“Protecting data is a matter of trust and your privacy is important to us”.

Your Privacy is of paramount importance to us. This Policy complies with Rule 4 of the Information Technology (Reasonable Security Practices, Procedures, and Sensitive Personal Data or Information) Rules, 2011. You are requested to please have a read and accept our privacy policy before going further, as it sets out important information relating to how we handle your personal information.

Welcome, Lead Labs / LeadLabs App Inc./ VC Learning Edtech LLP Users!

Any person who wishes to use our Platform or software in order to upload video(s) / image(s) / pdf file(s) etc. (hereinafter referred to as “Content”) on the Platform, shall be considered and is hereinafter addressed as ‘Customer’.

Any person accessing, browsing, or watching the Content uploaded by Customers on our Platform, either manually or via an automated device or program, shall be considered and is hereinafter addressed as ‘User’ . [The Customers and the Users are hereinafter collectively addressed as ‘you’].

Lead Labs respects the privacy of its Customers and Users, and always endeavour to protect their personal information on top priority. This website or any other website owned and managed by VC Learning Edtech LLP , including the Mobile App (hereinafter referred to as “Platform”), web interfaces, documentation, servers and all other Intellectual Property, software and infrastructure is owned, operated and managed by VC Learning Edtech LLP (hereinafter referred to as “we” or “our”), a registered limited liability partnership in India under the Limited Liability Partnership Act, 2008.

Our software tools offer our Customers and Users the ability to easily produce creative interactive experiences and capture leads. The software has been designed and developed for the Customers (including but not limited to course creators, business owners, digital marketers and freelancers) and Users for the purpose of capturing leads and making the interactions more creative.

We firmly desire you to read this policy and make sure you fully understand it, before you access or use any of our services. This Privacy Policy covers the use of Lead Labs Platform.

Lead Labs does not sell, rent or disclose your personal information to anyone until mentioned hereunder int his Policy. The Privacy Policy is open to the public at all times so that you may read the full text of the Privacy Policy whenever you intend to do so.

The purpose of this Privacy Policy is to explain the type of information that we collect from you and the processing of such collected information.

This Privacy Policy may be amended from time to time based on our requirements and the effective date of the amended policy will be reflected herein. Customers and Users will be informed about the updated Privacy Policy via pop-up notification or e-mail. In view of the above, Customers and Users are requested to review the changes carefully. If you disagree with the Privacy Policy, you must stop using the service(s). If you continue to use the amended Platform / software or any such platform owned and developed by VC Learning Edtech LLP , as applicable, it will be deemed that you have read the changes and given your consent to such changes. In this regard, Customers and Users acknowledge that it is the responsibility of the Customers and Users itself, to review this Privacy Policy from time-to-time.

This Privacy Policy contains the following sections-

(A) WHAT IS THE PURPOSE OF THIS POLICY?

We are committed to safeguarding the privacy of Customers and Users of our Platform. This Policy applies where we are acting as a data controller with respect to the personal data of our Customers and Users by determining the purposes and means of processing the user Information.

This Privacy Policy has been drafted in order to make you understand as to how we collect, use and protect the information we receive from Customers and Users at our Platform and software, and the same is applicable to everybody who use our services.

(B) WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers the type of information collected from the Users through the Platform which includes the sensitive Personal Data or the information. This Policy also tells us the purpose, means and modes of usage of such information and how and to whom such information, which has been collected will be disclosed.

(C) WHAT INFORMATION DO WE DISPLAY OR COLLECT?

C.1 Information User / You provide to us

To use our Platform, following information from the User’s database are collected in order to generate unique User ID’s and encrypted passwords, such as your name, e-mail, contact details, etc. on our server but inaccessible to VC Learning EdTech LLP. Customers after signing-up are allowed to upload Content on the Platform. Such data are stored with Lead Labs / VC Learning Edtech LLP and Users can see / watch such Content after providing the requisite information.

Since the software has been designed to create leads and make interactions between the Customers and the Users, therefore data of such Users who visit our Platform are also stored with us, which includes their name, e-mail, contact details, etc.

C.2 Information collected automatically

When you interact through the Platform, Lead Labs would automatically receive and record information on our server logs from your browser, including your IP address, Lead Labs’ cookie information, and the page(s) you might visit next. We also record the details of your activity on the Platform, and the number and frequency of Users to our Platform and its components.

During sign-up / browsing on the Platform, we automatically collect information on the device type, the operating system version, the app version, User’s name, e-mail, contact details, company website, monthly web traffic and monthly leads generated, as well as actions performed by you.

We also use third-party mobile analytics software to allow us to better understand the functionality of our Mobile App on your phone. This software may record information such as how often you use the Mobile App, the events that occur within the Mobile App, aggregated usage information, performance data, and where the application was downloaded from.

Cookies are alphanumeric identifiers that are transferred to your computer or mobile device to enable systems to recognize a computer or device and specify how and when pages in a site are visited and by how many people. Lead Labs cookies may collect Personal Information of the Customers and Users and combines the general information collected through these cookies with other Personal Information for various purposes, such as to allow for single-sign-on and to count the number of visitors to a Lead Labs page. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways.

