privacy policy

1. ABOUT THE ACADEMY

Elevate English Academy ("Academy", "we", "us" or "our"), operated as a sole proprietorship by Mr. Sameer Dhamija, Sole Proprietor and Founder & Lead Trainer, is an online English-language education and training academy providing courses, live classes, educational content and related learner support through its website and associated digital platforms.

This Privacy Policy explains how the Academy collects, uses, stores, shares and otherwise processes personal data of students, prospective students, website visitors, users and other individuals who interact with the Academy.

By accessing or using the Academy's website, registering for a course, communicating with the Academy, or otherwise providing personal data to the Academy, you acknowledge that you have read and understood this Privacy Policy.

The Academy is committed to handling personal data responsibly, transparently and only for legitimate and specified purposes.

2. CONTACT INFORMATION

Elevate English Academy
Sole Proprietor & Founder: Mr. Sameer Dhamija
Email: sameer@elevateenglishacademy.in
Contact: +91 98182 48493
Website: https://elevateenglishacademy.in
Principal Business Address: Plot-103, Keshav Majestic, Sunrakh Road, Near Indian Public School, Vrindavan, Mathura – 281121.

The above email address is the Academy's primary contact mechanism for privacy-related enquiries, requests, consent withdrawal, correction or erasure requests, marketing opt-outs and grievances.

3. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to personal data collected or processed through:

the Academy's website;
online course registration and enrolment;
the Academy's Graphy platform;
live classes and webinars;
course recordings;
payment and enrolment processes;
email and WhatsApp communications;
customer/student support;
enquiries and communications with the Academy; and
other digital services or platforms used by the Academy in connection with its educational activities.

This Policy does not apply to third-party websites, applications, platforms or services that are independently operated by third parties. Their own privacy policies may apply to personal data processed by them.

4. PERSONAL DATA WE MAY COLLECT

4.1 Identification and Contact Information

This may include full name, email address, mobile or telephone number, communication details, age or date of birth where reasonably required, and information provided during registration or enquiry.

4.2 Course and Enrolment Information

This may include course selected, enrolment details, learner account information, course participation, attendance or engagement information, progress or completion information, and communications concerning courses or student support.

4.3 Payment and Transaction Information

Where a course or service involves payment, the Academy may receive transaction-related information necessary to verify payment, confirm enrolment, administer applicable refunds, reconcile transactions, and maintain financial and accounting records.

The payment gateway currently selected on the Academy's Graphy platform is the Graphy Payment Gateway.

Complete card, UPI or banking credentials are processed by the relevant payment service provider and are not intended to be stored directly by the Academy.

4.4 Communication Information

Where you communicate with the Academy through email, WhatsApp, website forms or other permitted communication channels, the Academy may process the content of your communication, contact details, documents or information voluntarily provided by you, and information necessary to respond to your enquiry or request.

4.5 Live Class and Recording Information

Where live classes are conducted and recorded, recordings may contain participant name, image, voice, video, questions, chat messages, comments, interactions, and other contributions made during the live session.

The Academy intends to conduct live classes primarily through Graphy's integrated live-class/webinar facility.

If the Academy uses another integrated or third-party video-conferencing service in the future, the relevant service may process personal data in accordance with its own terms and privacy practices.

4.6 Technical and Usage Information

When you access the website or digital services, certain technical information may be collected automatically, such as IP address, browser or device information, operating system, approximate usage information, pages or content accessed, access times, and information generated through cookies or similar technologies.

Such information may be used for security, website functionality, analytics, troubleshooting and improvement of the Academy's digital services.

5. HOW WE COLLECT PERSONAL DATA

Personal data may be collected:

directly from you;
when you create an account or register for a course;
when you make or attempt to make a payment;
when you communicate with the Academy;
when you participate in live classes;
through class recordings;
through Graphy or other service providers used by the Academy;
through website forms;
through email or WhatsApp communications; and
automatically through cookies, logs and similar technologies.

The Academy will seek to collect only such personal data as is reasonably necessary for the relevant purpose.

6. PURPOSES FOR PROCESSING PERSONAL DATA

6.1 Course and Service Delivery

register and enrol students;
provide access to purchased courses;
conduct live classes;
provide educational content;
provide revision materials;
administer learner accounts;
monitor course completion where necessary;
provide student support.

