Privacy Policy

About the Policy:

Effective Date: October 25, 2025
Last Updated: October 25, 2025
Applicable Laws: While we are based in India and adhere to local laws, including the Digital Personal Data Protection Act (DPDP), we strive to meet the spirit of global privacy regulations like the GDPR where applicable to our users.

Privacy Inquiries:

Email: aurigapvtltd@gmail.com
Address: [Insert Registered Address from Source 3.2: Sreemandiram, 10/119, Nellikkottu, Ramanattukara, Kozhikode, Kozhikode, Kerala, India, 673633 – or other official address]
Please address all DPO inquiries to the email above, subject line: “DPO Inquiry.”

Basic Definitions:

Personal Data (PD): Any information relating to an identified or identifiable natural person.
Processing: Any operation performed on Personal Data, such as collection, recording, organization, storage, use, disclosure, or deletion.
Controller: The entity that determines the purposes and means of the Processing of Personal Data (Auriga ThriveX).
“We,” “Our,” “Us”: Refers to Auriga ThriveX and its associated legal entity (Thrivex Auriga Private Limited).
“You,” “Your”: Refers to the parents, guardians, students, or other clients utilizing the Auriga ThriveX program.
Third Parties: Any person or entity other than Auriga ThriveX and the user.

Collected Data:

Types of Personal Data Collected:

Identification & Contact Info: Name, email address, phone number, login credentials.
Service Data (Usage & Progress): Student progress details, habit tracking with photo proof, mentor feedback, daily micro tasks completion.
Financial Info: Payment data and billing information necessary to process program fees.
Technical Data: IP address, device type, operating system, browser type, and time zone setting.
Usage Data: Details of your visits to our app and website, including page visits, clickstream data, and program features used.
User-Generated Content: Communication via the app or website, feedback provided during monthly reviews, and survey responses.

How Data is Collected:

Directly from You: When you register for the program, subscribe to our newsletter, fill out forms, or interact with our mentors.
Automatically (via Technology): Through the use of cookies, web beacons, and analytics tools as you navigate our mobile application and website.
From Third Parties: If you use a third-party payment gateway, we receive confirmation of the payment transaction (but not your full payment card details).

Data Collection Purpose:

Account Creation and Authentication: To set up and manage your access to the 40-week program and the mobile app.
Service Delivery and Customization: To provide the mentoring program, track progress (daily micro tasks, monthly reviews), and tailor the experience.
Customer Support: To respond to your inquiries, provide technical support for the app, and resolve disputes.
Marketing and Communication: To send you updates, promotional materials, and information about our services (Teachers Training, Parents Training, etc.).
Analytics and Product Improvement: To monitor usage, analyze trends, assess the effectiveness of our program design, and improve service functionality.
Legal/Contractual Obligations: To fulfill our contractual agreement with you and meet necessary legal or compliance requirements.
Fraud Detection and Security: To prevent illegal activity, protect against unauthorized access, and ensure a safe user environment.

Explicit User Consent:

Sign-Up/Registration: Consent is sought before finalizing your account creation and accessing the services.
Marketing Communications: Separate opt-in consent is obtained for sending marketing emails and newsletters.
Data Processing: We rely on consent as a legal basis for processing your data where necessary, particularly for the student’s progress tracking and photo proof.

You have the Right to Withdraw Consent at any time. Withdrawal will not affect the lawfulness of processing carried out before the withdrawal. To withdraw consent, please contact us via the provided email address.

First-Party & Third-Party Sharing:

Internal Sharing (First-Party): Your data is accessible only to authorized personnel within Auriga ThriveX, including the founder, co-founders, coordinators, master trainers, and relevant operational departments (e.g., IT, Marketing, Mentorship Team). Access is strictly controlled based on the principle of least privilege.

External Sharing (Third-Party):

As a core commitment, Auriga ThriveX does not sell, rent, or trade your Personal Data to external third parties for marketing or commercial purposes.

