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AQADEMIQ PRIVACY POLICY

Effective Date: 19/07/2026.
Last Updated: 16/08/2026

1. INTRODUCTION

1.
This Privacy Policy ("Policy") is issued by R13 Labs India Private Limited ("Aqademiq", "We", "Our", or "Us"), the developer and operator of the Aqademiq application. This Policy explains how Aqademiq collects, Processes (as defined below), stores, uses and shares Personal Data (as defined below) in connection with the Platform (as defined below) and Services (as defined below). The Policy has been prepared in accordance with Applicable Laws (as defined below)
2.
This Policy applies to the collection, use, Processing, storage, and disclosure of digital Personal Data by Aqademiq when a Data Principal (as defined below) accesses or uses the Aqademiq website, web application and mobile application (including the iOS and Android applications), and any related interfaces through which the Services are made available on the Digital Platform (as defined below).
3.
This Policy applies to all individuals located in India who access or interact with the Digital Platform in the capacity of a User (as defined below) including individuals accessing the Digital Platform in Guest Mode (as defined below) prior to registration. Aqademiq currently offers its Services to individual Users only, and does not, as of the date of this Policy, offer institutional, enterprise, or corporate accounts. Aqademiq may introduce the Platform in additional jurisdictions after assessing the legal and regulatory requirements applicable in those jurisdictions.
4.
By accessing or using the Digital Platform, You acknowledge that You have been provided with and have had an opportunity to review this Policy. Where Aqademiq relies on Consent (as defined below) for any Processing activity, such Consent will be requested through a clear affirmative action and may be withdrawn in accordance with this Policy.
5.
This Policy should be read together with Aqademiq's Terms of Service and any other notices or policies that may apply to your use of the Platform and Services.

2. DEFINITIONS

For the purposes of this Policy, the terms below shall have the meanings assigned to them in this Section 2. Any capitalised term not expressly defined in this Policy shall be interpreted in accordance with the Applicable Laws.

1.
“Applicable Laws” mean the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and the Digital Personal Data Protection Rules, 2025 (“DPDP Rules”), as and when the relevant provisions become applicable, and other applicable data protection laws in India.
2.
"Ada" means the AI-enabled conversational and academic-support feature integrated into the Digital Platform that assists Users with schedule management, task planning, study-related queries and such other functions as may be described on the Digital Platform.
3.
"Child/Children" means an individual who has not completed the age of eighteen (18) years, in accordance with Applicable Laws.
4.
"Consent" means a freely given, specific, informed, unconditional, and unambiguous indication of a Data Principal's agreement to the Processing of their Personal Data, communicated through a clear affirmative action, including ticking a checkbox, clicking an "I Agree" button and capable of being withdrawn with ease comparable to the ease with which it was given in accordance with Applicable Laws.
5.
"Data Fiduciary" means Aqademiq, which determines the purpose and means of Processing Personal Data, collected through the Digital Platform, in accordance with this Policy and Applicable Laws.
6.
"Data Principal" means the User to whom the Personal Data relates, including any individual who downloads, accesses, registers on, or otherwise interacts with the Platform, and, where applicable, the parent or lawful guardian of a Child.
7.
"Data Processor" means any person or entity that Processes Personal Data on behalf of Aqademiq, including providers of cloud hosting, authentication, artificial intelligence infrastructure, communications, customer support, security and related technical services.
8.
"Digital Platform" means the technology-enabled platform operated by Aqademiq, comprising the Aqademiq website at www.Aqademiq.com and web application accessible at www.aqademiq.app together with the mobile application (including the iOS and android applications) and any related interfaces through which the Services are made available to the Users.
9.
"Grievance Officer" means the individual designated by Aqademiq in accordance with Applicable Laws to receive, acknowledge, and address grievances raised by Data Principals relating to the Processing of their Personal Data.
10.
"Guest Mode" means the limited, unregistered mode in which a User may explore certain features of the Digital Platform prior to creating an account or providing Personal Data.
11.
"Personal Data" means any data about an User who is identifiable by or in relation to such data, and includes, in relation to the Digital Platform, information such as name, email address, age, and any other data described in Section 3.
12.
"Processing" or "Process" means any operation or set of operations performed on Personal Data, whether wholly or partly by automated means, including the collection, recording, organisation, storage, adaptation, retrieval, use, alignment, combination, sharing, transmission, disclosure, restriction, erasure, or destruction of Personal Data.
13.
"Services" means the academic planning, schedule management, task tracking, and grade-tracking functionality offered through the Digital Platform, together with the AI-enabled features provided through Ada, which operate as supplementary tools to assist Users and do not independently determine any User's academic outcomes, rights, or eligibility.
14.
"User/ You/Your" means any individual who registers for or otherwise accesses or interacts with the Digital Platform or Services, including Users who access the Digital Platform in Guest Mode.

