📋 Privacy at a Glance

Data FiduciaryThe smARTists — Ms. Sridevi Manoj
Data we collectParent name, child name & age, WhatsApp, email
Why we collect itTo respond to enquiries and manage enrolment
Do we sell your data?No — never, under any circumstances
Children's dataProcessed only with verifiable parental consent
Your rightsAccess, correct, erase, withdraw consent anytime
Retention period3 years from last interaction, or until withdrawal
Grievance officerMs. Sridevi Manoj — thesmartistssridevi@gmail.com
👧
Important — Children's Data: Our services are for children aged 6–12. We process a child's personal data only on the basis of verifiable consent provided by a parent or legal guardian, in compliance with Section 9 of the DPDP Act, 2023. We do not process children's data for profiling, behavioural monitoring, or targeted advertising.

1 Identity of the Data Fiduciary

Under the Digital Personal Data Protection Act, 2023 (DPDP Act), The smARTists is the Data Fiduciary — the entity that determines the purpose and means of processing your personal data.

🏢 Name: The smARTists

👤 Operated by: Ms. Sridevi Manoj

📍 Address: 23/4, Gangadara Chetty Cross Road, Rukmani Colony, Sivanchetti Gardens, Bengaluru, Karnataka – 560042

📧 Email: thesmartistssridevi@gmail.com

📱 WhatsApp: +91 6379 741 305 (WhatsApp only)

🌐 Website: thesmartists.in

2 Personal Data We Collect

We collect only the minimum personal data necessary for the specific purpose stated. The table below describes what we collect, why, and the legal basis under the DPDP Act:

Data Collected Purpose Legal Basis (DPDP Act)
Parent / Guardian name To address and identify the person responsible for the child Consent (Section 6)
Child's name To personalise class placement and communication Consent of parent/guardian (Section 9)
Child's age To assign the appropriate programme (6–8 or 8–12) Consent of parent/guardian (Section 9)
WhatsApp number To schedule a class and send updates Consent (Section 6)
Email address To send confirmation, reminders, and programme updates Consent (Section 6)
Programme interest To recommend the right class for your child Consent (Section 6)
Preferred timing To allocate a suitable batch Consent (Section 6)
Message / Notes To understand specific needs or questions Consent (Section 6)
We do not collect sensitive personal data (financial information, government IDs, biometric data, health records, or caste/religion information) at any point.

3 Consent — How We Obtain and Manage It

Under Section 6 of the DPDP Act, 2023, we are required to obtain free, specific, informed, unconditional, and unambiguous consent before processing your personal data.

How we obtain consent

Withdrawing consent

You have the right to withdraw consent at any time, without affecting the lawfulness of processing prior to withdrawal. To withdraw consent:

We will process all withdrawal requests within 7 working days and confirm deletion in writing.

Please note: Withdrawal of consent means we will no longer be able to contact you about your child's enrolment or programme updates. If your child is currently enrolled, please discuss continuity of service with us before withdrawing consent.

4 Processing of Children's Personal Data

This section addresses compliance with Section 9 of the DPDP Act, 2023, which applies specifically to the processing of personal data of children (persons under 18 years of age).

Verifiable parental consent

We process a child's personal data — specifically their name and age — only on the basis of consent provided by a parent or legal guardian. By submitting our form, the submitter confirms they are the parent or legal guardian of the child named.

What we do NOT do with children's data

Under Section 9(3) of the DPDP Act, we strictly do NOT:

✗ Track or monitor children's behaviour
✗ Use children's data for targeted advertising
✗ Profile children based on their data
✗ Share children's personal data with any third party for commercial purposes
✗ Collect data from children directly — all data is collected from parents/guardians

Minimum data principle

We collect only a child's first name and age group — the minimum necessary for class placement. We do not collect school names, photographs, health information, or any other data about the child without explicit separate consent.

Age verification

Our form is directed at parents and guardians. If we become aware that data has been submitted by or about a child without parental consent, we will delete it immediately.

5 How We Use Your Personal Data

We process personal data only for the purposes for which it was collected. We will not use your data for any other purpose without obtaining fresh consent.

Purpose limitation: We will never use your data for purposes beyond those listed above without your explicit consent.

