Privacy Policy

1. Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service, including Syslabs Academy and Orgofin.
• Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for election of directors or other managing authority.
• Company (referred to as either "the Company", "We", "Us", or "Our" in this Agreement) refers to Syslabs | Xenlabs Services LLP, registered office at 5-45 Narsingapoor, Veenavanka, Karimnagar, Telangana 505502, India, with an operational office at Flat No. 301, 2C, Captain Veera Raja Reddy Marg, Vasant Vihar, Uppal, Hyderabad, Telangana 500007, India.
• Cookies are small files placed on Your computer, mobile device, or any other device by a website, containing details of Your browsing history on that website among its many uses.
• Country refers to: Telangana, India.
• Data Fiduciary has the meaning given to it under India's Digital Personal Data Protection Act, 2023 (DPDP Act) - broadly, the entity that determines the purpose and means of processing Personal Data. The Company acts as a Data Fiduciary in respect of Personal Data collected through the Service.
• Data Principal has the meaning given to it under the DPDP Act - broadly, the individual to whom the Personal Data relates. This corresponds to "Data Subject" under the GDPR and "Consumer" under the CCPA/CPRA.
• Device means any device that can access the Service such as a computer, a cellphone, or a digital tablet.
• Personal Data (referred to as "Personal Information" under the CCPA/CPRA and "Digital Personal Data" under the DPDP Act) is any information that relates to an identified or identifiable individual.
• Service refers to the Website, including syslabs.in, Syslabs Academy, and the Orgofin platform where applicable.
• Service Provider (referred to as "Data Processor" under the GDPR and "Service Provider" or "Contractor" under the CCPA/CPRA) means any natural or legal person who processes data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the Service is used.
• Third-party Social Media Service refers to any website or social network through which a User can log in or create an account to use the Service.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website refers to Syslabs, accessible from https://www.syslabs.in.
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under the DPDP Act, "You" corresponds to a "Data Principal".

2. Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Account credentials (where You create an account with the Service, including Syslabs Academy or Orgofin)
• Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers, and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Information from Third-Party Social Media Services

The Company may allow You to create an account and log in to use the Service through the following Third-party Social Media Services:

• Google
• Facebook
• LinkedIn

If You decide to register through or otherwise grant Us access to a Third-Party Social Media Service, We may collect Personal Data that is already associated with Your Third-Party Social Media Service account, such as Your name, Your email address, and Your activities or contact list associated with that account, to the extent You have authorized such sharing via that service's permission controls.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless You have adjusted Your browser settings so that they will refuse Cookies, our Service may use Cookies.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email, and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

Types of Cookies We Use

• Necessary / Essential Cookies
  • Type: Session Cookies
  • Administered by: Us
  • Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
• Cookies Policy / Notice Acceptance Cookies
  • Type: Persistent Cookies
  • Administered by: Us
  • Purpose: These Cookies identify whether users have accepted the use of cookies on the Website.
• Functionality Cookies
  • Type: Persistent Cookies
  • Administered by: Us
  • Purpose: These Cookies allow Us to remember choices You make when You use the Website, such as remembering Your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter Your preferences every time You use the Website.
• Analytics & Performance Cookies
  • Type: Persistent Cookies
  • Administered by: Third-Party Service Providers (e.g. Google Tag Manager / Google Analytics)
  • Purpose: These Cookies help Us understand how visitors interact with the Service by collecting and reporting information anonymously, supporting analytics tools used by the Company to improve the Service.

For more information about the cookies We use and Your choices regarding cookies, please contact Us using the details in Section 16 (Contact Us).

3. Legal Basis for Processing (GDPR) / Grounds for Processing (DPDP Act)

Where the GDPR applies (for example, if You are located in the EU/EEA or UK), We process Your Personal Data on one or more of the following legal bases:

• Consent - where You have given clear consent for Us to process Your Personal Data for a specific purpose.
• Contract - where processing is necessary for a contract We have with You, or because You have asked Us to take specific steps before entering into a contract.
• Legal obligation - where processing is necessary for Us to comply with the law.
• Legitimate interests - where processing is necessary for Our legitimate interests or those of a third party, provided Your interests and fundamental rights do not override those interests.

Where the DPDP Act 2023 applies, We process Your Personal Data primarily on the basis of Your consent, given through clear affirmative action (such as submitting a form, creating an account, or accepting cookie notices), or where permitted under one of the "legitimate uses" recognized by the DPDP Act, such as for the purpose for which You have voluntarily provided Your Personal Data and have not indicated that You do not consent, compliance with a court order or judgment, responding to a medical emergency, or other purposes specified under the Act and its rules.

4. Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user, including on Syslabs Academy or Orgofin.
• For the performance of a contract: the development, compliance, and undertaking of the purchase contract for the products, items, or services You have purchased, or of any other contract with Us through the Service.
• To contact You: to contact You by email, telephone calls, SMS, WhatsApp, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers, and general information about other goods, services, and events which We offer that are similar to those that You have already purchased or enquired about, unless You have opted not to receive such information.
• To manage Your requests: to attend to and manage Your requests to Us, including requests related to course enrollment, internship applications, or service enquiries.
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving our Service, products, services, marketing, and Your experience.

5. Sharing of Your Personal Data

We may share Your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to process payments, to host data, or to contact You.
• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your information with Our affiliates, in which case We will require those affiliates to honor this Privacy Policy. Affiliates include Syslabs Academy, Syslabs Marketing, and any other subsidiaries, joint venture partners, or other entities that We control or that are under common control with Us.
• With business partners: We may share Your information with Our business partners to offer You certain products, services, or promotions.
• With other users: when You share personal information or otherwise interact in public areas with other users (for example, on Syslabs Academy discussion features, if enabled), such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on that Third-Party Social Media Service may see Your name, profile, pictures, and a description of Your activity. Similarly, other users may be able to view descriptions of Your activity, communicate with You, and view Your profile.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

We do not sell Your Personal Data for monetary consideration. To the extent the CCPA/CPRA's broader definition of "sale" or "sharing" (including for cross-context behavioral advertising) applies to any data transfers We make (for example, to analytics or advertising Service Providers), You may exercise the rights described in Section 11 (Your Privacy Rights - California (CCPA/CPRA)) to opt out.

6. Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain Your data to comply with applicable laws, including tax, accounting, or the DPDP Act's data retention provisions), resolve disputes, and enforce Our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen security or improve the functionality of Our Service, or We are legally obligated to retain this data for longer periods.

Where Personal Data is no longer necessary for the purpose for which it was collected, and We are not required to retain it under applicable law, We will take reasonable steps to erase or anonymize such data, consistent with the data minimization and storage limitation principles under the DPDP Act and GDPR.

7. Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices in Telangana, India, and in any other places where parties involved in the processing are located. This means that this information may be transferred to - and maintained on - computers located outside of Your state, province, country, or other governmental jurisdiction where data protection laws may differ from those of Your jurisdiction.

Your consent to this Privacy Policy, followed by Your submission of such information, represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy. Where the DPDP Act requires, cross-border transfers of Personal Data will be made only to countries permitted under the Act (or, where no restricted list is notified, in a manner consistent with the Act's general requirements). Where the GDPR applies, transfers of Personal Data outside the EU/EEA or UK will rely on an adequacy decision, Standard Contractual Clauses, or another valid transfer mechanism recognized under the GDPR.

8. Your Privacy Rights - India (Digital Personal Data Protection Act, 2023)

If You are located in India, the DPDP Act 2023 gives You, as a Data Principal, the following rights in relation to Your Personal Data processed by Us:

• Right to Access Information: You have the right to obtain a summary of the Personal Data We hold about You and the processing activities undertaken with respect to such data.
• Right to Correction and Erasure: You have the right to request correction of inaccurate or misleading Personal Data, completion of incomplete Personal Data, updating of Personal Data, and erasure of Personal Data that is no longer necessary for the purpose for which it was processed, unless retention is required for a legal purpose.
• Right to Grievance Redressal: You have the right to have Your grievances regarding the processing of Your Personal Data addressed by Us in a timely manner. See Section 16 (Contact Us) for Our grievance contact details.
• Right to Nominate: You have the right to nominate another individual to exercise Your rights under the DPDP Act in the event of Your death or incapacity.
• Right to Withdraw Consent: Where We process Your Personal Data on the basis of Your consent, You have the right to withdraw that consent at any time, with the withdrawal being as easy as it was to give consent. Withdrawal of consent does not affect the lawfulness of processing carried out before such withdrawal.

To exercise any of these rights, please contact Us using the details in Section 16 (Contact Us). We will respond to verifiable requests within the timeframes prescribed under the DPDP Act and its rules.

9. Your Privacy Rights - EU/EEA & UK (GDPR)

If You are located in the European Economic Area, the European Union, or the United Kingdom, You have the following rights under the GDPR (and, where applicable, the UK GDPR):

• Right to be informed: You have the right to be informed about the collection and use of Your Personal Data, which this Privacy Policy aims to provide.
• Right of access: You have the right to request copies of Your Personal Data.
• Right to rectification: You have the right to request that We correct any information You believe is inaccurate or complete information You believe is incomplete.
• Right to erasure ("right to be forgotten"): You have the right to request that We erase Your Personal Data, under certain conditions.
• Right to restrict processing: You have the right to request that We restrict the processing of Your Personal Data, under certain conditions.
• Right to object to processing: You have the right to object to Our processing of Your Personal Data, under certain conditions, including processing for direct marketing purposes.
• Right to data portability: You have the right to request that We transfer the data We have collected to another organization, or directly to You, under certain conditions.
• Rights related to automated decision-making and profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning You or similarly significantly affects You, except in limited circumstances permitted under the GDPR.