3. CATEGORIES OF PERSONAL DATA COLLECTED

3.1.
General Notice

Aqademiq collects and Processes Personal Data strictly in accordance with Applicable Laws and only to the extent necessary for the specific, explicit, and lawful purposes set out in this Policy.

3.2.
Personal Data collected upon Registration

When a User creates an account on the Digital Platform, Aqademiq collects the following categories of Personal Data:

(a)
Identity information, including the User's name;
(b)
Contact information, including the User's email address;
(c)
Demographic information, including the User's age;
(d)
Level of education and subject
3.3.
Personal Data collected during Guest Mode

Where a User accesses the Platform through Guest Mode, Aqademiq does not collect or store the categories of Personal Data described in Section 3.2 above. Guest Mode enables a User to explore certain features of the Digital Platform prior to registration and prior to providing Consent, in order to support informed and voluntary decision-making before Personal Data is collected.

3.4.
Academic and Usage Data provided by the User

In the course of using the Services, Users may input or upload information relating to their academic activities, including course names, assignment details, deadlines, schedules, and grades, for the purpose of using the Digital Platform's organisation and tracking features. Aqademiq Processes this information to provide the Services selected by the User, personalise scheduling and planning features, maintain Platform functionality and security, and undertake such other purposes as are specifically disclosed in this Policy.

3.5.
Data collected through Ada and AI-enabled features

Where a User interacts with Ada, Aqademiq Processes the prompts, queries, and inputs submitted by the User to Ada, together with the corresponding AI-generated responses ("AI Interaction Data"). AI Interaction Data may include references to a User's schedule, tasks, or academic information to the extent voluntarily shared by the User in the course of the conversation. Aqademiq may also Process usage and behavioural information generated through a User's interaction with the Platform's adaptive scheduling and planning features such as task completion patterns and study session activity, to the extent this is used to operate and personalise such features for that User ("Usage Data"). Further details of how AI Interaction Data is Processed, including its disclosure to Aqademiq's AI infrastructure provider, are set out in Sections 5.2 and 7.3 of this Policy.

3.6.
Payment information

The Platform is currently available without charge. If Aqademiq introduces any paid features in the future, payments may be processed through third-party payment service providers. Aqademiq will not ordinarily collect or store complete payment card or banking details, but may receive limited transaction information for payment confirmation, account administration, and legal compliance.

3.7.
Technical and Security Information

Aqademiq may automatically Process limited technical and security information when a User accesses or uses the Digital Platform, including IP address, device type, operating system, application version, login timestamps, authentication records, session identifiers, crash or diagnostic information, security events and usage logs. Such information is Processed to operate, secure and troubleshoot the Platform, detect and prevent unauthorised access, fraud and misuse, and maintain service performance.

4. PURPOSES OF PROCESSING PERSONAL DATA

Aqademiq Processes Personal Data in a lawful, fair, and transparent manner, solely for the specific and legitimate purposes set out below, and only to the extent necessary for such purposes.

1.
Processing of Account and Authentication Data

To create and authenticate a User's account, including through a third party authentication provider and to enable secure access to the Platform and to respond to a User's queries, feedback, or grievances, and to send Service-related communications, including onboarding information and notices required under this Policy.

2.
Processing of Academic and Institutional Data

To provide the Platform's core academic organisation features, including schedule management, task and assignment tracking, and grade tracking, based on the information a User chooses to input.

3.
Processing of AI Interaction Data and Usage Data
(a)
to generate conversational responses and study-planning suggestions through Ada-,based on a User's prompts and, where the User shares it, their academic information;
(b)
to personalise adaptive scheduling suggestions based on a User's own inputs and usage of the Platform; AI-generated outputs are informational and advisory in nature and do not independently determine a User's academic outcomes, eligibility, or any other legally significant decision concerning the User.
4.
Processing of Account and Usage Data for Platform Security

To maintain the security of the Platform, including through access controls and authentication mechanisms, to detect and prevent unauthorised access, and to maintain the technical functionality of the Digital Platform.

