This is the privacy policy (“Policy”) of the Lumos Learn by Billabong application which is accessible via mobile application and website at https://bhis.lighthouse-learning.com/ (hereinafter collectively referred to as “App”). This App is owned, operated and managed by Lighthouse Learning Private Limited (hereinafter referred to as “Company”, “We”, “Us”, “Our”).

This Policy applies to all visitors, users, children, parents, lawful guardians, teachers, and other persons who access the App (hereinafter referred to as the “User”, “You”, “Your”). Reference to User, You, or Your in this Policy includes reference to yourself as well as the Child User (as defined below) whom you are Guardian (as defined below) of, unless the context otherwise requires.

This Policy must be read together with the App’s Terms of Use available herehttps://bhis.lighthouse-learning.com/terms-of-use. If there is a conflict between this Policy, the App Terms or other policies of the App, the order of prevalence in the Terms shall be followed.

This Policy is published in English. In the event You require Us to share this Policy in any local language, You may write to Us at developer@lighthouse-learning.com.

While the App can be used by users who are below the age of 18 years (“Child Users”), children are not eligible to register on the App by themselves. Parent or the lawful guardian of each Child User (“Guardian”) must register on the App to use or enable usage by Child Users. The use of the App by Child User must be with the consent of Guardian as required under applicable law. It must also be under the supervision of the Guardian or the teacher at all times.

Please read Policy carefully to understand how We collect, use, store, retain, disclose and otherwise process Your and the Child User’s personal data in relation to the access and usage of the App. The Policy applies to all personal data shared in digital form, or in non-digital form but subsequently digitized.

By registering, accessing, or using the App or allowing Your child to access or use the App, You confirm to us that:

1. You have read the terms of this Policy as well as App’s Terms of Use https://bhis.lighthouse-learning.com/terms-of-use, which together form a legally binding and enforceable contract between You and the Company. Such contract is formed when You register (by clicking on the “I agree” button) on the App, or access or use the App;
2. You are legally capable of entering into this contract and have formed a contract with Us out of Your own free will. We will consider that Your consent is free, specific, informed, unconditional and unambiguous and You are not disqualified from contracting by law;
3. You have the ability and authority under applicable law to share Your and Child User’s personal data with us, and permit us to use such data for the purposes mentioned in this Policy;
4. You are, at all times, responsible for Your as well as Child User’s usage and activities on the App.

If You have any questions related to how this Policy applies to the processing of Your or Child User’s personal data, please write to Our Grievance Officer at developer@lighthouse-learning.com.

We may update this Policy at any time in the manner provided in Clause 14 (Modification) below. Hence, We recommend that You review this Policy from time to time. You agree that it is Your responsibility to update Yourself with any such change from time to time.

If You do not consent to the terms of this Policy, please do not use or access the App, and do not share Your personal data with Us. If You wish to opt-out or withdraw Your consent, We request You to refer to Clause 9 (Rights of the User) below and write to Us at developer@lighthouse-learning.com.

Any and all consequences of Your withdrawal of consent resulting in, inter alia, any inability by Us to comply with Our obligations viz-a-viz You, limitations, or termination of Your access to the App, will be borne entirely by You.

1. Personal Data We Collect

1. Personal data means any data about an individual who is identifiable by or in relation to such data. However, it does not include data where the identity has been removed and cannot be reconnected to an individual (called ‘anonymise’ data).
2. We collect, store and otherwise process personal data when You access or use the App. This data includes:
   • Name
   • Contact number(s)
   • Date of birth
   • Age
   • Gender
   • Email address
   • Password related details
3. You are responsible to provide accurate, error-free and complete personal data. We shall not be liable for any errors, inaccuracies, or incompleteness in the personal data provided by You, or any direct or indirect consequences arising from such incorrect, inaccurate or incomplete personal data. If We find out that You have provided false personal data, We shall be at liberty to restrict Your access to the App.

