Privacy Policy

Effective date: 1 July 2026 · Last updated: 1 July 2026

1. Who we are and what this policy covers

SIRTIKA™ Learning OS (the “Platform”) is operated by Naveenn Suri, sole proprietor carrying on business under the trade name SIRTIKA, having its principal place of business at B-802, Great Value Sharanam, Sector 107, Noida – 201301, Uttar Pradesh, India (GSTIN: 09AOCPS5021B1ZB) (“SIRTIKA”, “we”, “us” or “our”). This Privacy Policy is a notice that explains how we collect, use, share, and protect the personal data of learners and visitors (“you” or the “Data Principal”) when you register for or use the Platform and the Revenue Growth & Industry Readiness Program (the “Programme”). Please read it together with our Terms & Conditions.

2. The law we follow

We process personal data in accordance with applicable Indian law, including the Information Technology Act, 2000 and the rules currently in force. We have also designed our privacy practices to align with the Digital Personal Data Protection Act, 2023 and the Digital Personal Data Protection Rules, 2025 as their relevant provisions come into force.

3. The personal data we collect

Account data: your name, email address, mobile number, password, and college or organisation (where applicable).
Enrolment and payment data: your payment is processed by our payment gateway, Razorpay. We receive transaction confirmation and records; we do not collect or store your full card, UPI, or bank credentials.
Learning data: your course progress, topics viewed, downloads, capstone submissions, and assessor feedback.
Technical and session data: IP address, device and browser information, and session activity, used for security, access control, and protection of our content (including watermarking and session monitoring).
Communications: messages you send to support, and your preferences.
Cookies and similar technologies, as described in clause 12.

4. How we collect it

We collect personal data directly from you when you register, enrol, and use the Platform; automatically through your use of the Platform; from our payment gateway on completion of a transaction; and, where you are enrolled through a college or partner, from that institution.

5. Why we process it, and our lawful basis

We process your personal data to create and manage your account; deliver the Programme and track progress; process payments and issue receipts; review and assess your capstone and issue your Certificate of Completion; provide support; secure the Platform and protect our intellectual property; comply with law; and send you service communications. We rely on your consent and on other lawful and permitted uses available under applicable Indian law, including the Digital Personal Data Protection Act, 2023 as its provisions come into force.

6. Consent and how to withdraw it

Where we rely on consent, we obtain it through a clear affirmative action at registration or enrolment. You may withdraw your consent at any time by writing to our Grievance Officer (clause 15). Withdrawing consent does not affect processing already carried out, and may mean we can no longer provide part or all of the Programme to you.

7. When we share personal data

We share personal data only with the following categories of recipients:

Service providers who help us run the Platform — hosting and infrastructure, email and communication, analytics, customer-support tools, assessment tools, and our payment gateway (Razorpay) — under appropriate obligations of confidentiality and security.
Your college, placement cell, or sponsoring organisation, only where you are enrolled or sponsored through them, and limited to the progress and completion information needed for that arrangement or provided with your consent.
Authorities or third parties where required by law, regulation, legal process, or to protect our rights.
A successor entity in the event of a merger, acquisition, or restructuring, subject to this policy.

We do not sell your personal data.

8. How long we keep it

We keep personal data only as long as needed for the purposes it was collected or as required by law, and then erase or anonymise it. Our indicative retention schedule is:

Account and profile data: while your account is active and up to 12 months after closure.
Learning and progress records: for your access period and up to 12 months thereafter.
Payment and transaction records: for the period required under tax and accounting law (generally up to 8 years).
Support and correspondence: up to 24 months.
Data from deleted accounts: erased or anonymised within 90 days, except records we are legally required to retain.

These periods are indicative and may be adjusted to meet legal and accounting requirements.

9. How we protect it

We apply reasonable security safeguards, including role-based access control, encryption in transit, restricted access, and protection of learning content through watermarking and session controls. No system is completely secure. In the event of a personal data breach, we will take appropriate steps and notify affected individuals and the relevant authority (including the Data Protection Board of India, as and when that requirement is in force) as required by applicable law.

10. Your rights

In line with the Digital Personal Data Protection Act, 2023 (as its provisions come into force) and other applicable law, you may: access a summary of your personal data and how it is processed; seek correction, completion, or updating of your data; request erasure; nominate another individual to exercise your rights in the event of death or incapacity; and raise a grievance. To exercise any right, write to our Grievance Officer (clause 15).

11. Minors

The Platform is primarily intended for persons aged 18 years or above. Where access is offered to a person below 18, enrolment and payment must be completed by their parent or lawful guardian, who accepts our Terms on the learner's behalf and provides consent. We do not undertake tracking, behavioural monitoring, or targeted advertising directed at children.

12. Cookies and analytics

We use cookies and similar technologies to keep you signed in, remember preferences, secure the Platform, and understand usage. You can control cookies through your browser settings; disabling some cookies may affect how the Platform works.

13. Where your data is stored

We intend to store personal data on servers located in India. We will confirm the location of our hosting, backups, email, and analytics services, and where any processing or transfer takes place outside India, we will carry it out in accordance with applicable Indian law and any restrictions notified by the Central Government.

14. Third-party links

The Platform may link to third-party sites or services (such as the payment gateway). We are not responsible for their privacy practices; please review their policies.

15. Grievance Officer and escalation

For any question, request, or grievance about your personal data, contact our Grievance Officer: Naveenn Suri, n.suri@sirtika.com, B-802, Great Value Sharanam, Sector 107, Noida – 201301, Uttar Pradesh, India. We will acknowledge your request or grievance promptly and respond within the timelines prescribed by applicable law. If you are not satisfied, you may escalate to the Data Protection Board of India as and when that mechanism is operational.

16. Changes to this policy

We may update this policy from time to time and will post the revised version with a new effective date. Where a change introduces a new purpose for processing your personal data that requires your consent, we will obtain fresh consent as required by law, rather than relying on your continued use of the Platform.

17. Contact

Questions about this policy: Naveenn Suri · n.suri@sirtika.com · www.sirtika.com · B-802, Great Value Sharanam, Sector 107, Noida – 201301, Uttar Pradesh, India · GSTIN: 09AOCPS5021B1ZB.