Privacy Policy

1. Introduction and Scope

Cleveratti Learn (referred to in this document as “we,” “us,” or “our”) is committed to protecting the privacy of every person who interacts with our educational programs and digital platforms. This Privacy Policy explains how we collect, use, share, and protect personal information in connection with our website (cleverattilearn.com), mobile applications, offline learning centres, franchise-delivered programs, and any related services (collectively, the “Services”).

This Policy applies to:

• Visitors who browse our website or landing pages
• Prospective learners who submit enquiry or lead forms
• Enrolled students across our three programs: Personality Development Master Program, Professional Digital Marketing Program, and AI for Career & Business
• Franchise partners and their authorised representatives
• Any other individual whose personal data we process in connection with our Services

Please read this Policy carefully. By accessing our website, submitting an enquiry, or enrolling in any of our programs, you acknowledge that you have read and understood this Policy. If you do not agree, please refrain from using our Services.

2. Business Identity and Contact Details

For all privacy-related requests, grievances, or questions, please use the contact details provided in Section 24 of this Policy.

3. Definitions

In this Policy, the following terms have the meanings set out below:

• “Personal Data” means any information that identifies or can identify a natural person, directly or indirectly, including name, email address, phone number, device identifiers, and financial information.
• “Learner” or “Student” means a person enrolled in, or applying to, any Cleveratti Learn program.
• “Franchise Partner” means a business entity or individual licensed to deliver Cleveratti Learn programs through an authorised learning centre.
• “Processing” means any operation performed on personal data, including collection, recording, storage, use, disclosure, and erasure.
• “Service Provider” means a third party engaged by us to perform functions on our behalf, such as payment processors, cloud-hosting providers, and communication platforms.
• “DPDP Act” means India's Digital Personal Data Protection Act, 2023 and any rules or regulations made thereunder.

4. Personal Information We Collect

We collect the following categories of personal data, depending on how you interact with us:

5. How We Collect Information

We collect personal data through the following means:

• Directly from you when you fill in an enquiry form, enrol in a program, contact our support team, or otherwise communicate with us
• Automatically through our website and application via cookies, web beacons, and analytics tools
• From franchise partners who collect enrolment and attendance data at authorised learning centres
• From social-media platforms when you interact with our paid or organic content and submit your details through lead-generation forms
• From payment gateways and financial institutions in connection with fee transactions

6. Purpose of Collecting and Using Information

We collect and process personal data for the following purposes:

• Creating and managing learner and partner accounts on our platforms
• Processing enrolments, issuing offer letters (ToT certificates), and administering programs
• Facilitating fee collection, invoicing, receipts, and refunds
• Delivering course content, study materials, and assessments
• Communicating program updates, class schedules, and important notices
• Providing customer and academic support
• Sending information about new programs, events, and promotions (with your consent)
• Conducting internal research, quality improvement, and curriculum development
• Preventing fraud, misrepresentation, or unauthorised access
• Complying with applicable laws, regulations, and government directives
• Issuing certificates, transcripts, and placement-assistance services
• Operating our franchise network and supporting franchise partners

7. Consent and Lawful Processing

We process your personal data on one or more of the following lawful bases:

• Consent — where you have freely, specifically, and unambiguously given consent (e.g., for marketing communications). You may withdraw consent at any time by writing to privacy@cleverattilearn.com; withdrawal does not affect processing carried out before withdrawal.
• Contract — where processing is necessary to perform the enrolment agreement or take pre-contractual steps at your request.
• Legal obligation — where we are required to process data to comply with applicable law (e.g., tax records, regulatory reporting).
• Legitimate interests — where processing is necessary for our legitimate business interests, provided those interests are not overridden by your rights and freedoms.

In accordance with the DPDP Act, 2023, when we seek your consent, we will provide a clear, plain-language notice specifying the personal data to be processed, the purposes, your rights, and the mechanism to file a complaint. Consent requests will be presented separately from other terms and conditions. Withdrawing consent is as straightforward as providing it.

8. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to enhance your experience. The categories of cookies we use include:

You may manage your cookie preferences at any time through the cookie-preference banner on our website or through your browser settings. Disabling certain cookies may affect website functionality.