2. How We Collect Your Personal Data

Some of the ways in which We collect Your personal data are:

1. Directly from You.
2. Automatically from Your browser type, internet protocol address used, Your usage patterns as collected by Our cookies. Cookies are tiny pieces of information which an application sends to Your computer. Cookies help Us personalize Your experience. You can change Your browser settings and choose to disable sharing of personal data through cookies. Sometimes, tracking pixels including but not limited to browser HTML pixels may be used to collect personal data about User’s behaviour on the App. Pixels are tiny units which measure the digital images and graphics You see on an application. You agree that cookies and pixels are used to improve Your experience as a User and consent to the use of the same.
3. Your use of the App in cases where You voluntarily provide certain personal data.

3. How We Process Your Personal Data

We may process personal data collected from You. The purposes include:

1. Verifying Your identity by using the contact details provided by You.
2. Providing You access to the App.
3. Administration of Your account on the App.
4. Contacting You and/or communicating with You.
5. Enabling a customized experience for You on the App and providing You with a better and more efficient service.
6. Improving the App’s design and style.
7. Developing new products, features, services, and functionalities.
8. Informing You about Our ongoing and upcoming offers and promotions as well as sending marketing and other non-transactional information such as newsletters, SMS and notifications.
9. Addressing and resolving Your grievances.
10. Business management and internal purposes including accounting and auditing and complying with any statutory or regulatory reporting obligations.
11. Complying with and fulfilling any obligations under any law for the time being in force in India.
12. Preventing fraud or for detection of any crime
13. Ensuring network and information security, including preventing unauthorised access to the App.
14. Sharing personal data with third parties as discussed in Clause 4 (Who We Share Your Personal Data With) below.

4. Who We Share Your Personal Data With

The Company may share Your personal data with:

1. Affiliates: As agreed, We may share Your personal data with Our affiliate entities who may need to access Your personal data for operational and functional needs.
2. Employees and consultants: We may share Your personal data with Our employees and consultants on a need-to-know basis for providing services to You which improves Your experience in relation to the App.
3. Franchises and Trusted third-party service providers: We may provide Your personal data to our franchisees and Our trusted third-party service providers on a need-to-know basis for servicing You in relation to Your use of or access to the App.
4. Counsellors/experts: We may share Your personal data with the counsellors/ experts available on the App to provide counselling or expert help to You.
5. Business transfers: If We are acquired by, or merged with, another company, or if Our assets are transferred to another company or as part of a bankruptcy, liquidation or insolvency proceedings, We may transfer Your personal data to such other company.
6. Law enforcement agencies: We may share Your personal data when compelled by any law enforcement agency in compliance with applicable laws.

All Our third-party service providers and other entities in the group are required to take appropriate security measures to protect Your personal information in line with Our policies and in accordance with the applicable data protection laws in India. Our third-party service providers are not allowed to use Your personal data for their own purposes. They only process Your personal data for specified purposes and in accordance with Our instructions.

5. Child Users’ Personal Data

1. Given that Child Users are not by themselves eligible to register, access, and/or use the App, the use of the App by the Child User must be with the consent of/enabled by the Guardian, and under the supervision of, a Guardian. If You are a Guardian, by allowing Your child to access/ use the App, You confirm to having consented to Child User’s use or access of the App. Rest assured, We collect and process the personal data of Child Users in a safe, protected and responsible manner in compliance with the Policy and the applicable data protection laws in India.
2. We do not permit Child Users to create an account on the App. If You discover that a Child User has created an account without the consent of their Guardian, please write to Us at developer@lighthouse-learning.com and We will take the required steps to delete such account and cease processing of the personal data of such Child User, other than as required under the applicable law. A Child User creating an account on the App by providing false or fake information about their age will not be Our liability. All responsibility of monitoring and supervising access and usage of the App by a Child User is on the Guardians and We shall not be held liable for the same.