5.
Legal basis for Processing

Aqademiq Processes Personal Data on one or more of the following grounds, as permitted under Applicable Laws:

(a)
Consent: Personal Data described in Section 3.2 is Processed on the basis of the Consent obtained from the Data Principal through the onboarding pop-up described in Section 8, before or at the time of registration;
(b)
Performance of the Services: Processing that is necessary to provide the features of the Platform that a User has chosen to use; and
(c)
Legal obligation: Processing that is necessary to comply with a statutory or regulatory requirement, or a lawful direction of a court or governmental authority.

5. DATA SHARING AND DISCLOSURE

Aqademiq does not sell, rent, or trade Personal Data to any third party for monetary or other consideration. Save as expressly set out in this Section 5, Aqademiq does not disclose Personal Data to any third party, and any disclosure made pursuant to this Section 5 shall be limited to the minimum extent necessary to give effect to the relevant purpose.

1.
No general third-party sharing

Aqademiq does not share Personal Data with third parties for marketing, advertising, or analytics purposes. Aqademiq does not currently use analytics, advertising, or tracking cookies, as described in Section 12.

2.
Disclosure to AI infrastructure providers
(a)
Ada is powered by AI infrastructure provided by one or more third-party providers of large language models (each an "AI Service Provider"). When a User interacts with Ada, only the User's prompts are transmitted to the relevant AI Service Provider to generate a response, and any academic information voluntarily included by the User in such prompts is transmitted to the AI Service Provider’s API to generate the corresponding response. Aqademiq does not transmit a User's account or identity information (such as name or email) to any AI Service Provider.
(b)
Aqademiq engages each AI Service Provider under a valid contract incorporating the AI Service Provider's data-processing terms, and shall ensure that any current or future AI Service Provider is bound by appropriate contractual safeguards consistent with Applicable Laws.
(c)
Some AI Service Providers, or their infrastructure, may be located outside India, and AI Interaction Data may therefore be Processed outside India. Aqademiq will take reasonable steps to ensure that any such Processing is subject to appropriate contractual safeguards and is carried out consistently with Applicable Laws, including any conditions or restrictions on cross-border transfer under the Applicable Laws
(d)
Users are advised not to enter sensitive personal data, confidential information, or the personal data of third parties into Ada.
3.
Legal and regulatory disclosure

Aqademiq may disclose Personal Data, where necessary, to comply with Applicable Laws or a lawful order or direction of a court, law enforcement agency, or governmental authority; to investigate or prevent fraud or security incidents; or to establish, exercise, or defend legal rights. Any such disclosure shall be limited to what is required under Applicable Laws.

4.
International transfers

Personal Data described in Section 3.2 is currently hosted on cloud infrastructure located in India, as described in Section 6.3. Where Personal Data is Processed outside India, including I Interaction Data Processed by AI Service Provider, such Processing shall be undertaken in accordance with Applicable Laws and subject to reasonable safeguards.

6. DATA RETENTION AND STORAGE

6.1.
Retention period

Aqademiq retains Personal Data only for as long as reasonably necessary to fulfil the purposes described in Section 4, including the provision of the Services, compliance with Applicable Laws, and protection of Aqademiq's legal rights. Personal Data is not retained for longer than reasonably necessary and shall be deleted or anonymised upon fulfilment of the applicable purpose, unless continued retention is required under Applicable Laws.

6.2.
Account deletion

(a)A User may currently delete their account themselves or request deletion of their account and associated Personal Data by contacting Aqademiq through the Grievance Officer identified in Section 11.3. Such requests are presently Processed manually. (b)Aqademiq intends to implement an automated data deletion mechanism, including deletion following prolonged account inactivity or subscription cancellation, following the initial launch of the Digital Platform.

6.3.
Storage location

Personal Data described in Section 3.2 is presently stored on cloud infrastructure located in India. Certain categories of information, including AI Interaction Data, may be Processed outside India by third-party service providers as described in Section 5.4. Any such Processing is carried out in accordance with Applicable Laws, including any restrictions on cross-border transfer . Upon expiry of the applicable retention period, or where Personal Data is no longer required for the purposes for which it was collected, such Personal Data shall be securely deleted or anonymised, subject to any overriding legal or regulatory retention obligation.

