In addition to our Terms and Conditions, Top One Percent respects your privacy and is committed to protecting it. This Privacy Policy (the “Policy”) governs the manner in which the Website collects, uses, maintains and discloses information collected from Users (each, a 'User') of the Website ('Site'). This privacy policy applies to the Site and all products and services offered by the Company. This Policy explains the types of information collected by us when you inquire and/or enroll with us, how we collect, use, share and store such information collected and also explains the rationale for collection of such information, the privacy rights and choices you have regarding your information submitted to us when you inquire and/or enroll.

For ease of reference, use of the terms “Top One Percent”, "we", “us, and/or “our” refer to BOLD Education Private Limited – a company incorporated in India. Similarly, use of the terms “you”, “yours” and/or “User(s)” refer to all those who have inquired and/or enrolled with us.

Please read this Policy carefully prior to accessing our Website and/or Application and using the Services. By accessing and using the Website and/or Application, providing your Personal Information (defined below), or by otherwise signaling your agreement when the option is presented to you, you consent to the collection, use, disclosure, sharing and storing of information described in this Policy, and Terms and Conditions and Top One Percent disclaims all the liabilities arising therefrom.

A. APPLICABILITY
The Policy is applicable to the Users of the Site and all those who inquire and/or enroll with Top One Percent. Top One Percent has taken reasonable precautions as per applicable laws and implemented industry standards to treat Personal Information as confidential and to protect it from unauthorized access, improper use or disclosure, modification and unlawful destruction or accidental loss of the Personal Information.

B. CONTROLLERS
Top One Percent is the controller of Personal Information that it collects and processes in connection with the use of the Website and/or Application and the provision of the Services. The kind of Personal Information we collect in connection with such use is detailed below.

C. PERSONAL INFORMATION
“Personal Information” shall mean the information which identifies a User i.e., first and last name, identification number, email address, age, gender, location, photograph and/or phone number provided at the time of enrollment or any time on the Website.

“Sensitive Personal Information” shall include (i) passwords and financial data (except the truncated last four digits of credit/debit card), (ii) health data, (iii) official identifier (such as biometric data, aadhar number, social security number, driver’s license, passport, etc.,), (iv) information about sexual life, sexual identifier, race, ethnicity, political or religious belief or affiliation, (v) account details and passwords, or (vi) other data/information categorized as ‘sensitive personal data’ or ‘special categories of data’ under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, General Data Protection Regulation (GDPR) and / or the California Consumer Privacy Act (CCPA) (“Data Protection Laws”) and in context of this Policy or other equivalent / similar legislations.

Usage of the term ‘Personal Information’ shall include ‘Sensitive Personal Information’ as may be applicable to the context of its usage.

We request you to not provide Top One Percent with any Personal Information unless specifically requested by us. In the event you share with us any Personal Information without us having specifically requested for the same, then we bear no liability in respect of such Personal Information provided by you.

D. INFORMATION WE COLLECT
We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Products and Services better. We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our Site, register on the Site, subscribe to the newsletter, and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for their Personal Identification Information. Users may, however, visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply Personal Identification Information, except that it may prevent them from engaging in certain Site related activities.

We collect the following information from you:
I. We ask for basic information which may include your name, an email address, contact number.
II. We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users' means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.

E. BASIS OF COLLECTION
We collect and process your Personal Information based on the following legal parameters depending upon the nature of Personal Information and the purposes for which it is processed:
I. Consent: We rely on your consent to process your Personal Information in certain situations. If we require your consent to collect and process certain Personal Information, as per the requirements under the applicable Data Protection Laws, your consent is sought at the time of collection of your Personal Information and such processing will be performed where consent is secured.
II. Compliance with a legal obligation: Your Personal Information may be processed by us, to the extent that such processing is necessary to comply with a legal obligation.

F. PROCESSING OF YOUR PERSONAL INFORMATION
We do not sell, trade, or rent Users’ personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We may process your Personal Information in connection with any of the purposes and uses set out in this Policy on one or more of the following legal grounds:
I. To improve customer service: The information you provide helps us respond to your customer service requests and support needs more efficiently.
II. To personalize User Experience: We may use information in the aggregate to understand how our Users, as a group, use the services and resources provided on our Site.
III. To send periodic emails: We may use the email address to send User information and updates pertaining to their order. It may also be used to respond to their inquiries, questions, and/or other requests. If User decides to opt-in to our mailing list, they will receive emails that may include Company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or User may contact us via our Site.
IV. To market our Products and Services and communicate with You: We will use your information to develop a more targeted marketing of our Products and Services, to communicate with you about our offers, new products, services or even receive your feedback.
V. To establish, exercise, or defend legal claims: We may process any Personal Information identified in this Policy when necessary for establishing, exercising, or defending legal claims, whether in court, administrative, or other proceedings. The legal basis for this processing is our legitimate interest in the protection and assertion of our legal rights, your legal rights, and the legal rights of others.
VI. Consent: We may otherwise use your information with your consent or at your direction.

G. HOW WE PROTECT YOUR INFORMATION
We adopt appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.

H. THIRD-PARTY WEBSITES
Users may find advertising or other content on our Site that links to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website's own terms and policies.

I. MODIFICATION TO PRIVACY POLICY
The Company has the discretion to update this privacy policy at any time. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. Unless stated otherwise, our current Policy applies to all information that we have about you and your account. We stand behind the promises we make, however, and will not materially change our policies and practices making them less protective of customer information collected in the past without your consent. You acknowledge and agree that it is solely your responsibility to review this Privacy Policy periodically and become aware of modifications.