6. Legitimate Uses

Please note that We may process Your personal data without Your knowledge or consent for certain legitimate uses which are required or permitted by law. The circumstances of such legitimate use include:

1. Enforcing any legal right or claim;
2. Processing by any court or tribunal or any other body in India which is entrusted by law with the performance of any judicial or quasi-judicial or regulatory or supervisory function, where such processing is necessary for the performance of such function;
3. Processing in the interest of prevention, detection, investigation or prosecution of any offence or contravention of any law for the time being in force in India;
4. Fulfilling any obligation under any law for the time being in force in India to disclose any information to the State or any of its instrumentalities;
5. Complying with any judgment or decree or order issued under any law for the time being in force in India, or any judgment or order relating to claims of a contractual or civil nature under any law for the time being in force outside India;
6. Responding to a medical emergency involving a threat to the life or immediate threat to the health of the User(s) or any other individual;
7. Taking measures to provide medical treatment or health services to any individual during an epidemic, outbreak of disease, or any other threat to public health;
8. Taking measures to ensure safety of, or providing assistance or services to, any individual during any disaster, or any breakdown of public order.

7. Data Security

1. We take security of Your personal data very seriously and have taken steps to implement appropriate and reasonable safeguards and technical security measures to prevent any personal data breach, or unauthorized access, use, modification, disclosure, or destruction of Your personal data that You entrust with Us.
2. You should, however, take necessary steps at Your end as well to protect against unauthorized access to Your passwords and devices. We will not be responsible for any lost, stolen, or compromised passwords, data or for any unauthorized activities on Your account.

8. Data Retention

1. We shall retain Your data for the purposes it was collected for and in compliance with applicable laws of India. For further details on data retention, We request that You write to Us at developer@lighthouse-learning.com.
2. In some circumstances, We may anonymise Your personal data so that it can no longer be associated with You, in which case We may use such information without further notice to You.

9. Rights of the User

We respect Your data and acknowledge Your rights in relation to it. Your rights in relation to Your data are protected under law. You also have the following rights under this Policy:

1. Right to access information about personal data processed. You can access and/or obtain information related to Your personal data and its processing by writing to Us at developer@lighthouse-learning.com.
2. Right to correction, completion, and updating of the personal data for the processing of which You have previously given Your consent. We assume that Your personal data as provided by You is accurate, error-free and complete. We shall not be liable for any errors, inaccuracies, or incompleteness in the personal data provided by You, or any direct or indirect consequences arising from such incorrect, inaccurate or incomplete personal data. In case of changes to Your personal data, You can correct, complete, or update Your personal data by writing to Us.
3. Right to erasure of Your personal data for the processing of which You have previously given Your consent. You can request us to erase Your personal data processed by Us, by writing to us. We will also erase Your personal data if (i) We recognize that the specified purpose for which Your personal data was collected is no longer being served; and/or (ii) You withdraw Your consent vis-a-vis the personal data. However, erasure of Your personal data may not be done in cases where (i) retention of Your personal data is necessary for the specified purpose for which Your personal data was collected; or (ii) for compliance with any applicable law for the time being in force. Erasure of data is also subject to Our retention policy. Any erasure of Your data may impact the service we provide/ or may provide to You.
4. Right to opt-out of receiving marketing and promotional materials, newsletters, and other non-essential messages by using the ‘unsubscribe’ function included in all such communications. However, You will continue to receive essential communication such as security incident alerts, change in policies, etc. as necessary or required under the applicable laws.
5. Right to withdraw consent: To the extent Your consent forms the basis of processing Your personal data, You have the right to withdraw Your consent at any time, without affecting the legality of processing Your personal data based on such consent before its withdrawal. Any and all consequences of Your withdrawal of consent resulting in, inter alia, disruption, or unavailability of services, will be borne entirely by You.
6. Right to grievance redressal to redress Your grievances in respect of any act or omission by Us in relation to the performance of Our obligations in relation to Your personal data. We have also appointed a Grievance Officer who will expeditiously redress any grievance(s). Please see Clause 16 (Redressal of Grievances) of this Policy for details of the Grievance Officer.
7. Right to nominate, in the prescribed manner, any other individual who shall, in the event of Your death or incapacity, exercise Your rights in accordance with the applicable law and Our policies.

To exercise any of Your rights above, please contact Us in writing, by emailing Your relevant Grievance Officer at developer@lighthouse-learning.com.