9. Personalised Advertising and Profiling

We may use your browsing behaviour on our website, program enquiries, and interactions with our content to personalise recommendations and advertisements. For example, if you viewed information about the Personality Development Master Program, you may see related advertising on social-media platforms such as Instagram or Facebook.

We do not use automated decision-making or profiling in a manner that produces legal or similarly significant effects on you without your explicit consent. You may opt out of personalised advertising by managing your cookie preferences or contacting us at privacy@cleverattilearn.com.

10. Payment Information

Cleveratti Learn accepts program fees through third-party payment gateways (such as Razorpay, PayU, or similar providers). We do not store full card numbers, CVV codes, or other sensitive payment-card data on our servers. Our payment partners maintain their own security certifications and privacy practices.

We retain:

• Transaction reference numbers and confirmation status
• Amount paid, date of payment, and fee-head details
• Details required for tax invoices and GST compliance

You are encouraged to review the privacy policy of the applicable payment gateway when making a transaction.

11. Sharing of Personal Information

We do not sell your personal data. We may share it with the following categories of recipients, strictly as necessary:

• Franchise Partners — to facilitate program delivery, attendance, and assessments at authorised learning centres
• Payment Gateways and Banks — to process fee transactions securely
• Cloud-Hosting and Technology Providers — to operate our website, LMS, CRM, and data-storage systems
• Communication Platforms — to send emails, SMS, and WhatsApp notifications (e.g., MSG91, SendGrid)
• Analytics and Advertising Partners — where you have consented, for website analytics and targeted campaigns
• Professional Advisers — accountants, auditors, and legal counsel bound by confidentiality obligations
• Government Authorities and Regulators — when required by law, court order, or regulatory directive

All service providers are contractually required to process personal data only as instructed by us and to maintain appropriate security measures.

12. Franchise Partners and Learning Centres

Cleveratti Learn operates through a franchise model. When you enrol at a franchise-operated learning centre, relevant personal data (name, contact details, attendance records, and performance data) will be shared with the Franchise Partner responsible for that centre, for the purposes of program delivery and academic support.

Franchise Partners are required under their agreements with us to process learner data only for program-related purposes and in compliance with applicable privacy law. However, Franchise Partners may maintain their own internal privacy practices for their business operations. We are not responsible for data processing conducted by Franchise Partners outside the scope of our programs.

13. International and Cross-Border Data Transfers

Cleveratti Learn primarily stores and processes data within India. Some of our third-party service providers (e.g., cloud platforms, analytics tools, communication services) may process data on servers located outside India.

Where personal data is transferred internationally, we take reasonable steps to ensure that adequate protections are in place, consistent with applicable law including the DPDP Act, 2023 and any rules issued thereunder. These protections may include contractual clauses or equivalent safeguards with the receiving party.

If you would like more information about international data transfers, please contact us at privacy@cleverattilearn.com.

14. Data Retention

We retain personal data for as long as necessary to fulfil the purposes described in this Policy, subject to the following general retention periods:

Data that is no longer required for any lawful purpose will be securely deleted or anonymised.

15. Data Security

We implement reasonable administrative, technical, and physical safeguards to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit using TLS/SSL protocols
• Role-based access controls limiting data access to authorised personnel
• Regular security reviews of our systems and third-party providers
• Staff training on data protection responsibilities
• Secure disposal of physical and digital records no longer required

We collect only personal data that is necessary for the stated purpose. While we take reasonable precautions, no transmission of data over the internet or electronic storage system can be guaranteed to be completely secure. In the event of a data breach, we will act promptly in accordance with applicable law and notify affected individuals where required.

16. Your Rights and Choices

Subject to applicable law, including the DPDP Act, 2023, you have the following rights in relation to your personal data:

• Right to Access — You may request confirmation of whether we hold your personal data and obtain a copy of that data, including information about processors with whom it has been shared.
• Right to Correction — You may request that inaccurate or incomplete data be corrected or updated.
• Right to Erasure — You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations.
• Right to Withdraw Consent — You may withdraw consent for any processing based on consent at any time, without affecting prior processing.
• Right to Opt Out of Marketing — You may unsubscribe from promotional communications at any time (see Section 18).
• Right to Grievance — You may file a complaint with our Grievance Officer (see Section 24) or with the Data Protection Board of India, once established.

