- POLICY TOWARDS CHILDREN
- 2.1. The Platform is not intended for use by a Minor without the permission and supervision of their Guardian. In the event any participant or subscriber to any event organized by LXL is a Minor, the User hereby represents and warrants that the User is the guardian of such Minor accessing the Platform and the Services; and that the User shall ensure that the Minor uses the Services only with the permission and authorization from and under the strict supervision and guidance of the User.
- 2.2. If LXL learns that any personal information has been collected from a Minor, other than as set out herein, or if LXL learns that a Minor has provided personal information beyond the information required by LXL, LXL will delete such information at the earliest possible. If the User believes that a Minor may have provided LXL personal information in violation of the provisions herein, please contact LXL at firstname.lastname@example.org.
- INFORMATION COLLECTED ON THE WEBSITE / APPLICATION
4.1. The User may provide certain information to LXL while registering on the Platform and/or using the Services. LXL receives and stores any information the User, knowingly enters on the Platform, whether via computer, mobile phone, other wireless device, or that the User provides to LXL in any other way. [This information may include personal information such as name, phone number, email address, photograph,
and, in certain circumstances, school affiliation, of the User or the Minor using the Platform under the supervision of the User.]1 [LXL further stores information that it: (a) collects from the User when the User accesses and uses the Service, such as User’s IP address and other relevant details; (b) collects regarding the User’s content, received, uploaded or submitted for any competition or otherwise, using the Platform; and (c) collects information that the User chooses to upload, sync or import from the device on which the Platform is being used. All information disclosed by the User shall be deemed to be disclosed willingly and without any coercion, and in the event of any information being disclosed by a Minor, such information shall be deemed to be disclosed with the consent of the User under whose supervision such Minor is accessing the Platform and Services. No liability pertaining to the authenticity, genuineness, misrepresentation, fraud, negligence, etc. of the information disclosed shall lie on LXL.
4.2. LXL may collect non-personal information relating to the User’s activities while accessing the Services or other information from and about the devices through which the Platform is used including SDK/API/JS code version, browser, internet service provider, timestamp, application identifier, application version, application distribution channel, independent device identifier, android ad master identifier, network card (MAC) address, and international mobile device identification code (IMEI), the equipment model, the terminal manufacturer, the terminal device operating system version, the session start / stop time, location, language, the time zone and the network state (WiFi and so on).
4.3. The Platform is an educational platform which organizes various competitions (“Competitions”), so most of the information the User provides to LXL, is information that the User chooses to be made public and shared with the organizers, sponsors and judges of the Competitions. When the User shares information or content via the Services, the User should think carefully about what the User is making public. Any content submitted by the User may be published or posted on the Website and/or Application.
4.4. In addition to profile information, the User may also provide LXL his/her exact location if the User chooses to enable his/her computer or mobile device to send LXL location information. LXL may use and store information about the User’s location to provide features of the Service and to improve and customize the Service.
4.5. LXL may keep track of how the User interacts with links across the Service, including email notifications, third-party services, and client applications, by redirecting clicks or through other means. LXL does this to help improve the Service, for example to provide relevant advertising, and to be able to share aggregate click statistics such as how many times a particular link was clicked on.
4.6. LXL’s servers automatically record information (“Log Data“) created by User’s use of the Services. Log Data may include information such as IP address, operating system, the referring web page, pages visited, location, mobile carrier, device and application IDs, search terms. LXL receives Log Data when the User interacts with the Service. LXL uses Log Data to provide Services, to measure, customize, and improve the Services, and to aid a better user experience.]2
1 IndusLaw: We have retained photograph and school affiliation as part of the information collected by LXL, as it was mentioned in the draft shared with us. LXL to confirm the personal information that will be collected.
2 IndusLaw: LXL to confirm the log data, if any, that is collected by the Platform.
5. COLLECTION OF INFORMATION BY THIRD-PARTY SITES AND ADVERTISERS
6. [USE OF INFORMATION]3
6.1. The information gathered by LXL as specified in Clause 4 above, may be used for the following purposes:
- (i) for registration, login and management of the Platform;
- (ii) to confirm User’s identity directly and/or through third parties;
- (iii) helping the User efficiently access User’s information after signing into the Platform;
- (iv) remembering User’s personal information so that the User is not required to re-enter it the next time the User visits the Platform;
- (v) to understand the User’s preferences and to enhance and customize User’s experience of using the Platform;
- (vi) for providing customized user relevant suggestion / services;
- (vii) to communicate with the User through push notifications, mail, e-mail and telephone, in connection with the Services;
- (viii) to respond to the User’s comments, reviews and questions and provide better Service;
- (ix) to communicate important notices or changes in the Services, use of the Platform and the terms/policies which govern the relationship between the User and LXL;
- (x) for internal purposes such as auditing, data analysis, research and improvement relating to the Platform or the Services provided through the Platform;
- (xi) for promotion and marketing purposes;
- (xii) for sharing such information with any third party, including any service providers and any group companies of LXL, in the course of providing the Services through the Platform;
- (xiii) to transfer data to the regulatory authorities or other appropriate authorities as required by law.