10. Transfer of Personal Data Outside India

1. Presently, We only store the personal data that We collect about You in India.
2. If We have to transfer Your personal data outside India in the future, We will do it in compliance with applicable law.

11. Third-Party Links

1. The App may contain hyperlinks to various external websites, applications, content, advertisement section of the App which includes hyperlinks to various external websites (“Third-Party Links”). We do not own or control such Third-Party Links present on the App. If You choose to click on such Third-Party Links which direct You to a third-party website or application, You choose to do so at Your own risk. We assume no control or responsibility for the content, offerings, privacy policies or practices of such Third-Party Links or their services. You must read the privacy policy of such third-party website/application before You share any personal data on such website/ application.
2. The presence of any Third-Party Links on the App cannot be construed as a recommendation, endorsement or solicitation of any material or content present on such Third-Party Links, or any other material on or available through such Third-Party Links.
3. We recommend that You exercise reasonable diligence, as You would in traditional offline or online channels before committing to any transaction or exchange of information, including but not limited to reviewing the third-party website or application’s privacy policy.
4. You further acknowledge and agree that We are not liable for any loss of Your personal data as a result of the collection and/or disclosure of Your information through such third-party links, or as a result of any reliance placed by You on the completeness, accuracy or existence of any advertising, services or other materials on, or available through, such third-party links. This will include all transactions and information transmitted on such third-party links between You and any third-party websites/ application.

12. Online Safety & Awareness

1. Access to the App by a Child User is contingent upon the Guardian’s explicit consent.
2. Upon using this App, You hereby acknowledge and agree that Your interactions, such as comments and likes, will be made visible to other Users on the App.
3. You further acknowledge and agree that photographs of activities shared by the school or school authorized person(s) are accessible to other Users on this App. We urge You to prioritize online safety and carefully assess real-world risks before sharing information for access by other Users on the App.

13. Reporting of Data Breach

In the event, We come to know of any personal data breach, We will expeditiously, in compliance with the applicable laws, inform the relevant authorities of such personal data breach. In the event You come to know of any personal data breach, You are required to inform the same to us within 2 hours of having such knowledge of breach.

14. Modifications

This Policy may be updated by Us from time to time. The updated version of the Policy can be accessed at any time on the App. You are advised to regularly review the Policy. We will notify You of any updates to this Policy that might materially affect the purpose of collecting Your personal data, prior to the change becoming effective by means of a notice on the App. You will be required to review the updated Policy. Your continued use of the App after any changes to this Policy will be deemed as Your acceptance of such change(s). If You do not accept the updated Policy, You may exercise Your right of withdrawal of consent as per Clause 9 (Rights of the User) above. However, We may not be able to provide You access to the App in such case.

15. Governing Law and Jurisdiction

1. This Policy shall be construed in accordance with the applicable laws of India Subject to the arbitration in clause 15(b) below, disputes under or arising out of the Terms shall be subject to exclusive jurisdiction of courts at Mumbai, India.
2. All disputes arising from or in connection with this Agreement shall be referred to, and finally settled by, arbitration in accordance with the Indian Arbitration and Conciliation Act, 1996, presided over by a sole arbitrator jointly appointed by the Parties. The arbitration proceedings shall be held at Mumbai and shall be conducted in the English language. The award of the arbitral tribunal shall be binding on the Parties. The arbitration proceedings shall be kept confidential.

16. Redressal of Grievances

If You have any queries regarding the App or find any discrepancies in relation to the processing of personal data under this Policy, You may write to the Grievance Officer, the details of which are provided below:

Name: Rakesh Bhat

Email: rakesh.bhat@lighthouse-learning.com, with cc to legal@lighthouse-learning.com.

Phone: 9819283336

Address: Windsor, 801, Off, Manipada Rd, Kalina, Santacruz East, Mumbai, Maharashtra 400098.

Our Grievance Officer will attempt to redress Your queries and concerns expeditiously or in accordance with the timelines prescribed under the applicable laws.

Last Updated: 30th May 2025.