The Platform may also contain electronic images known as web beacons (sometimes called single-pixel gifs), which are used along with cookies to compile aggregated statistics to analyze how the Platform are used. Gifs are not Personal Information and are sourced from a third party(s), but we evaluate them periodically to ensure they meet our trust & safety requirements.

(D) WHAT DOES LEAD LABS USE MY IMFORMATION FOR?

D.1 Generally

Customers and Users are allowed to access the Platform, create their accounts, register for services available with Lead Labs by creating an account on the Platform or providing any Personal Information. Lead Labs takes no responsibility or validates the information provided by the Customers and Users except as otherwise required under any law, regulation or an order of competent authority. In order to have access to all the features and benefits on our Platform, a Customer and / or User is required to first create an account on our Platform. Other information requested on the registration page, including the ability to receive promotional offers from Lead Labs is optional. Lead Labs may, in future, include other optional requests for information from the Customers and User to help Lead Labs to customize the Platform to deliver personalized information to the Customers and User.

The other purpose of collection of information is to provide customer service, for the improvement of the Platform, personalization of Customer and User experience, to administer contests, surveys etc., or sending newsletter or the promotional e-mails.

D.2 Personal Information

We also use the Personal Information you provide to respond to your requests for certain information on our Platform or software, customizing your experience, and communicating with you about the Platform.

D.3 Your e-mail address

Use of our Platform requires your e-mail address and we may send you e-mail communications. Web beacons may also be used in some of our e-mails to let us know which e-mails have been opened by recipients, which allows us to gauge the effectiveness of our customer communications.

If you no longer wish to receive e-mails from Lead Labs, please click the unsubscribe link that is included in the footer of our e-mails, update your email preferences or contact us at vineeth@vclearing.co

D.4 Mobile usage information

Mobile usage information is used to determine device capabilities and usage trends, which allows us to better understand which devices we should support and what features are most frequently used. We do not link this information, we obtain from analytics software to any personally identifying information that you submit within the Mobile App.

D.5 Push notifications

If you use the Mobile App, we will send push notifications to your mobile device in order to make you aware of certain activities that may occur within your account, such as when someone has entered a new post, when you have new notifications, or when grades have been posted. You may opt-out of receiving these types of communications by turning them off at the device level or emailing us at vineeth@vclearning.co

(E) CUSTOMER / USER RIGHTS

Customers and / or Users may at any time request information about the data, which we hold about the them as well as about their origin, recipients or categories of recipients to which such data is forwarded and about the retention purpose.

Customer and / or User may request immediate correction of any incorrect personal data related to them or opt for a restriction of the processing. The Customers and / or User is also entitled to request completion of incomplete personal data also by means of a supplementary declaration.

Customers and / or Users are entitled to receive the respective personal data provided to us in a structured, common, and machine-readable format and User is entitled to transmit such data to other data controllers without restriction if the processing was based on Customers and / or User consent or if the data was processed by means of automated procedures.

Customers and / or Users may also request for removal of any personal data. Once such request is being placed by the Customers and / or User, we are, inter-alia, obliged to erase such data only in such case when it is no longer required for the purpose for which it was collected or otherwise processed. Customers and / or User may withdraw the given consent to the use of his/her data at any time.

Customers and Users understand that the Platform is only a software / tool developer and provider. Lead Labs / VC Learning Edtech LLP have no role in the Content of the uploaded by the Customers that is being placed upon our Platform. Therefore, we shall be at no case be held responsible for authenticity, accuracy or storage of the data. Likewise, we are not responsible for any Content created and uploaded by the Customers. Lead Labs / VC Learning Edtech LLP takes no responsibility or verify its accuracy over e-mails, notifications, ads, certificates, links, sent by Customers to their respective Users.

(F) RETENTION PERIOD

We retain your personal information as long as it is necessary and expedient for our operations. Besides, we may retain personal information from closed accounts to comply with national laws, prevent fraud, collect any payment owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our terms of use and take other actions permitted or required by applicable Indian laws. In the event it is no longer required for us to retain your personal information, we dispose off in a secure manner according to our relevant policies.

(G) HOW DO WE DISCLOSE YOUR INFORMATION?

G.1 information sharing

Except as set forth in this Privacy Policy or as specifically agreed to by you, Lead Labs / VC Learning Edtech LLP will not disclose any of your Personal Data. In addition to the other uses set forth in this Privacy Policy, Lead Labs / VC Learning Edtech LLP may disclose and otherwise use Personal Data as described below.

• Lead Labs uses Personal Data which you provide to us in order to allow you to access and use the Platform and/or software, and in order to provide any information, products, or services that you request from us.

• Lead Labs may use Personal Data to provide technical support to you, where required, and to ensure the security of our services and the Platform.

• Lead Labs uses the Personal Data that we collect from you when you participate in a content offering through our Platform for processing purposes.

• Joint promotions are possible to share the related information to offering a wider portfolio, experience, and knowledge to its Customers. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, provided that such parties agree to keep this information confidential.

• We may also release your information when we believe release is appropriate to comply with the law, enforce our website policies, or protect ours or others' rights, property, or safety.