6 Data Processors and Third-Party Services

We use the following third-party services that may process your personal data on our behalf. Each is bound by appropriate data processing agreements:

Service Purpose Data Shared Location
Brevo (formerly Sendinblue) Email marketing & contact management Name, email, WhatsApp, programme details EU (GDPR compliant)
Bluehost India Website hosting No personal data stored in website files India
Google Maps Location display on website No personal data — anonymised usage only USA (Google's servers)
Google Fonts Website typography No personal data — IP address only (Google) USA (Google's servers)
Cross-border data transfer: Brevo stores data on servers in the European Union. This constitutes a cross-border transfer of personal data. Brevo is GDPR-compliant and maintains Standard Contractual Clauses (SCCs) for such transfers. We will update this section when the Indian government notifies additional rules on cross-border data transfers under the DPDP Act.

We do not sell, rent, or trade your personal data with any third party for their own marketing or commercial purposes.

7 Data Retention

We retain personal data only as long as necessary for the stated purpose or as required by applicable law, whichever is longer.

Data TypeRetention PeriodReason
Enquiry data (non-enrolled) 12 months from submission Follow-up and future programme interest
Enrolled student records 3 years from last class attended Academic records and re-enrolment
Email communication records 3 years Dispute resolution and audit trail
Withdrawn consent records 1 year from withdrawal Evidence of compliance with withdrawal request

After the retention period, data will be securely deleted or anonymised. You may request earlier deletion at any time — see Section 8.

8 Your Rights as a Data Principal

Under the DPDP Act, 2023, you (the Data Principal) have the following rights with respect to your personal data:

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Right to Access
Request a summary of the personal data we hold about you and how it is being processed.
✏️
Right to Correction
Request correction of inaccurate, incomplete, or outdated personal data.
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Right to Erasure
Request deletion of your personal data when the purpose of processing is fulfilled or consent is withdrawn.
🚫
Right to Withdraw Consent
Withdraw consent at any time without affecting prior lawful processing. We will act within 7 working days.
📋
Right to Grievance Redressal
Lodge a grievance with our Grievance Officer. We will respond within 48 hours and resolve within 30 days.
👤
Right to Nominate
Nominate another individual to exercise your rights on your behalf in the event of death or incapacity.

How to exercise your rights

Submit your request to our Grievance Officer:

👤 Grievance Officer: Ms. Sridevi Manoj

📧 thesmartistssridevi@gmail.com — Subject: "Data Rights Request"

📱 +91 6379 741 305 (WhatsApp only)

⏱️ Response time: Acknowledgement within 48 hours · Resolution within 30 days

Escalation: If your grievance is not resolved to your satisfaction within 30 days, you may approach the Data Protection Board of India once it is constituted under the DPDP Act, 2023.

9 Data Security

We implement reasonable security measures to protect personal data against unauthorised access, disclosure, alteration, or destruction, including:

Data breach notification: In the event of a personal data breach that is likely to result in harm to you, we will notify affected individuals and the Data Protection Board of India (once notified) as required under Section 8(6) of the DPDP Act, 2023, in the prescribed manner and within the prescribed timeline.

10 Cookies and Tracking

Our website does not use tracking cookies, advertising cookies, or behavioural analytics tools. We do not use Google Analytics, Meta Pixel, or similar tracking services.

The following third-party resources are loaded when you visit our site and may involve limited technical data collection by those parties:

Please refer to Google's Privacy Policy for information on how Google handles this data.

11 Marketing Communications

We send marketing communications (updates, event announcements, offers) only to individuals who have explicitly opted in via our form. Each communication will include a clear opt-out mechanism.

To opt out of marketing communications at any time:

Opt-out requests will be processed within 7 working days.

12 Cross-Border Data Transfers

When you submit our enquiry form, your data is processed by Brevo, whose servers are located in the European Union. This constitutes a cross-border transfer of personal data outside India.

We ensure this transfer is protected by appropriate safeguards including Brevo's compliance with GDPR and Standard Contractual Clauses. We will update our practices in accordance with any rules notified by the Central Government under Section 16 of the DPDP Act, 2023.

13 Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or regulatory requirements. When we make material changes, we will update the "Last updated" date at the top of this page.

We encourage you to review this policy periodically. Continued use of our website or services after any changes constitutes your acknowledgement of the updated policy.

14 Grievance Officer

In accordance with Section 13 of the DPDP Act, 2023, we have designated a Grievance Officer to address data-related complaints and requests:

👤 Name: Ms. Sridevi Manoj

🏢 Organisation: The smARTists

📍 Address: 23/4, Gangadara Chetty Cross Road, Rukmani Colony, Sivanchetti Gardens, Bengaluru, Karnataka – 560042

📧 Email: thesmartistssridevi@gmail.com

📱 WhatsApp: +91 6379 741 305

⏱️ Response: Acknowledgement within 48 hours · Resolution within 30 days