Note: Exercising these rights may affect your ability to use certain features of our Services or your continued enrolment in a program, in cases where processing is necessary to perform the contract.

17. How to Exercise Your Privacy Rights

To exercise any of the rights described in Section 16, please submit a written request to:

• Email: privacy@cleverattilearn.com
• Subject Line: "Privacy Rights Request — [Your Full Name]"
• Include: your full name, registered email address, the nature of your request, and (if applicable) a self-attested copy of identity proof

We will acknowledge your request within 72 hours and endeavour to respond substantively within 30 days. We may need to verify your identity before processing the request. Complex or multiple requests may require additional time, and we will inform you accordingly.

18. Marketing Communications

With your consent, we may send you promotional emails, SMS messages, WhatsApp messages, and push notifications about our programs, events, and offers. You may opt out of such communications at any time by:

• Clicking the "Unsubscribe" link in any promotional email
• Replying STOP to any promotional SMS or WhatsApp message
• Writing to privacy@cleverattilearn.com with the subject "Unsubscribe"

Operational and transactional messages (e.g., fee receipts, class schedules, certificate dispatch notifications) are not promotional communications and will continue to be sent as part of our service delivery.

19. Children's Privacy

Our programs are designed for individuals aged 18 years and above. We do not knowingly collect personal data from persons under the age of 18 without verifiable parental or guardian consent. If a person under 18 wishes to enrol, consent must be provided in writing by a parent or legal guardian.

If we discover that we have inadvertently collected personal data from a minor without appropriate consent, we will promptly delete that data. If you believe we may have such information, please contact us at privacy@cleverattilearn.com.

20. User Reviews and Public Content

Our website and social-media channels may display student testimonials, reviews, ratings, and photographs voluntarily submitted by learners. By submitting such content, you acknowledge that it may be published on our website, marketing materials, or social-media platforms.

If you wish to have a testimonial or photograph removed, please write to privacy@cleverattilearn.com and we will endeavour to process your request within 14 working days, subject to any limitations of third-party platforms.

21. Third-Party Websites and Services

Our website may contain links to third-party websites, social-media platforms (Instagram, WhatsApp, YouTube), and embedded tools (e.g., payment gateways, video-hosting platforms). Clicking such links will take you to websites operated by third parties who maintain their own privacy practices.

We are not responsible for the privacy practices of third-party websites and encourage you to review their respective privacy policies before submitting any personal data. The inclusion of a link does not imply endorsement.

22. Fraud Prevention and Legal Disclosure

We may use or disclose personal data when we reasonably believe it is necessary to:

• Prevent, detect, or investigate fraud, misrepresentation, or unauthorised access
• Enforce our Terms and Conditions or Franchisee Agreements
• Respond to valid legal process such as court orders, summons, or subpoenas
• Protect the safety, rights, or property of Cleveratti Learn, its learners, staff, or the public
• Comply with applicable law, government directives, or regulatory requirements

Where permitted, we will make reasonable efforts to notify affected individuals before disclosing personal data in response to legal process.

23. Data Breach and Security-Incident Communication

In the event of a personal data breach that is likely to result in risk to the rights and freedoms of affected individuals, we will:

• Take immediate steps to contain and investigate the breach
• Notify the Data Protection Board of India (once established) where required by the DPDP Act, 2023
• Inform affected individuals without undue delay, providing details of the nature of the breach, the data affected, likely consequences, and steps we are taking to address it

Notifications will be sent to the email address or phone number registered with us. We maintain an internal incident-response procedure to manage and document security incidents.

24. Grievance Officer and Data Protection Contact

If you are not satisfied with our response, you may escalate your complaint to the Data Protection Board of India, once it is constituted and operational under the DPDP Act, 2023.

25. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices, technology, law, or business operations. When we make material changes, we will:

• Post the revised Policy on our website with an updated "Last Revised" date
• Send a notification to your registered email address or display a prominent notice on our website
• Seek fresh consent where required by applicable law

Your continued use of our Services after the effective date of any revision constitutes your acceptance of the updated Policy. If you do not agree with the changes, please discontinue use of our Services and contact us to discuss the implications for your enrolment.

26. Effective Date and Version History

This Policy was last reviewed and approved on 15 July 2026.

Questions about this Policy?

Write to us at privacy@cleverattilearn.com and our team will respond within 30 working days.