G.2 Information sharing with Users

This Policy control applies to all systems, people and processes that constitute the organization’s information systems, including board members, employees and other third parties who have access to Personal Data available within Lead Labs.

The information of Users visiting our Platform and providing information for the purpose of watching the Content is supplied to the respective Customers who have uploaded Content, enabling them to contact the Users, so that they can offer, market, and sell their services.

Each such Customer will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such Customer will supply to you a copy of its own privacy policy, if available, which will govern that third party’s use of your Personal Information.

G.3 Disclosure of information for legal compliance

In addition to the foregoing, we may disclose your Personal Information where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your Personal Information where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

G.4 Disclosure of Personal Information to third-party service providers facilitating links and payment

We provide the Customers with the ability to pay for service offerings and software usage using a credit card or other methods through a third party payment processing service provider. Please note that such service provider and not Lead Labs / VC Learning Edtech LLP, collects and processes your financial information. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your transactions, payments, refunding such payments, and dealing with complaints and queries relating to such payments and refunds.

(H) COOKIES & SIMILAR TECHNOLOGIES

We collect Personal information using cookies, web beacons, and similar technologies. We use cookies to help us compile aggregate data about Platform traffic and interactions so that we can offer better Platform experiences and tools in the future. We also use cookies to:

• Understand and save the Customer’s and User's preferences for future visits.

• Compile aggregate data about Platform traffic and interactions to offer better experiences and tools in the future. We may also use trusted third party services that track this information on our behalf.

• Use Third-Party services to track this information for us.

• To restrict usage of the software on the defined number of machines to avoid unauthorized access to software.

Where such cookies are not strictly necessary for the utilization of the Lead Labs / VC Learning Edtech LLP Platform and services rendered thereon, we will ask you to consent to our use of cookies when you first visit our Platform.

(I) GLOBAL DATA PROTECTION REGULATIONS (GDPR) & ITS COMPLIANCE FOR EURPOEAN UNION RESIDENTS

Customers and Users are requested to note that this Website further complies with the Global Data Protection Regulations (GDPR) for data protection of the citizens of the European Union. GDPR was implemented in May 25, 2018 in the European Union and requires organizations to safeguard personal data and uphold the privacy rights of anyone in EU territory. So, if you are a citizen of European Union countries, you have certain rights and privileges as mentioned below:

• Right to access and/or correct your personal information;

• Right to restrict use of your personal information;

• Right to request deletion of your personal information;

• Right to object to processing of your personal information;

• Right to data portability;

• Right to lodge a complaint with a supervisory authority in the country where you reside.

Customers and Users may further note that they can use the right to request deletion of their personal information by filling up a simple Right to Erasure Request Form.

(J) SECURITY

This Platform has security measures to protect against the loss, misuse, and alteration of the information that is submitted to Lead Labs / VC Learning Edtech LLP and is under its control. We have complied with Secured Socket Layer Certificate (SSL Certification). We also have embedded malware scan software. However, we make no representations or warranties concerning the sufficiency of these security measures. We shall not be responsible for any actual or consequential damages that result from a lapse in compliance with this Policy as a result of a security breach or technical malfunction. Certain information may be transmitted to you by e-mail. Besides, only you and anyone, to whom you address your message in most cases, view Customers’ and Users’ communications through the Platform. As the operator of the Platform or software, we may need to review or monitor your electronic mail and other communications from time to time as may be required by law.

(K) PASSWORD RELATED INFORMATION

Password is encrypted and not visible even to Lead Labs / VC Learning Edtech LLP. There shall be no storage of password related information of the Customers or Users. If the Customer or User forgets his/her password, an e-mail link shall be sent for verification purpose. All password requests will be forwarded to the registered e-mail with the option to contact us.

Customers or Users cannot recover old password. However, he/she can reset his/her password and link for reset will be sent to the customer at registered identity.

(L) DISPUTE RESOLUTION AND JURISDICTION

It is expressly agreed to by the Parties hereto that the formation, interpretation, and performance of this Policy, and any disputes arising here from will be resolved through a two-step Alternate Dispute Resolution (“ADR”) mechanism. It is further agreed to by the Parties that the content of this Section shall survive even after the termination or expiry of the Policy and/or Terms.

In case of any dispute between the parties, the Parties will attempt to resolve the same amicably amongst themselves, to the mutual satisfaction of both Parties. If the Parties are unable to reach such an amicable solution within thirty (30) days of one Party communicating the existence of a dispute to the other Party, the dispute will be resolved by arbitration, as detailed herein below.

The Parties expressly agree that the Privacy Policy is governed by the laws, rules, and regulations of India, and that the Courts at Karnataka shall have exclusive jurisdiction over any disputes arising between the Parties.

(M) GRIEVANCE OFFICER

In accordance with Rule 5 (9) of the Information Technology (Reasonable Security Practices, Procedures and Sensitive Personnel Data or Information) Rules, 2011, the name and contact details of the Grievance Officer who can be contacted for any complaints or concerns pertaining to the Platform, including those pertaining to breach of the Terms of Use or and other polices are published as under:

Vineeth Ellore