Privacy Policy for CounsellyEdu
CounsellyEdu (“we,” “us,” or “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, services, and platforms (collectively, the “Services”). Our Services provide educational counseling and college admission assistance to parents for their children’s higher education in India and the United States.
This Policy applies to all users, including those in India and the United States. We comply with applicable data protection laws, including the Digital Personal Data Protection Act, 2023 (DPDPA) in India and relevant state privacy laws in the US, such as the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), and similar laws in other states like Virginia, Colorado, and others where applicable.
If you are a resident of India, you are considered a “Data Principal” under the DPDPA, and we act as a “Data Fiduciary.” For US residents, this Policy serves as our privacy notice under applicable state laws. By using our Services, you consent to the practices described in this Policy. If you do not agree, please do not use our Services.
Information We Collect
We collect personal data necessary to provide our Services. This may include:
- Personal Identifiers: Name, email address, phone number, postal address, and other contact details provided during registration, booking, or consultations.
- Student Information: Academic records, test scores (e.g., SAT, ACT, JEE), resumes, essays, recommendation letters, and other documents related to college admissions. This may include sensitive data such as health information if relevant to accommodations or scholarships.
- Payment Information: Billing details, credit card information, or bank details for processing fees.
- Usage Data: IP address, browser type, device information, and interaction data from our website (e.g., pages visited, time spent).
- Communication Data: Recordings or notes from calls (e.g., the initial 11-minute free consultation) and subsequent interactions.
- Other Data: Any additional information you provide, such as preferences for colleges in India or the US, where processes may differ (e.g., interviews for US admissions).
We collect this data directly from you (e.g., via forms, uploads, or calls), automatically through website technologies (e.g., cookies for essential functions), or from third parties (e.g., testing agencies with your consent).
For users in India: We only collect personal data that is necessary for the specified purposes under the DPDPA.
For users in the US: Categories of personal information collected align with those defined under CCPA and similar laws, including identifiers, education information, and commercial information.
How We Use Your Information
We use your personal data for the following purposes:
- To provide and improve our Services, including the initial free 11-minute call, counseling, student profiling, document review, and complete admission assistance.
- To customize services based on your needs, such as university shortlisting, application preparation, and guidance on differences in Indian and US admission processes (e.g., post-application interviews in the US).
- To process payments and manage billing.
- To communicate with you, including updates, reminders, and responses to inquiries.
- To comply with legal obligations, such as record-keeping for audits.
- For internal analytics, research, and service enhancement (anonymized where possible).
- Services after the initial call up to profiling (before admission) are provided as free bonus add-ons, but data collected during this phase is used to facilitate these services.
We process data based on your consent (e.g., for marketing) or legitimate uses (e.g., fulfilling services). For Indian users: Processing is primarily based on consent or legitimate uses as per DPDPA Section 4. We do not process data for purposes beyond those specified without fresh consent.
For US users: We do not “sell” or “share” your personal information as defined under CCPA/CPRA (e.g., for targeted advertising), but if we did, you would have opt-out rights.
Sharing Your Information
We may share your personal data with:
- Service Providers: Counselors, IT vendors, payment processors, and third-party tools for document management or analytics, bound by confidentiality.
- Educational Institutions: Universities or colleges in India or the US for application submissions, with your consent.
- Legal Authorities: If required by law, such as subpoenas or regulatory requests.
- Affiliates: Within our organization for service delivery.
We do not share data for marketing without consent. For cross-border transfers (e.g., US universities), we ensure adequate safeguards.
For Indian users: Sharing complies with DPDPA, and we appoint Data Processors with contractual obligations.
For US users: Disclosures align with CCPA categories; we do not sell data to third parties.
Data Security
We implement reasonable technical and organizational measures to protect your data, including encryption, access controls, and regular audits. However, no system is completely secure, and we cannot guarantee absolute security.
In case of a data breach, we will notify affected users and authorities as required (e.g., within 72 hours under DPDPA for significant breaches).
Data Retention
We retain personal data only as long as necessary for the purposes outlined (e.g., throughout the admission process) or as required by law. Post-service, data is deleted or anonymized within reasonable periods (e.g., 3 years under DPDPA for certain records unless you request erasure).
Your Rights
You have rights regarding your personal data:
- Access: Request details of data we hold.
- Correction: Update inaccurate information.
- Deletion/Erasure: Request removal, subject to legal exceptions.
- Withdrawal of Consent: Opt out of processing where consent-based.
- Portability: Receive data in a structured format (where applicable).
- Objection: Object to certain processing.
- Grievance: File complaints.
For Indian users: Exercise rights as a Data Principal under DPDPA; contact our Data Protection Officer (details below). We respond within 30 days.
For US users: If you are a resident of a state with privacy laws (e.g., California), you have rights to know, delete, correct, and opt-out of sales/sharing. We do not use data for automated decision-making affecting rights. Submit requests via email; we respond within 45 days (extendable). No discrimination for exercising rights.
To exercise rights, email [privacy@counsellyedu.com]. We may verify your identity.
Children’s Privacy
Our Services are for parents, but we process data about students who may be minors. We do not knowingly collect data from children under 13 (US COPPA) or under 18 (India DPDPA) without verifiable parental consent.
Parents: By providing student data, you consent on their behalf. For Indian users: We obtain verifiable parental/guardian consent for processing children’s data under DPDPA.
For US users: Compliant with COPPA for under-13s; parental consent required.
International Data Transfers
Data may be transferred between India and the US for service delivery (e.g., US college applications). We ensure transfers comply with laws, using standard contractual clauses or adequacy decisions where applicable.
Cookies and Tracking
We use essential cookies for website functionality. No third-party tracking for advertising. You can manage browser settings to refuse cookies, but this may affect Services.
Changes to This Policy
We may update this Policy; changes will be posted with the updated date. Continued use constitutes acceptance. Significant changes will be notified via email.