7. SECURITY SAFEGUARDS AND REASONABLE SECURITY PRACTICES

7.1.
Aqademiq implements reasonable technical and organisational safeguards designed to protect Personal Data against unauthorised access, disclosure, alteration, loss, or destruction, proportionate to the nature and scope of the Personal Data Processed through the Digital Platform.
7.2.
Access to Personal Data is restricted to personnel who require such access for legitimate operational purposes, subject to authentication controls.
7.3.
Where Personal Data is Processed through Ada or other AI-enabled features, Aqademiq shall implement measures designed to support the responsible and secure operation of such features.
7.4.
In the event of a Personal Data breach, Aqademiq shall take reasonable steps to investigate, contain, and mitigate the impact of such breach. Where required under Applicable Laws, Aqademiq shall notify the relevant regulatory authority and affected Data Principals in accordance with the timelines prescribed under Applicable Laws.
7.5.
Where Aqademiq engages third-party service providers, such providers are required to maintain appropriate security safeguards and to Process Personal Data solely in accordance with Aqademiq's instructions and Applicable Laws.

8. CONSENT MANAGEMENT

1.
At the time of registration, a User is presented with a clear onboarding notice describing the categories of Personal Data collected, the specific purposes of Processing, the services or functionality enabled with such processing, the manner of withdrawing consent together with a hyperlink to this Policy. A User must provide an affirmative indication of Consent before the Personal Data described in Section 3.2 is collected.
2.
A User may explore certain features of the Platform in Guest Mode prior to providing such Consent, as described in Section 3.3, to support informed and voluntary decision-making.
3.
A Data Principal may withdraw Consent previously provided at any time by contacting Grievance Officer identified in Section 11.3. Withdrawal of Consent does not affect the lawfulness of Processing carried out before the withdrawal. Upon withdrawal, Aqademiq shall cease Processing the relevant Personal Data, except to the extent continued Processing is required under Applicable Laws and shall proceed with deletion in accordance with Section 6. Withdrawal of Consent may result in the relevant feature becoming unavailable. For example, withdrawal of Consent for AI Interaction Data may prevent the User from accessing Ada, while withdrawal of Consent necessary to maintain an account may require closure of the account.
4.
Each User, including a User accessing the Digital Platform through Guest Mode, represents and warrants that any Consent, declaration, confirmation, or information provided to Aqademiq in connection with the use of the Digital Platform is true, accurate, complete, and given by the individual lawfully entitled to provide such Consent under Applicable Laws. Aqademiq shall be entitled to rely on such representations and shall not be responsible or liable for any false, inaccurate, misleading, fraudulent, or unauthorised Consent, declaration, or information submitted by any User or Guest Mode User. Where Aqademiq becomes aware that any such Consent or information is invalid or has been falsely provided, Aqademiq reserves the right to suspend or terminate access to the Digital Platform and take such other measures as may be required under Applicable Laws.
5.
The Digital Platform employs a layered consent mechanism at the point of registration. Primary Consent, comprising acceptance of these Terms and the Privacy Policy together with confirmation that the User is above the age of eighteen years, is mandatory and must be affirmatively indicated before the User may proceed with registration. Ada Consent, being consent for enabling AI Interaction with Ada, is sought separately from Primary Consent, is optional, is unchecked by default and shall not condition or restrict the User's ability to proceed with registration irrespective of whether Ada Consent is provided. The onboarding notice for Ada Consent shall disclose that Ada functions by transmitting the User's prompts to a third-party artificial intelligence service located outside India, that the Digital Platform remains fully usable without enabling Ada, and that Ada Consent may be withdrawn at any time through the Settings of the Digital Platform.