The data gathered from the User may also be used for any reason incidental to the reasons listed above; and for any other purpose with the consent of the User.
7. DATA INTEGRITY
i) When required to do so by law or regulation, or in response to a request from a law enforcement or governmental agency or authority or to establish or exercise LXL’s legal rights or defend against any legal claims and protect LXL, from incurring any liability.
3IndusLaw: We understand that the information collected by LXL from the users may be used for various purposes and we have revised the clause accordingly. Please confirm the same. Further, we suggest that this clause should be made as comprehensive as possible. While a residuary clause may be retained, it is advisable to disclose all possible purposes for which the user data will be used. Please confirm if there is any other usage of the information collected.
- iv) To firms representing LXL in judicial proceedings and/or any legal, accounting and auditing firms providing services to LXL. Such third parties shall be contractually bound to not disclose further, any personal information disclosed to them.
- v) For any reason incidental to above.
In the events mentioned hereinabove, LXL shall not be under any obligation to inform the User or seek any further approval or consent from the User.
- 7.2. LXL may also share aggregated (and de-identified) information with third parties at its discretion.
- 7.3. Notwithstanding the above, LXL employs other companies and third parties to perform tasks on LXL’s behalf and may share User’s information with such third parties (and for them to use that information) in order to provide aspects of LXL’s Services to the User. Some examples of services for which LXL may use agents include sending email or SMS, analyzing data, and providing user services. LXL may also share User’s information with third parties who provide services such as auditing, data analysis, platform improvement and assistance with delivery of content, relevant marketing messages and advertisements. These third parties may use personal information LXL shares with them, for example, to assist LXL, to provide their services to User and/or LXL, and to measure and improve the performance of their services. [If the User provides a mobile phone number and/or e-mail address, LXL or the third-party service providers or the persons authorized by them, may send the User text messages, e-mails or push notifications in relation to the User’s use of the Platform. LXL contractually requires these third parties to keep such information confidential and use it only for the purposes for which LXL discloses it to them.]4 These third parties may view, edit, or set their own cookies or may place beacons on User’s personal information.
8. DATA PROTECTION
- 8.1. LXL has adopted reasonable industry standard practices, and at the minimum those mandated under applicable laws, to ensure that there are adequate safeguards and techniques to protect the data of the User against any unauthorized or unlawful disclosure. LXL will not store, copy, disclose or use the data of the User except as necessary for the performance by LXL of its obligations under this Agreement or as otherwise provided herein.
- 8.2. LXL employs physical, electronic and procedural safeguards to protect the information that LXL receives from the User, from unauthorized disclosure. LXL limits access to personal information about the User to employees of LXL who LXL believes reasonably needs to come into contact with such information to provide Services to the User or in order to do their jobs.
- 8.3. The User should not, and should ensure that any Minor accessing the Platform does not, share his/her password with anyone. In addition, if the User suspects unauthorized access to his/her information, it is the User’s responsibility to contact LXL immediately. LXL will never ask the User to divulge its password in written or electronic communications. However, please be aware that internet data transmission is not completely secure and LXL cannot warrant that information transmitted through the Platform will be
4 IndusLaw: LXL to confirm.
secure. LXL will always make reasonable efforts to ensure the security of the data provided on the Platform. However, LXL does not assume any liability for breach in the security of User’s information. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of the User’s information at any time.
8.4. In order to facilitate interaction among users of this Platform, other users may share information with User, or User may be allowed to access certain information about other users of this Platform. By entering into this Agreement, User agree to treat information about other users of this Platform with strict confidentiality and User shall not disclose information about any other user of the Platform to a third party.
- DELETION OF INFORMATION OR DATA
- 10.1. Once the User provides relevant information, data on the Platform for creating User’s profile, the same can be deleted by sending a request to the email id email@example.com.
- 10.2. Please note that certain information may remain in LXL’s records, server logs and archives after deletion of the User’s account. LXL retains this information for purposes such as diagnosing problems with the Service and for auditing legal investigations, but reserves the right to delete this information in accordance with its standard business practices in effect from time to time. Further, information and other content that the User has provided may remain visible elsewhere to the extent such content was copied or stored by other users.
- 10.3. For Users with an account that is inactive for twelve (12) months or more (i.e. the account has not received a message through the LXL during the above mentioned period), LXL shall disable access to personal information associated with such account.
- 10.4. If the User’s personal information changes, the User should inform LXL of such changes so that the records of LXL may be updated or corrected. If the User no longer desires the Services, wishes to refuse further contact or communication by LXL, or in order to review, correct, update, amend, delete inaccuracies or to request deletion of the User’s information, the User can contact LXL at firstname.lastname@example.org. LXL will respond to User’s request as quickly as possible.
- 10.5. LXL will retain the User’s personal information or that of the Minor accessing the Platform under supervision of the User, as long as needed to provide the Services, or as required or permitted by applicable laws.
Name of the Grievance Redressal Officer: Sharath Kumar LXL Ideas Private Limited
#175, 2nd Cross Road, Lower Palace Orchards,
Bengaluru, Karnataka 560003
Phone no.: +91 9019111110