred to either by Data Controller’s name or “Data  Controller,” as listed above. If Data Controller or Data Controller’s property shall be  referred to through first-person pronouns, it shall be through the use of the following: us,  we, our, ours, etc. 

e) YOU: Should you agree to this Privacy Policy and continue your use of the Mobile  App, you will be referred to herein as either you, the user, or if any second-person  pronouns are required and applicable, such pronouns as ‘your”, “yours”, etc. 

f) PERSONAL DATA: “Personal DATA” means personal data and information that we  obtain from you in connection with your use of the Mobile App that is capable of  identifying you in any manner. 

Article 2 – GENERAL INFORMATION: 

This privacy policy (hereinafter “Privacy Policy”) describes how we collect and use the  Personal Data that we receive about you, as well as your rights in relation to that  Personal Data, when you visit our Mobile App and interact with it in any way, including  passively. 

This Privacy Policy does not cover any information that we may receive about you  through sources other than the use of our Mobile App. The Mobile App may link out to  

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other websites or mobile applications, but this Privacy Policy does not and will not apply  to any of those linked websites or applications. 

We are committed to the protection of your privacy while you use our Mobile App. 

By continuing to use our Mobile App, you acknowledge that you have had the chance to  review and consider this Privacy Policy, and you acknowledge that you agree to it. This  means that you also consent to the use of your information and the method of disclosure  as described in this Privacy Policy. If you do not understand the Privacy Policy or do not  agree to it, then you agree to immediately cease your use of our Mobile App. 

Article 3 -CONTACT: 

The Party responsible for the processing of your personal data is as follows: UPTOSIX  KIDS PRIVATE LIMITED. The Data Controller may be contacted as follows: 

E: Dev@uptosix.co.in 

C103, Veracious Lansdale, Whitefield, Bangalore, Karnataka, India – 560066 M:+91 9845230435 (Indian Standard Time 1:00 PM – 9:00 PM) 

The Data Controller and operator of the Mobile App are one and the same. 

Article 4 – LOCATION: 

The location where the data processing activities take place is as follows: C103, Veracious Lansdale, Whitefield, Bangalore, Karnataka, India – 560066 

Article 5 – MODIFICATIONS AND REVISIONS: 

We reserve the right to modify, revise, or otherwise amend this Privacy Policy at any  time and in any manner. If we do so, however, we will notify you and obtain your consent  to the change in processing. Unless we specifically obtain your consent, any changes to  the Privacy Policy will only impact the information collected on or after the date of the  change. It is also your responsibility to periodically check this page for any such  modification, revision or amendment. 

Article 6 – THE PERSONAL DATA WE RECEIVE FROM YOU: 

Depending on how you use our Mobile App, you will be subject to different types of  Personal Data collected and different manners of collection: 

a) Registered users: You, as a user of the Mobile App, may be asked to register in  order to use the Mobile App in a legal manner. 

If you are using the latest updated version of the app from the store, we do not collect any user details anymore.

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If you are using an older version of the app, during the process of your registration, we will collect some of the following  Personal Data from you through your voluntary disclosure: 

– Parent’s or Teacher’s email address for registration 

The lawful basis of collecting email address are: Contractual obligation, legal  obligation, consent and legitimate interest 

Personal Data may be asked for in relation to: 

I) Interaction with our representatives in any way 

II) receiving notifications by text message or email about marketing III) receiving general emails from us 

IV) commenting on our content or other user-generated content on our Mobile  App, such as blogs, articles, photographs or videos, or participating in our  forums, bulletin boards, chat rooms or other similar features 

By undergoing the registration process, you consent to us collecting your Personal  Data, including the Personal Data described in this clause, as well as storing, using  or disclosing your Personal Data in accordance with this Privacy Policy. 

b) Unregistered users: If you are a passive user of the Mobile App and do not  register at all, you may still be subject to certain passive data collection (“Passive  Data Collection”). Such Passive Data Collection may include through cookies, as  described below, IP address information, location information, and certain browser  data, such as history and/or session information. 

If you are using the latest updated version of the app from the store, we do not collect any user details anymore.

c) All users: The Passive Data Collection that applies to Unregistered users shall  also apply to all other users and/or visitors of our Mobile App. 

