This Policy is made by Lumera Systems Private Limited, incorporated in India and having its office at 7th Floor, RR Tower 4, Thiru Vi Ka Industrial Estate, Guindy, Chennai – 600032 (including its subsidiaries, affiliates, partners, shareholders, directors, executives, officers, employees, agents, successors-in-interest and permitted assigns, hereinafter referred to as "we", "us" or "our"), which operates and manages Study Shield.
We believe effective learning should not come at the cost of privacy. That is why we have designed Study Shield to help your child develop healthy study habits, maintain focus and achieve learning goals while collecting only the information necessary to provide these services. We follow a privacy-by-design approach and seek to minimise the personal data we collect, use and retain.
This Privacy Policy explains how we collect, use, store, disclose and protect personal data when you and your child use our application, website, devices, software and related services (collectively, "Study Shield"). The terms "you" and "your" refer to any person accessing or seeking to use Study Shield. The personal information of you and/or your children entrusted to us will be used only in the manner described in this Policy.
1. Privacy as our Fulcrum
Protecting the privacy of you and your child is one of our core principles. We are committed to implementing appropriate technical, organisational and security measures to safeguard personal data, and to collecting only the information necessary to enable, maintain, secure and improve Study Shield.
Maintaining privacy is a shared responsibility. To help ensure a safe and privacy-focused learning environment, we each undertake the following:
What you should do
- Use an alias or nickname (that cannot be linked to your child's identity) instead of your child's real name wherever possible.
- Keep your account credentials and access devices secure.
- Review and manage the websites and applications you choose to whitelist for your child.
- Notify us of any suspected unauthorised access or security incident.
What we will do
- Collect only the information necessary for you and your child's use of Study Shield.
- Implement reasonable security measures to protect personal data.
- Use personal data only for the purposes described in this Policy.
- Never sell personal data or use your child's data for targeted advertising.
- Enable you to access, manage or request deletion of personal data in accordance with applicable law.
2. What information do we collect?
| Category | Examples | Purpose |
|---|---|---|
| Parent Account Information | Name, email address, mobile number | To create and manage accounts, authenticate users, communicate with you, and provide customer support. |
| Parent Account Information | Physical address | For delivering the NFC kit. |
| Child Profile Information | Alias, nickname, avatar, age group or grade level (if provided) | To create and manage your child's profile and personalise the learning experience. |
| Learning and Goal Information | Learning goals, study preferences, subjects, study targets and schedules | To generate personalised study plans, focus schedules, and learning recommendations. |
| Parent Configuration Information | Whitelisted websites, domains, applications, and parental settings | To implement parental controls and focus-management settings. |
| Session and Focus Information | Session duration, start and end times, completion data, study activity records | To provide focus-management features, track study progress, and generate learning insights. |
| Focus Scores and Analytics | Focus scores, consistency metrics, study habit indicators, and related analytics | To measure engagement, provide progress insights, and improve learning recommendations. |
| Report to Parent | Weekly study summaries, focus metrics, and progress reports | To keep parents informed of their child's learning progress and engagement. |
| Coaching Institute Data | Anonymised study activity, preparation trends, focus metrics, and learning insights | To provide coaching institutes with academic insights and preparation trends where enabled. |
Study Shield is designed to minimise the collection of personal data. We do not require or intentionally collect your child's real name, Aadhaar number, photograph, precise location data, browsing history, social media activity, biometric information, financial information or contact lists. We encourage the use of aliases and collect only the information reasonably necessary to support your child's learning experience.
Device permissions
To provide focus-management and parental control features, Study Shield may utilise operating system permissions, device management capabilities and parental control frameworks available on your device. These are used solely to enable functionality such as focus sessions, application restrictions, content access controls and parental supervision settings — never for advertising, profiling or any unrelated purpose.
Such information is processed only locally on the device. We do not access, receive or store information obtained through device-level parental control frameworks except to the extent necessary for the functionality of Study Shield. Parents remain in control and may activate, modify or deactivate restrictions and permissions at any time through the Parent Dashboard or device settings.
3. Who we share information with
We may share information only on a need-to-know basis with:
- Service providers who assist us in operating, securing, maintaining and improving Study Shield, including our cloud infrastructure providers.