We only share data with essential third-party service providers who assist us in operating our business under strict data processing agreements:

Hosting Providers: For storing data securely.
Payment Gateways (e.g., Stripe, Razorpay): To process transactions securely.
Analytics Tools (e.g., Google Analytics): To analyze website and app performance (data is often anonymized before sharing).
Legal Authorities: Data will be shared if required by law, court order, or government request (see Section Y).

Third-Party Policy Disclaimer: The external service providers we use (like payment gateways) have their own privacy policies governing their use of your data. We encourage you to review them.

GDPR / Legal Bases for Processing:

We process your Personal Data only when we have a lawful basis to do so:

Consent: You have given clear consent for us to process your Personal Data for a specific purpose (e.g., marketing communication, use of student photo proof).
Contractual Necessity: The processing is necessary for the performance of the 40-week mentoring program contract and service delivery.
Legal Obligation: The processing is necessary for us to comply with the law (e.g., tax or regulatory requirements).
Legitimate Interests: The processing is necessary for our legitimate interests (or those of a third party), such as security, service improvement, and fraud prevention, provided these interests do not override your rights.

How Data Is Used:

Personalization: To tailor the mentoring program, including feedback and daily micro tasks, to the student’s individual potential and needs.
Communication: To send essential service updates, program information, and, based on your consent, promotional materials regarding our other services (Counselling, Teachers Training).
Security & Safety: To monitor the platform for abuse, illegal activity, and unauthorized access, ensuring the integrity of the program.
Improvement: To conduct internal data analysis (using aggregated data) to improve program efficacy, functionality, and performance.

Information Security:

We implement technical and organizational security measures to protect your Personal Data against unauthorized access, alteration, disclosure, or destruction.

Technical Measures: Data is transferred using secure encryption protocols (e.g., SSL/HTTPS). We employ firewalls, strict access controls, and regular vulnerability scans on our infrastructure.
Organizational Measures: Access to Personal Data is limited to employees on a need-to-know basis. Employees receive mandatory data security and privacy training.
Data Minimization: We only collect and retain data that is necessary for the stated purpose. Data is pseudonymized or anonymized where possible.

Jurisdiction & Data Transfer:

Data Hosting: Your Personal Data is primarily stored and processed on servers located in India or within data centers that comply with Indian data protection laws.
Applicable Law: This Privacy Policy is governed by the laws of India, specifically the jurisdiction of Kerala.
Cross-Border Transfers: If data must be transferred internationally (e.g., by a global service provider), we ensure appropriate safeguards are in place, such as executing Standard Contractual Clauses (SCCs) or relying on the recipient’s adequacy status.

Kids / Minor Privacy:

The Auriga ThriveX program is specifically designed for children’s development, including young students.

Age Restriction: We require that the account for the student is created and managed by a parent or legal guardian who is at least 18 years old.
Parental Consent: We require verifiable parental consent for the collection and processing of a child’s data, including progress tracking and use of photo proof in the app.
If we learn that we have collected information from a child without verifiable parental consent, we will take steps to delete that information promptly.

Legal Rights of Users:

As a user of Auriga ThriveX, you have the following rights regarding your Personal Data:

Right to Access: To request copies of your Personal Data held by us.
Right to Rectification: To request correction of any inaccurate or incomplete data we hold about you.
Right to Erasure (“Right to be forgotten”): To request that we delete your Personal Data when it is no longer necessary for the purposes for which it was collected, and provided there is no overriding legal reason for us to retain it.
Right to Restrict Processing: To request the limiting of how we use your data.
Right to Data Portability: To receive your Personal Data in a structured, commonly used, and machine-readable format.
Right to Object: To object to the processing of your Personal Data in certain circumstances.
Right to Withdraw Consent: To withdraw your consent at any time (see Section E).

Marketing & Communication:

Opt-In: We use your Personal Data to send updates and promotional materials about our services, such as Teachers Training, Parents Training, and Counselling, only where you have provided explicit opt-in consent (e.g., for our email newsletter).
Opt-Out: You can exercise your opt-out right at any time by clicking the “unsubscribe” link in any marketing email or by contacting us directly.
Push Notifications: You can disable push notifications on your device settings at any time.

Non-Personal / Aggregate Data:

We collect and use Non-Personal Data (NPD), which is data that cannot identify you, such as aggregated statistical data related to user traffic, usage patterns, and the overall effectiveness of our habit-tracking system.