If you are using the latest updated version of the app from the store, we do not collect any user details anymore.

d) Email Marketing: You may be asked to provide certain Personal Data, such as  your name and email address, for the purpose of receiving email marketing  communications. This information will only be obtained through your voluntary  disclosure and you will be asked to affirmatively opt-in to email marketing  communications. 

If you are using the latest updated version of the app from the store, we do not collect any user details anymore.

e) User Experience: From time to time we may request information from you to  assist us in improving our Mobile App, such as demographic information or your  particular preferences. 

If you are using the latest updated version of the app from the store, we do not collect any user details anymore.

f) Content Interaction: Our Mobile App may allow you to comment on the content  that we provide or the content that other users provide, such as blogs, multimedia,  or forum posts. If so, we may collect some Personal Data from you at that time,  such as, but not limited to, username or email address. 

If you are using the latest updated version of the app from the store, we do not collect any user details anymore.

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g) Combined or Aggregated Information: We may combine or aggregate some of  your Personal Data in order to better serve you and to better enhance and update  our Mobile App for your and other consumers’ use. 

We may also share such aggregated information with others, but only if that  aggregated information does not contain any Personal Data

If you are using the latest updated version of the app from the store, we do not collect any user details anymore.

Article 7 – THE PERSONAL DATA WE RECEIVE AUTOMATICALLY: 

Cookies: We may collect information from you through automatic tracking systems  (such as information about your browsing preferences) as well as through information  that you volunteer to us (such as information that you provide during a registration  process or at other times while using the Mobile App, as described above). 

For example, we use cookies to make your browsing experience easier and more  intuitive: cookies are small strings of text used to store some information that may  concern the user, his or her preferences or the device they are using to access the  

internet (such as a computer, tablet, or mobile phone). Cookies are mainly used to adapt  the operation of the site to your expectations, offering a more personalized browsing  experience and memorizing the choices you made previously. 

A cookie consists of a reduced set of data transferred to your browser from a web server  and it can only be read by the server that made the transfer. This is not executable code  and does not transmit viruses. 

Cookies do not record or store any Personal Data. If you want, you can prevent the use  of cookies, but then you may not be able to use our Mobile App as we intend. To  proceed without changing the options related to cookies, simply continue to use our  Mobile App. 

Technical cookies: Technical cookies, which can also sometimes be called HTML  cookies, are used for navigation and to facilitate your access to and use of the site.  They are necessary for the transmission of communications on the network or to  supply services requested by you. The use of technical cookies allows the safe and  efficient use of the site. 

You can manage or request the general deactivation or cancellation of cookies  through your browser. If you do this though, please be advised this action might  slow down or prevent access to some parts of the site. 

Cookies may also be retransmitted by an analytics or statistics provider to collect  aggregated information on the number of users and how they visit the Mobile App.  These are also considered technical cookies when they operate as described. 

Temporary session cookies are deleted automatically at the end of the browsing  session – these are mostly used to identify you and ensure that you don’t have to log  

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in each time – whereas permanent cookies remain active longer than just one  particular session. 

Third-party cookies: We may also utilize third-party cookies, which are cookies  sent by a third-party to your computer. Permanent cookies are often third-party  cookies. The majority of third-party cookies consist of tracking cookies used to  identify online behavior, understand interests and then customize advertising for  users. 

Third-party analytical cookies may also be installed. They are sent from the domains  of the aforementioned third parties external to the site. Third-party analytical cookies  are used to detect information on user behavior on our Mobile App. This place  anonymously, in order to monitor the performance and improve the usability of the  site. Third-party profiling cookies are used to create profiles relating to users, in  order to propose advertising in line with the choices expressed by the users  themselves. 

Profiling cookies: We may also use profiling cookies, which are those that create  profiles related to the user and are used in order to send advertising to the user’s  browser. 

When these types of cookies are used, we will receive your explicit consent. 

Support in configuring your browser: You can manage cookies through the  settings of your browser on your device. However, deleting cookies from your  browser may remove the preferences you have set for this Mobile App. 

