PRIVACY POLICY

1. Identity of the Data Controller

This Privacy Policy is issued by FLAGBEARERS NETWORK PRIVATE LIMITED, operating as JUMPINGGOOSE® WORKADEMY ('WORKADEMY', 'We', 'Us', 'Our'), a company incorporated under the Companies Act, 2013, with its registered office at #323, CMR Main Road, HRBR Layout, Kalyan Nagar, Bengaluru – 560043, Karnataka, India.
We are the data controller responsible for your personal information collected through workademyworld.com ('Website'). This Policy is compliant with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ('SPDI Rules'), and applicable provisions of the Digital Personal Data Protection Act, 2023 ('DPDPA') as notified and brought into force.

2. Information We Collect

When you use our Website and register on the WORKADEMY Waitlist, we may collect the following categories of personal information:

2.1 Information You Provide Directly

• Full name;
• Date of birth;
• Email address;
• Mobile number;
• City and state of residence;
• Educational background and current institution (if applicable);
• Portfolio links or creative samples submitted during registration;
• Statement of Intent responses submitted through the Website;
• Payment information (processed by Razorpay – WORKADEMY does not store card details);
• Any other information you choose to provide through our forms or correspondence.

2.2 Information Collected Automatically

• IP address and device identifiers;
• Browser type and version;
• Pages viewed, time spent on the Website, and navigation patterns;
• Referring URLs;
•  Cookies and similar tracking technologies (see Clause 8).

2.3 Sensitive Personal Data or Information (SPDI)

Under the SPDI Rules, certain information is classified as sensitive. Where such information is collected (e.g., financial information in connection with payment), it is processed in accordance with the requirements of the SPDI Rules, including obtaining your explicit consent prior to collection.

3. How We Use Your Information

We use your personal information for the following purposes:

• To process your waitlist registration and Registration Fee payment;
• To communicate with you regarding the status of your application and selection process;
• To administer and improve the selection process, including evaluating your Statement of Intent and other submissions;
• To send you program updates, important notices, and announcements relating to WORKADEMY;
• To comply with applicable legal obligations, including tax and regulatory requirements;
• To detect, prevent, and address fraud, security breaches, and technical issues;
• To enforce our Terms and Conditions;
• Where you have consented, to send you promotional communications about WORKADEMY and related programs.

4. Legal Basis for Processing

We process your personal information on the following legal bases:

• Contract: Processing is necessary to fulfil the waitlist registration agreement and the selection process;
• Legal Obligation: Processing is necessary to comply with applicable Indian laws, including the Income Tax Act, 1961, and GST legislation;
• Consent: Where required by law, we will seek your explicit, informed, and freely given consent before processing your personal data, including for marketing communications and collection of SPDI;
• Legitimate Interests: Processing is necessary for our legitimate interests in operating and improving the WORKADEMY program, provided such interests are not overridden by your data protection rights.

5. Disclosure of Your Information

We do not sell, rent, or trade your personal information to third parties. We may share your information with the following categories of recipients:

5.1 Service Providers

We engage third-party service providers who assist us in operating the Website and processing your information, including:

• Razorpay Payment Solutions Private Limited – for secure payment processing;
• Email and communication service providers;
• Cloud hosting and data storage providers;
• Analytics and website performance providers.

All service providers are bound by data processing agreements and are required to process your information only on our instructions and in accordance with applicable law.

5.2 Legal Disclosure

We may disclose your personal information to government authorities, law enforcement agencies, or judicial bodies where required by law, court order, or to protect the rights, property, or safety of WORKADEMY, its users, or the public.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of our assets, your personal information may be transferred as part of that transaction. We will notify you by email or prominent notice on the Website before your personal information is transferred and becomes subject to a different privacy policy.

6. Data Retention

We retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including for the duration of the selection process and, if you are selected, for the duration of your program participation and thereafter as required by applicable law.

Specifically:

• Registration and waitlist data: retained for 2 (two) years from the date of registration or the completion of the relevant cohort, whichever is later;
• Payment records: retained for 8 (eight) years as required under the Income Tax Act, 1961, and GST legislation;
• Selection process submissions: retained for 1 (one) year from the completion of the relevant selection process.
• Analytics and website performance providers.

After the applicable retention period, personal information is securely deleted or anonymised.

7. Your Rights

Subject to applicable Indian law, including the DPDPA as notified, you have the following rights in relation to your personal information:

• Right to Access: You have the right to request access to the personal information we hold about you;
• Right to Correction: You have the right to request that we correct any inaccurate or incomplete personal information;
• Right to Erasure: You have the right to request deletion of your personal information, subject to our legal obligations to retain certain data;
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing prior to withdrawal;
• Right to Grievance: You have the right to raise a grievance with our Grievance Officer (see Clause 10);
• Right to Nominate: Under the DPDPA, you have the right to nominate an individual to exercise your data rights on your behalf in the event of death or incapacity.

To exercise any of these rights, please write to our Grievance Officer at grievance@workademyworld.com with the subject line 'Data Rights Request'. We will respond within 30 (thirty) calendar days.

8. Cookies

Our Website uses cookies and similar tracking technologies to enhance your browsing experience, understand how users interact with the Website, and improve our services. Cookies are small text files stored on your device by your browser.

We use the following types of cookies:

• Strictly Necessary Cookies: Essential for the Website to function and cannot be switched off. They are set in response to actions made by you, such as setting your privacy preferences or completing a payment;
• Analytics and Performance Cookies: These allow us to count visits and traffic sources so we can measure and improve the performance of the Website;
• Functional Cookies: These enable enhanced functionality and personalisation.

You can control cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Website.

9. Security

We implement reasonable security practices and procedures as required under the SPDI Rules, including technical, administrative, and physical safeguards designed to protect your personal information against unauthorised access, disclosure, alteration, and destruction.

Payment information is processed exclusively by Razorpay and is subject to their PCI-DSS compliant security infrastructure. WORKADEMY does not store, process, or transmit payment card details on its own servers.

However, no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

10. Grievance Officer

In accordance with the Information Technology Act, 2000, the SPDI Rules, and the DPDPA, we have appointed a Grievance Officer to address your privacy concerns:
‍
Name: Bhagyaraju
Designation: Grievance Officer, JUMPINGGOOSE® WORKADEMY
Email: grievance@workademyworld.com
Address: #323, CMR Main Road, HRBR Layout, Kalyan Nagar, Bengaluru – 560043, Karnataka, India
Response Time: Grievances will be acknowledged within 48 hours and resolved within 30 business days of receipt.
You also have the right to lodge a complaint with the Data Protection Board of India, once constituted under the DPDPA, or with any other applicable regulatory authority.

11. Third-Party Links

The Website may contain links to third-party websites. We are not responsible for the privacy practices or content of such websites. We encourage you to review the privacy policies of any third-party websites you visit.

12. Children's Privacy

Our Website and services are not directed to individuals under the age of 18 years. We do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected personal information from a minor, we will take prompt steps to delete such information. If you believe a minor has provided us with personal information, please contact us at grievance@workademyworld.com.

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make material changes, we will notify you by posting a prominent notice on the Website or by sending an email to your registered email address prior to the change becoming effective.
Your continued use of the Website after the effective date of any changes constitutes your acknowledgment of and agreement to the updated Privacy Policy.

14. Governing Law

This Privacy Policy is governed by the laws of India. Any disputes arising in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts at Bengaluru, Karnataka, India.