This anonymized data may be used for research, reporting, and improving our program design.
NPD is not subject to the restrictions in this policy but is treated with the same commitment to integrity.

Online Tracking & Cookies:

We use cookies and similar tracking technologies (pixels, web beacons) on our website and application to enhance your experience and analyze usage.

Cookie Types: We use necessary cookies (essential for website function), analytics cookies (to track performance), and preference cookies (to remember your settings).
User Management: You have the ability to manage or disable cookies through your browser settings. You may also encounter a cookie consent banner on our website providing options to accept or decline non-essential tracking.

Policy Updates:

We reserve the right to modify this Privacy Policy at any time.
Changes will be communicated via a prominent notice on our website and/or mobile application, or via email to registered users.
The updated policy will take effect immediately upon posting, and the “Last Updated” date at the beginning of the policy will reflect the change.

Questions & Contact Information:

If you have any questions about this Privacy Policy or our data practices, or if you wish to file a complaint, please contact us:

Dedicated Privacy Contact Email: aurigapvtltd@gmail.com (Please use the subject line: “Privacy Policy Question/Complaint”).
Complaint Mechanism: We will investigate and attempt to resolve any complaints regarding the use or disclosure of your Personal Data in accordance with this Policy.

Retention Period:

Retention Criteria: We retain Personal Data only for as long as necessary to fulfill the purposes for which it was collected, including for the duration of the 40-week program, to comply with legal obligations (e.g., tax and accounting), and for resolving disputes.
Deletion Procedures: Data that is no longer necessary is either securely deleted or completely anonymized so that it can no longer be associated with you.

Sensitive Information Handling:

We may collect limited Sensitive Personal Data as it relates to a student’s educational or psychological profile (e.g., learning difficulties or emotional challenges reported during counselling or mentoring sessions).

Special Safeguards: This data is collected and processed with the highest degree of security, strict confidentiality, and only with your explicit, verifiable consent. Access to this information is extremely restricted.

Third-Party Links:

Our website or app may contain links to external third-party websites or services.

Disclaimer: This Privacy Policy applies only to Auriga ThriveX. We have no control over and are not responsible for the content or privacy practices of these external sites. We encourage you to review their privacy policies before submitting any information.

User Control & Choices:

We provide tools for you to manage your data:

Account Deletion: You can request the deletion of your account and all associated data (subject to legal retention requirements).
Preferences Management: You can manage your communication and notification preferences within the mobile application.
Data Download/Export: You can request a copy of your Personal Data in a portable format (Right to Data Portability).

Verification Procedures:

To protect your data and the privacy of the student, we will take reasonable steps to verify your identity before granting access to your Personal Data, fulfilling an erasure request, or transferring data. This may involve confirming information associated with your account.

Website Analytics:

We use essential analytics tools, such as Google Analytics, to track general traffic, measure the performance of our site, and improve user flow.

Data collected by these tools is primarily anonymized and aggregated before analysis to ensure that it cannot be used to directly identify any individual user.

Your Responsibilities as a User:

Confidentiality: You are responsible for maintaining the confidentiality of your account credentials (usernames and passwords).
Responsible Usage: You must ensure that the data you provide to us, particularly in relation to the habit tracker photo proof system, is accurate, appropriate, and does not infringe upon the rights of others.

Yielding to Law Enforcement:

We will disclose your Personal Data without your prior consent only when we have a good-faith belief that such action is necessary to:

Comply with a legal obligation, a court order, or other governmental requests (e.g., search warrants or subpoenas).
Protect and defend the rights or property of Auriga ThriveX or our users.
Act in urgent circumstances to protect the personal safety of users of the service or the public.

Zero Discrimination & Fair Practice:

No Discrimination: We commit to processing Personal Data fairly, transparently, and lawfully. We will not discriminate against any user for exercising their privacy rights (e.g., the Right to Erasure or Right to Object).
Fair Practice: We maintain a strict commitment to ensuring that the Processing of all data, especially data related to our young students, is done with integrity and in the best interest of the child’s development.