6.2 Payments and Financial Administration

verify payments;
confirm enrolments;
process applicable refunds;
maintain transaction records;
comply with accounting and financial obligations;
address payment-related queries.

6.3 Communication

respond to enquiries;
communicate course-related information;
send administrative notices;
provide customer/student support;
communicate changes affecting courses or services;
address complaints and grievances.

6.4 Class Recordings

Where recording is undertaken, recordings may be processed for providing course access and revision material, educational and training purposes, course administration, resolving student queries, and internal quality improvement.

6.5 Website and Service Improvement

maintain and improve website functionality;
understand usage patterns;
troubleshoot technical problems;
improve educational services;
protect the security and integrity of the Academy's systems.

6.6 Legal and Compliance Purposes

comply with applicable legal obligations;
respond to lawful requests from competent authorities;
maintain necessary business records;
establish, exercise or defend legal rights;
prevent fraud, misuse or unlawful activity.

7. LIVE CLASSES

The Academy intends to conduct its live classes primarily through Graphy's integrated live-class/webinar facility.

The Academy may use an integrated or third-party video-conferencing service in the future. Where such a service is used, relevant personal data may be processed by that service provider in accordance with its applicable terms and privacy policy.

Participants should therefore avoid sharing unnecessary sensitive or private information during live classes, chat discussions or other interactive sessions.

8. CLASS RECORDINGS

The Academy may record certain live classes where recording is reasonably required for educational, administrative or quality-improvement purposes.

After a live session ends, its recording may be processed and stored through the Academy's Graphy platform.

Administratively, recordings may be accessed through Graphy's relevant asset library or live-class/recordings functionality.

Students may be provided access to a recording through the relevant course on the Academy's website or application only where the relevant Graphy setting permitting learner access to the recording is enabled.

Where a live class is to be recorded, students should be notified before recording begins.

A recording may contain a participant's name, photograph or image, voice, video, questions, chat messages, and other contributions made during the session.

8.1 Purposes of Recording

providing course access and revision material;
educational and training purposes;
course administration;
resolving student queries;
internal quality improvement.

8.2 Promotional Use of Recordings

A student's identifiable name, photograph, image, voice, video, testimonial or class participation will not be used for advertising, social media, testimonials or other promotional purposes without separate and explicit consent, where such consent is required.

Consent for participation in or access to an educational class should not automatically be treated as consent for promotional use.

8.3 Retention of Recordings

Ordinary class recordings are intended to be retained for up to 12 months after completion of the applicable course, unless a shorter or longer period is reasonably required for continued course access, revision or educational requirements, resolution of a complaint, compliance with a legal obligation, establishment, exercise or defence of legal rights, or another legitimate operational or legal requirement.

After the applicable retention period, recordings will be deleted or anonymised where reasonably possible, subject to technical limitations and any lawful requirement to retain them.

9. PAYMENT PROCESSING

The Academy currently uses the Graphy Payment Gateway through its Graphy platform.

The Academy may receive transaction information necessary to verify payments, administer enrolments, issue applicable refunds, reconcile transactions, and maintain financial records.

Complete card, UPI or banking credentials are processed by the relevant payment service provider and are not intended to be stored directly by the Academy.

Payment service providers may independently process personal data in accordance with their own privacy policies and terms.

10. COOKIES AND SIMILAR TECHNOLOGIES

The Academy's website or digital services may use cookies and similar technologies to enable essential website functionality, maintain security, remember preferences, understand website usage, improve performance, and support analytics where implemented.

Where required by applicable law, appropriate notice or consent mechanisms may be provided.

You may also be able to control cookies through your browser settings. Disabling certain cookies may affect some website functionality.

11. COMMUNICATIONS AND MARKETING

The Academy may send communications necessary for course administration, enrolment, payment confirmation, class schedules, course access, important service notices, account-related communications, and other communications necessary to provide the requested service.

Where the Academy sends promotional or marketing communications based on consent, the recipient may withdraw such consent or opt out.

11.1 Marketing Opt-Out

A marketing recipient may request cessation of promotional communications by using an unsubscribe mechanism provided in the communication, where available, or by contacting the Academy at sameer@elevateenglishacademy.in.