- Payment processors, for processing transactions.
- Parents or legal guardians, including through account access and progress reports.
- Coaching institutes, but only in anonymised form unless you expressly enable a setting that permits disclosure of your child's identity.
- E-wallet partners, if you opt for the reward system feature available within the platform.
- Career assessment service providers, if you opt for any psychometric or similar assessments for your child.
- Regulatory authorities, law enforcement agencies, courts or other governmental bodies where required by applicable law.
- Successors or acquirers in connection with a merger, acquisition, restructuring or transfer of business assets.
4. How long do we retain your information?
We retain your information only as long as necessary to maintain the functionality of Study Shield, resolve disputes, enforce our agreements and comply with legal and regulatory obligations. When personal data is no longer required, we delete, anonymise or securely dispose of it. In general, we retain session log data for 6 months post-lapse.
If you decide to stop using Study Shield, you can deactivate your account and your profile will no longer be visible to other members. If you are inactive for more than 3 years, we will deactivate your account automatically. We may retain certain account information only for as long as necessary to fulfil the purposes for which it was collected, comply with legal or regulatory obligations, establish, exercise or defend legal claims, prevent fraud, maintain the security and integrity of Study Shield, or enforce our rights and agreements.
5. How we safeguard your data
We have implemented physical, managerial and technical safeguards to preserve the integrity and security of your information, such as access restrictions and application-level security controls. Personal data is encrypted in transit and at rest, and we follow secure key management practices. However, transmission of information via the internet is not always secure; we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk.
6. Your rights
We want you to have control over your and your child's personal data. We have enabled technical functionality that lets you edit your information, and deactivate or delete the account as you require. Under the Digital Personal Data Protection Act, 2023 of India you have the following rights:
| Your right | How to exercise it |
|---|---|
| To obtain a copy of your personal information | You can access and review some data directly by logging into your account. You can also retrieve the data by contacting the Grievance Officer using the details below. |
| To correct, complete or update inaccurate personal information | You can update your data directly within the application by updating your profile. Certain health-related information may be locked for editing and can be updated only by contacting the Grievance Officer. |
| To withdraw consent or erase your information (when no longer necessary) | You can delete some of the data you provided directly within the application. You can also close or deactivate your account, and we will delete your data as laid out in this Policy. |
| To nominate another person to enforce your rights (in the event of death or incapacity) | Contact the Grievance Officer using the details below. |
In the case of any further grievance, you may also approach the Data Protection Board.
7. Your duties
You must ensure that the information you provide is true and accurate. Giving false information or impersonating another person is a punishable offence under the DPDPA. If you are providing information on behalf of another person, you must ensure that the individual has consented to our processing of their personal data in the manner prescribed in this Policy. You cannot provide details of a child unless you can verify yourself as an adult and as that child's parent or guardian.
8. Changes to the Privacy Policy
We may update this Privacy Policy from time to time. Where required by law, we will notify you of material changes through service announcements, email, SMS or WhatsApp message, in-app banners or other appropriate means. A "last updated" date at the start of this Policy indicates when it was last modified.
9. Other applications
Our website and application may contain links to other applications, such as our social media handles. When you click one of these links you connect with another platform. We have no responsibility or control over any linked platform, their privacy policies, or the manner in which they collect, use or disclose your personally identifiable information.
10. Governing law and jurisdiction
We are incorporated in the Republic of India and are obligated to comply with Indian laws. We do not warrant compliance with the privacy laws of other jurisdictions and disclaim any knowledge of such legal requirements. Any dispute arising in relation to this Policy shall be subject to the exclusive jurisdiction of the courts in Chennai, India.
11. Grievance mechanism and escalation
Step 1 — Contact us
If you have any grievance or question regarding the privacy of your information, please contact:
- Name
- Srinivasan Chelliah — Grievance Officer
- Phone
- +91 98409 20578
We will respond to any such grievance within 5 days.
Step 2 — Contact the Data Protection Board
If you are not satisfied with our response, or if your grievance remains unresolved, you may contact the Data Protection Board of India once the Board has been constituted and is functional. Its contact details will be updated in this Policy thereafter.