For further information and support, you can also visit the specific help page of the  web browser you are using: 

– Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or allow-cookies 

– Firefox: https://support.mozilla.org/en-us/kb/enable-and-disable-cookies website-preferences 

– Safari: http://www.apple.com/legal/privacy/ 

– Chrome: https://support.google.com/accounts/answer/61416?hl=en – Opera: http://www.opera.com/help/tutorials/security/cookies/ 

Log Data: Like all websites and mobile applications, this Mobile App also makes  use of log files that store automatic information collected during user visits. The  different types of log data could be as follows: 

– internet protocol (IP) address; 

– type of browser and device parameters used to connect to the Mobile App; Page 5 of 10

– name of the Internet Service Provider (ISP); 

– date and time of visit; 

– web page of origin of the user (referral) and exit; 

– possibly the number of clicks. 

The aforementioned information is processed in an automated form and collected in an  exclusively aggregated manner in order to verify the correct functioning of the site, and  for security reasons. This information will be processed according to the legitimate  interests of the Data Controller. 

For security purposes (spam filters, firewalls, virus detection), the automatically recorded  data may also possibly include Personal Data such as IP address, which could be used,  in accordance with applicable laws, in order to block attempts at damage to the Mobile  App or damage to other users, or in the case of harmful activities or crime. Such data  are never used for the identification or profiling of the user, but only for the protection of  the Mobile App and our users. Such information will be treated according to the  legitimate interests of the Data Controller. 

Article 8 – THIRD PARTIES: 

We may utilize third-party service providers (“Third-Party Service Providers”), from time  to time or all the time, to help us with our Mobile App, and to help serve you. 

We may use Third-Party Service Providers to assist with information storage (such  as cloud storage). 

We may provide some of your Personal Data to Third-Party Service Providers in  order to help us track usage data, such as referral websites, dates and times of  page requests, etc. We use this information to understand patterns of usage of, and  to improve, the Mobile App. 

We may use Third-Party Service Providers to host the Mobile App. In this instance,  the Third-Party Service Provider will have access to your Personal Data. 

Some of our Third-Party Service Providers may be located outside of the United  States and may not be subject to U.S. privacy laws. The countries or regions in  which our Third-Party Service Providers may be located include: 

Asia, Africa, Central and Eastern Europe, Western Europe, Mediterranean &  Middle East, South America 

We only share your Personal Data with a Third-Party Service Provider if that  provider agrees to our privacy standards as set out in this Privacy Policy. 

Your Personal Data will not be sold or otherwise transferred to other third parties  without your approval

If you are using the latest updated version of the app from the store, we do not collect any user details anymore.

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Notwithstanding the other provisions of this Privacy Policy, we may provide your  Personal Data to a third party or to third parties in order to protect the rights,  property or safety, of us, our customers or third parties, or as otherwise required by  law. 

We will not knowingly share your Personal Data with any third parties other than in  accordance with this Privacy Policy. 

If your Personal Data might be provided to a third party in a manner that is other  than as explained in this Privacy Policy, you will be notified. You will also have the  opportunity to request that we not share that information. 

In general, you may request that we do not share your Personal Data with third  parties. Please contact us via email, if so. Please be advised that you may lose  access to certain services that we rely on third-party providers for. 

Article 9 – HOW PERSONAL DATA IS STORED: 

We use secure physical and digital systems to store your Personal Data when  appropriate. We ensure that your Personal Data is protected against unauthorized  access, disclosure, or destruction. 

Please note, however, that no system involving the transmission of information via the  internet, or the electronic storage of data, is completely secure. However, we take the  protection and storage of your Personal Data very seriously. We take all reasonable  steps to protect your Personal Data. 

Personal Data is stored throughout your relationship with us. We delete your Personal  Data upon request for cancelation of your account or other general request for the  deletion of data. 

In the event of a breach of your Personal Data, you will be notified in a reasonable time  frame, but in no event later than two weeks, and we will follow all applicable laws  regarding such breach. 

If you are using the latest updated version of the app from the store, we do not collect any user details anymore.

Article 10 – PURPOSES OF PROCESSING OF PERSONAL DATA: 

We primarily use your Personal Data to help us provide a better experience for you on  our Mobile App and to provide you the services and/or information you may have  requested, such as use of our Mobile App. 