A marketing opt-out will not necessarily stop essential transactional, administrative, legal or service-related communications.

12. SHARING OF PERSONAL DATA

The Academy may share personal data where reasonably necessary with:

Graphy and its relevant service infrastructure;
payment service providers;
integrated or third-party video-conferencing providers;
email and communication service providers;
technology and hosting providers;
professional advisers, where necessary;
accounting or financial service providers;
government authorities or law-enforcement agencies where legally required; and
other service providers acting on behalf of the Academy for legitimate operational purposes.

The Academy does not intend to sell personal data of students or users to third parties.

Where third-party service providers process personal data on behalf of the Academy, the Academy will seek to use such providers for legitimate business purposes and, where applicable, subject to appropriate contractual, organisational or technical safeguards.

13. THIRD-PARTY SERVICES

The Academy's digital operations may involve third-party platforms and service providers, including Graphy, payment service providers, communication providers and video-conferencing services.

Such third parties may process personal data independently or on behalf of the Academy depending upon the nature of the service.

The Academy does not control the privacy practices of independent third-party services. Users should review the relevant third party's applicable privacy policy and terms before using such services where appropriate.

14. DATA RETENTION

The Academy will retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including providing courses and services, maintaining student and enrolment records, handling payments and refunds, resolving complaints, maintaining necessary business financial records, complying with legal obligations, and establishing, exercising or defending legal rights.

14.1 Indicative Retention Periods

Student/account information: For the duration of the learner relationship and thereafter for as long as reasonably required for legal, administrative or legitimate business purposes.
Enrolment/course records: For the duration of the course and thereafter for as long as reasonably required for administration, accounting, disputes or legal compliance.
Payment/transaction records: For the period reasonably required for accounting, tax, financial, legal and dispute-resolution purposes.
Class recordings: Up to 12 months after completion of the applicable course, subject to the exceptions stated in this Policy.
Promotional consent records: For as long as necessary to demonstrate or administer the relevant consent and for applicable legal/compliance purposes.
Communications/grievances: For as long as reasonably necessary to resolve the matter and protect legal rights.
Marketing preferences/opt-outs: As reasonably required to honour and maintain the applicable preference.

Where retention is no longer reasonably necessary, personal data will be deleted, anonymised or otherwise appropriately disposed of, subject to technical limitations and applicable legal requirements.

15. DATA SECURITY

The Academy will take reasonable technical and organisational measures appropriate to the nature and risk of the personal data processed.

Such measures may include access controls, account security, restricted access to personal data, use of reputable third-party service providers, reasonable safeguards against unauthorised access, alteration, disclosure or destruction, and appropriate procedures for handling suspected data-security incidents.

However, no online system or method of transmission can be guaranteed to be completely secure.

Users should also take reasonable steps to protect their account credentials and should not share passwords or other access credentials with unauthorised persons.

16. DATA BREACHES AND SECURITY INCIDENTS

If the Academy becomes aware of a personal data breach or security incident requiring action under applicable law, the Academy will take reasonable steps to contain, assess and address the incident and make any legally required notifications or disclosures.

Where required by applicable law, affected individuals and/or competent authorities may be notified in the prescribed manner.

17. AGE RESTRICTION AND DATA OF INDIVIDUALS BELOW 18 YEARS

The Academy's paid courses and live classes are strictly restricted to individuals aged 18 years and above.

Individuals below 18 years of age may view publicly accessible portions of the Academy's website, but they are not permitted to enrol in paid courses, make payments for paid courses, or otherwise use the Academy's paid educational services.

The Academy does not knowingly enrol or provide paid educational services to individuals below 18 years of age.

This Privacy Policy does not create any exception to the Academy's strict 18+ eligibility requirement.

18. LEGAL BASIS FOR PROCESSING

Depending on the circumstances and applicable law, the Academy may process personal data on one or more of the following bases:

consent provided by the individual;
processing necessary for providing a requested service or responding to a request;
compliance with a legal obligation;
compliance with applicable contractual or administrative requirements;
protection or exercise of legal rights;
prevention of fraud, misuse or unlawful activity; and
other grounds permitted under applicable law.

Where consent is relied upon as the legal basis for processing, consent should be free, specific, informed and unambiguous, and may be withdrawn in accordance with applicable law.