If You wish to exercise any of these rights, please contact Us using the details in Section 16 (Contact Us). You also have the right to lodge a complaint with a supervisory authority in your country of residence or work, or in the place where an alleged infringement occurred.

10. Your Privacy Rights - California (CCPA/CPRA)

If You are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), gives You the following rights regarding Your Personal Information:

• Right to know: You have the right to request that We disclose what Personal Information We collect, use, disclose, and sell or share about You.
• Right to delete: You have the right to request that We delete Personal Information We have collected from You, subject to certain exceptions.
• Right to correct: You have the right to request that We correct inaccurate Personal Information We maintain about You.
• Right to opt out of sale or sharing: You have the right to direct Us not to sell or share (including for cross-context behavioral advertising) Your Personal Information. The Company does not sell Personal Data for monetary consideration; if any data transfers qualify as "sharing" under the CPRA's broader definition, You may opt out by contacting Us.
• Right to limit use of sensitive personal information: You have the right to limit the use and disclosure of sensitive Personal Information to that which is necessary to perform the Service.
• Right to non-discrimination: You have the right not to receive discriminatory treatment for exercising any of the rights described above.

To exercise any of these rights, please contact Us using the details in Section 16 (Contact Us). We will verify Your request using the information associated with Your account or Your interactions with the Service before fulfilling it, as required under the CCPA/CPRA.

11. Deleting Your Personal Data

You have the right to delete, or request that We assist in deleting, the Personal Data that We have collected about You, subject to applicable legal retention requirements described in Section 6 (Retention of Your Personal Data).

Our Service may give You the ability to delete certain information about You from within the Service, such as account settings on Syslabs Academy or Orgofin.

You may update, amend, or delete Your information at any time by signing in to Your Account, if You have one, and visiting the account settings section that allows You to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information where We have a legal obligation or lawful basis to do so.

12. Other Disclosures of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition, or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency), consistent with the legitimate uses recognized under the DPDP Act and equivalent provisions under the GDPR and CCPA/CPRA.

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

13. Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While We strive to use commercially acceptable technical and organizational measures - including access controls, encryption in transit, and restricted internal access - to protect Your Personal Data, We cannot guarantee its absolute security.

If We become aware of a personal data breach that is likely to result in significant harm to You, We will take steps to notify You and the relevant supervisory authority (such as the Data Protection Board of India under the DPDP Act, or other applicable regulators under the GDPR or CCPA/CPRA) as required under applicable law.

14. Children's Privacy

Our Service is not directed to individuals under the age of 18 (or such other age as constitutes a "child" under applicable law, including under the DPDP Act, which defines a child as an individual under 18 years of age). We do not knowingly collect Personal Data from anyone under the age of 18 without verifiable parental or guardian consent.

Where the Service is used in an educational context (for example, by students enrolled through Syslabs Academy via their institution), and any User is identified as being under the age of 18, We will process such User's Personal Data only with verifiable consent from a parent or lawful guardian, and only to the extent necessary to provide the educational Service, in a manner that does not involve tracking, behavioral monitoring, or targeted advertising directed at children, consistent with the DPDP Act's requirements for processing children's data.

If You are a parent or guardian and become aware that Your child has provided Us with Personal Data without your consent, please contact Us using the details in Section 16 (Contact Us). If We become aware that We have collected Personal Data from a child without verification of parental or guardian consent, We will take steps to remove that information from Our servers.

15. Links to Other Websites

Our Service may contain links to other websites that are not operated by Us, including but not limited to third-party scheduling tools (such as Calendly), payment gateways, and social media platforms. If You click on a third-party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party sites or services.

16. Contact Us - Grievance Redressal & Privacy Requests

If You have any questions about this Privacy Policy, wish to exercise any of the rights described above, or have a grievance regarding the processing of Your Personal Data (including under the DPDP Act's grievance redressal requirements), You can contact Us:

• By email (Privacy / Data Protection enquiries): [email protected]
• By phone: +91 6303782560
• By post (Registered Office): 5-45 Narsingapoor, Veenavanka, Karimnagar, Telangana 505502, India
• By post (Operational Office): Flat No. 301, 2C, Captain Veera Raja Reddy Marg, Vasant Vihar, Uppal, Hyderabad, Telangana 500007, India

We aim to acknowledge and respond to privacy requests and grievances within the timeframes prescribed under applicable law, including the DPDP Act 2023.

17. Changes to this Privacy Policy

We may update Our Privacy Policy from time to time to reflect changes in our practices, the Service, or applicable law (including future rules notified under the DPDP Act 2023). We will notify You of any material changes by posting the new Privacy Policy on this page and updating the "Last Updated" date at the top of this Privacy Policy.

Where required by applicable law, We will also notify You via email and/or a prominent notice on Our Service prior to the change becoming effective.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.