Information that does not identify you personally, but that may assist in providing us  broad overviews of our customer base, will be used for market research or marketing  efforts. Such information may include, but is not limited to, interests based on your  cookies. 

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Personal Data that may be considering identifying may be used for the following: a) Improving your personal user experience 

b) Communicating with you about your user account with us 

c) Marketing and advertising to you, including via email 

d) Advising you about updates to the Mobile App or related Items 

If you are using the latest updated version of the app from the store, we do not collect any user details anymore.

Article 11 – DISCLOSURE OF PERSONAL DATA: 

Although our policy is to maintain the privacy of your Personal Data as described herein,  we may disclose your Personal Data if we believe that it is reasonable to do so in certain  cases, in our sole and exclusive discretion. Such cases may include, but are not limited  to: 

a) To satisfy any local, state, or Federal laws or regulations 

b) To respond to requests, such discovery, criminal, civil, or administrative process,  subpoenas, court orders, or writs from law enforcement or other governmental or  legal bodies 

c) To bring legal action against a user who has violated the law or violated the terms  of use of our Mobile App 

d) As may be necessary for the operation of our Mobile App 

e) To generally cooperate with any lawful investigation about our users 

f) If we suspect any fraudulent activity on our Mobile App or if we have noticed any  activity which may violate our terms or other applicable rules 

Article 12 – OPTING OUT OF TRANSMITTALS FROM US: 

From time to time, we may send you informational or marketing communications related  to our Mobile App such as announcements or other information. If you wish to opt-out of  such communications, you may contact the following email: Dev@uptosix.co.in. You  may also click the opt-out link which will be provided at the bottom of any and all such  communications. 

Please be advised that even though you may opt-out of such communications, you may  still receive information from us that is specifically about your use of our Mobile App or  about your account with us. 

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By providing any Personal Data to us, or by using our Mobile App in any manner, you  have created a commercial relationship with us. As such, you agree that any email sent  from us or third-party affiliates, even unsolicited email, shall specifically not be  considered SPAM, as that term is legally defined. 

Article 13 – MODIFYING, DELETING, AND ACCESSING YOUR INFORMATION: 

If you wish to modify or delete any information we may have about you, or you wish to  simply access any information we have about you, you may reach out to us at the  following email address: Dev@uptosix.co.in. 

Article 14 – ACCEPTANCE OF RISK: 

By continuing to our Mobile App in any manner, use the Product, you manifest your  continuing asset to this Privacy Policy. You further acknowledge, agree and accept that  no transmission of information or data via the internet is not always completely secure,  no matter what steps are taken. You acknowledge, agree and accept that we do not  guarantee or warrant the security of any information that you provide to us, and that you  transmit such information at your own risk. 

Article 15 – YOUR RIGHTS: 

You have many rights in relation to your Personal Data. Specifically, your rights are as  follows: 

– the right to be informed about the processing of your Personal Data – the right to have access to your Personal Data 

– the right to update and/or correct your Personal Data 

– the right to portability of your Personal Data 

– the right to oppose or limit the processing of your Personal Data 

– the right to request that we stop processing and delete your Personal Data – the right to block any Personal Data processing in violation of any applicable law 

– the right to launch a complaint with the Federal Trade Commission (FTC) in the  United States or applicable data protection authority in another jurisdiction 

Such rights can all be exercised by contacting us at the relevant contact information  listed in this Privacy Policy. 

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Article 16 – PROTECTING CHILDREN’s PRIVACY: 

Our mobile App is intended to be used by children under 8 years only with the consent of  a parent or by a teacher. We only collect the Parent’s or Teacher’s email address for  registration. We collect usage information when a child or parent or teacher uses the  App, which we associate with the parent’s or teacher’s information. We do not collect  other personal information from the child. 

If you are using the latest updated version of the app from the store, we do not collect any user details anymore.

Article 17 – CONTACT INFORMATION: 

If you have any questions about this Privacy Policy or the way we collect information  from you, or if you would like to launch a complaint about anything related to this Privacy  Policy, you may contact us at the following email address: Dev@uptosix.co.in. 

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