Withdrawal of consent will not affect the lawfulness of processing carried out before withdrawal and will not prevent the Academy from continuing processing where such processing is otherwise permitted or required by law.

19. YOUR DATA PROTECTION RIGHTS

Subject to applicable law and the provisions of the Digital Personal Data Protection Act, 2023 and the Digital Personal Data Protection Rules, 2025 as and when applicable and in force, individuals may have rights including:

the right to obtain information about processing of their personal data;
the right to correction of inaccurate or misleading personal data;
the right to updating of personal data where applicable;
the right to erasure of personal data where permitted;
the right to withdraw consent where consent is the basis of processing;
the right to register a grievance concerning processing of personal data; and
the right to nominate another individual to exercise applicable rights in accordance with law.

The availability and scope of these rights may depend upon the applicable legal provisions, the basis of processing and any lawful exceptions.

The Academy may require reasonable information necessary to verify the identity of the person making a request before acting upon it.

20. HOW TO EXERCISE YOUR RIGHTS

For privacy-related requests, including access or information requests, correction requests, erasure requests, consent withdrawal, marketing opt-outs, privacy enquiries and grievances, you may contact:

Mr. Sameer Dhamija
Founder & Lead Trainer
Elevate English Academy
Email: sameer@elevateenglishacademy.in
Contact: +91 98182 48493

The above email address is the Academy's primary mechanism for privacy enquiries, consent withdrawal, correction or erasure requests, marketing opt-outs and grievances.

The Academy will endeavour to respond to valid requests within a reasonable period and in accordance with applicable law.

21. GRIEVANCE REDRESSAL

The Academy does not presently maintain a separate public postal office specifically for privacy grievances. Privacy and data-protection grievances should therefore initially be addressed to:

Mr. Sameer Dhamija
Founder & Lead Trainer
Elevate English Academy
Email: sameer@elevateenglishacademy.in
Contact: +91 98182 48493

The Academy will review and respond to grievances in accordance with applicable law and its internal procedures.

Where applicable law provides for escalation to a competent regulatory or adjudicatory authority, the individual may exercise such rights in accordance with the applicable legal framework.

22. INTERNATIONAL DATA TRANSFERS

The Academy primarily operates online and may use third-party technology and service providers whose infrastructure or processing operations may involve locations outside India.

Where personal data is transferred, stored or processed outside India, the Academy will seek to do so in accordance with applicable Indian law and any applicable restrictions or requirements relating to cross-border transfers.

23. DATA OF THIRD PARTIES PROVIDED BY YOU

You should not provide personal data of another individual to the Academy unless you are authorised or legally permitted to do so.

Where you provide information relating to another person, you should ensure that the information is accurate and that you have the necessary authority or permission to provide it.

24. ACCURACY OF PERSONAL DATA

The Academy expects users to provide accurate and up-to-date information.

If any personal information provided to the Academy becomes inaccurate, incomplete or outdated, the individual may contact the Academy using the details provided in this Policy to request appropriate correction or updating.

25. CHANGES TO THIS PRIVACY POLICY

The Academy may update this Privacy Policy from time to time to reflect changes in its services or operational practices, changes in technology, changes in third-party service providers, changes in applicable law or regulatory requirements, or improvements to the Academy's privacy practices.

The updated version will be published on the Academy's website with an updated "Last Updated" date.

Where a change materially affects the manner in which personal data is processed, the Academy may provide additional notice or obtain consent where required by applicable law.

26. GOVERNING LAW

This Privacy Policy shall be governed by and interpreted in accordance with the laws of India.

Nothing in this Privacy Policy is intended to limit or exclude any right or protection available to an individual under applicable law.

27. SEVERABILITY

If any provision of this Privacy Policy is held to be invalid, unlawful or unenforceable, that provision shall be modified or severed to the extent necessary, and the remaining provisions shall continue to remain effective to the extent permitted by law.

28. FINAL CONTACT INFORMATION

For all privacy-related matters, please contact:

Mr. Sameer Dhamija
Founder & Lead Trainer
Elevate English Academy
Email: sameer@elevateenglishacademy.in
Phone: +91 98182 48493
Website: https://elevateenglishacademy.in

END OF PRIVACY POLICY