9. RIGHTS OF DATA PRINCIPALS

1.
In accordance with Applicable Laws, a Data Principal is entitled to exercise the following rights in relation to their Personal Data, subject to verification of identity:
(a)
the right to obtain confirmation as to whether Personal Data relating to them is being Processed, and to obtain a summary of such Personal Data, the purposes of Processing, and the identity of any Data Processors with whom it has been shared;
(b)
the right to request correction, completion, or updating of Personal Data that is inaccurate or incomplete;
(c)
the right to request erasure of Personal Data that is no longer necessary for the purpose for which it was collected, subject to Section 6;
(d)
the right to withdraw Consent at any time, in accordance with Section 8.3;
(e)
the right to nominate another individual to exercise these rights on the Data Principal's behalf in the event of death or incapacity; and
(f)
the right to grievance redressal in accordance with Section 11.
2.
A Data Principal may exercise the above rights by contacting the Grievance Officer identified in Section 11.3. Aqademiq may take reasonable steps to verify the identity of a Data Principal before acting on such a request.

10. PROCESSING OF CHILDREN'S PERSONAL DATA

1.
The Platform is intended for use by students, who have attained eighteen (18) years of age or older. Aqademiq does not currently offer the Platform to individuals below eighteen (18) years of age.
2.
During onboarding, a User is required to confirm their age. Where a User indicates that they are below eighteen (18) years of age, the User will not be permitted to create an account or use the Platform, and any information provided during onboarding will not be retained beyond what is necessary to give effect to this restriction.
3.
Aqademiq does not knowingly collect or Process the Personal Data of a Child. Aqademiq does not undertake behavioural monitoring or targeted advertising directed at Children, or any Processing likely to cause a detrimental effect on the well-being of a Child. If Aqademiq becomes aware that a Child has registered or that a Child's Personal Data has been collected, Aqademiq shall take reasonable steps to delete such Personal Data and suspend the relevant account, in accordance with Applicable Laws.
4.
Aqademiq may, in future, enable access for Users below eighteen (18) years of age, subject to obtaining verifiable Consent of a parent or lawful guardian in accordance with Applicable Laws. Any such feature will be introduced only with appropriate consent and verification mechanisms, and this Policy will be updated before any such Processing begins.
5.
Each User represents that the age information they provide is true. Aqademiq relies on these representations and is not responsible for any false or unauthorised age information (see clause 8.4). Where Aqademiq finds that age has been falsely declared, it may suspend or terminate access and delete the relevant Personal Data.

11. GRIEVANCE REDRESSAL MECHANISM

1.
Aqademiq has established a grievance redressal mechanism to address concerns, complaints, or requests relating to the Processing of Personal Data, in accordance with Applicable Laws.
2.
Any grievance, request, or query relating to the processing of Personal Data, including a request to exercise the rights described in Section 9, may be submitted to the Grievance Officer identified below.
3.
Grievance Officer

Aqademiq has designated a Grievance Officer responsible for addressing grievances raised by Data Principals. Contact details are as follows:

(a)
Name: Mohammed Aswath M
(c)
Contact Number: +918248547453
4.
Upon receipt of a grievance, Aqademiq shall take reasonable steps to acknowledge and address it in a timely manner in accordance with Applicable Laws.
5.
Where a Data Principal is not satisfied with the resolution provided by Aqademiq, the Data Principal may approach the Data Protection Board of India or any other competent authority in accordance with Applicable Laws.

12. COOKIES AND TRACKING TECHNOLOGIES

1.
The Digital Platform uses authentication tokens and session-management mechanisms that are strictly necessary for a User to log in and maintain an active session on the Digital Platform.
2.
As of the date of this Policy, Aqademiq does not use analytics, advertising, or third-party tracking cookies. Should this change, this Policy shall be updated in accordance with Section 13 prior to the deployment of any such technology.

13. POLICY UPDATES AND AMENDMENTS

1.
Aqademiq reserves the right to modify or update this Policy from time to time to reflect changes in Applicable Laws, the Services offered through the Digital Platform, or Aqademiq's data processing practices.
2.
Aqademiq shall notify all Users of any material changes to this Policy by publishing a prominent notice on the Digital Platform. Such notice shall specify the effective date of the revised Policy. Where required under Applicable Laws, Aqademiq shall obtain fresh Consent before Processing Personal Data in accordance with the updated Policy.
3.
Users are encouraged to periodically review this Policy to remain informed of how their Personal Data is collected, used, and protected.

14. GOVERNING LAW AND JURISDICTION

This Policy shall be governed by and construed in accordance with the laws of India. Any dispute arising out of or in connection with this Policy, including its interpretation, validity, or enforcement, shall be subject to the exclusive jurisdiction of the competent courts in India.