Privacy Policy

The Privacy Policy of the Academy is aligned with India's Digital Personal Data Protection Act, 2023 (DPDP Act) and the DPDP Rules, 2025, including consent, purpose limitation, data minimization, security safeguards, children's data, withdrawal of consent, grievance handling, processors, retention and breach management. The Rules were notified on 13 November 2025 and have phased commencement provisions, so the policy should be maintained as a living compliance document.

One important point: no privacy policy by itself can make data "fool-proof." Protection also requires technical controls, access restrictions, contracts with vendors, employee confidentiality obligations, audit logs, incident response and proper deletion procedures.

The policy below is therefore written as a combined privacy, confidentiality and data-protection framework.

ABHAYAM SKILL TRAINING ACADEMY LLP

PRIVACY & DATA PROTECTION POLICY

12, Sumeru, GF-1, Sir M N Krishna Rao Road, Basavanagudi

Bengaluru. KA 560004. Bharat.
Website: www.abhayamskills.com

Effective Date: 26 September 2026
Version: 1.0

Last Updated: 26 September 2026

1. PURPOSE OF THIS POLICY

ABHAYAM SKILL TRAINING ACADEMY LLP ("ABHAYAM", "we", "us", "our or "the Company") recognizes that personal information entrusted to us by students, parents, guardians, employees, trainers, faculty members, professionals, companies, academic institutions, applicants, visitors, vendors, partners and other stakeholders is confidential and must be protected. This Privacy & Data Protection Policy ("Policy") establishes the principles, responsibilities, safeguards and procedures governing the collection, use, storage, processing, sharing, retention, transfer and deletion of personal data by ABHAYAM.

The objective of this Policy is to ensure that personal data:

is collected lawfully and transparently;
is collected only for specified and legitimate purposes;
is limited to information reasonably necessary for those purposes;
is accessed only by authorized persons;
is not misused, sold, disclosed or exploited without lawful basis;
is protected against unauthorized access, alteration, loss, disclosure or destruction;
is retained only for as long as reasonably necessary;
is securely deleted or anonymized when no longer required;
is handled in accordance with applicable Indian data-protection and other applicable laws; and
remains subject to appropriate contractual, organizational and technical safeguards when handled by third parties.

2. SCOPE

This Policy applies to personal data collected or processed by ABHAYAM through or in connection with:

the ABHAYAM website and webpages;
online registration and admission forms;
student enrolment forms;
training and certification programs;
internships and placement activities;
counselling and student-support activities;
examinations, assessments and quizzes;
workshops, seminars and events;
corporate training programs;
academic partnerships;
institutional collaborations;
consultancy and professional services;
surveys and feedback forms;
telephone, WhatsApp, email and other communications;
learning-management systems;
online classes and virtual learning platforms;
applications and software used by ABHAYAM;
social-media interactions;
physical forms and records;
CCTV and security systems, where applicable;
recruitment and employment processes;
vendor and service-provider relationships; and
any other legitimate business or educational activity conducted by ABHAYAM.

This Policy applies irrespective of whether the information is collected electronically, digitally, verbally, photographically, audio visually or in physical form, to the extent applicable under law.

3. WHO IS RESPONSIBLE FOR THE DATA?

For personal data for which ABHAYAM determines the purpose and means of processing, ABHAYAM acts as the relevant Data Fiduciary or equivalent responsible entity under applicable law. ABHAYAM shall remain responsible for establishing appropriate controls over personal data processed on its behalf by employees, trainers, consultants, contractors, technology providers, cloud-service providers, placement partners, academic partners and other authorized Data Processors or service providers. Where another organization independently determines the purpose and means of processing, that organization may have its own privacy obligations and policies.

4. PERSONAL DATA WE MAY COLLECT

Depending upon the nature of the relationship and service involved, ABHAYAM may collect only such information as is reasonably necessary for a legitimate and specified purpose. This may include:

4.1 Identity Information

full name;
date of birth;
age;
photograph;
signature;
gender where necessary;
government-issued identification information where legally required;
student identification number;
employee identification information.

4.2 Contact Information

residential address;
email address;
telephone/mobile number;
emergency contact information;
parent/guardian contact information;
professional contact information.

4.3 Academic Information

school/college/university;
course and branch;
year/semester;
academic qualifications;
marks and grades;
examination information;
certificates;
attendance;
assessment results;
training history;
internship information;
placement-related information.

4.4 Professional Information

For working professionals, trainers, consultants and corporate participants, this may include:

employer;
designation;
professional qualifications;
experience;
professional certifications;
areas of expertise;
professional profile;
training requirements.

4.5 Transaction and Payment Information

Where required for legitimate transactions:

billing information;
transaction reference;
payment status;
invoice information;
fee/payment history.

ABHAYAM shall not intentionally collect or retain complete card numbers, CVV numbers, PINs, passwords or other authentication secrets unless a specific lawful and technically secure process expressly requires otherwise. Payment processing may be performed by authorized third-party payment service providers subject to their applicable terms and privacy practices.

4.6 Communication Information

ABHAYAM may retain records of:

emails;
enquiries;
support requests;
feedback;
complaints;
official correspondence;
consent records;
communications concerning enrolment, training, examination, placement or services.

4.7 Digital and Technical Information

Where technically necessary, ABHAYAM or its authorized technology providers may collect:

IP address;
browser type;
device information;
operating system;
login information;
access times;
system logs;
website interaction information;
cookies and similar technologies.

4.8 Photographs, Video and Audio

ABHAYAM may collect photographs, video recordings or audio recordings for legitimate purposes such as:

training delivery;
examination or assessment;
attendance;
security;
event documentation;
internal records;
quality assurance;
authorized educational or promotional activities.

Promotional or public use of identifiable photographs, testimonials, videos or recordings shall be subject to an appropriate lawful basis and, where required, separate consent.

5. INFORMATION WE DO NOT WANT YOU TO PROVIDE

Unless specifically requested through an authorized ABHAYAM process, individuals must not provide:

passwords;
ATM/debit/credit-card PINs;
CVV numbers;
banking login credentials;
OTPs;
authentication tokens;
private encryption keys;
confidential access credentials;
another person's personal information without lawful authority.

ABHAYAM personnel shall never request passwords, OTPs, PINs or similar authentication secrets through ordinary email, telephone, WhatsApp or social-media communication. If anyone claiming to represent ABHAYAM requests such information, the recipient should not provide it and should report the incident immediately to ABHAYAM.

6. PURPOSES FOR WHICH PERSONAL DATA MAY BE USED

ABHAYAM may process personal data only for specified, lawful and legitimate purposes, including where applicable:

student registration and enrolment;
admission and counselling;
delivery of training and educational services;
creation and administration of student accounts;
attendance management;
examinations and assessments;
issuance and verification of certificates;
internships;
placement and career-support services;
communication concerning programs and services;
customer/student support;
fee administration and accounting;
compliance with legal and regulatory obligations;
prevention, detection and investigation of fraud or misuse;
information-security and cybersecurity;
quality assurance;
academic and training administration;
corporate training administration;
institutional and industry collaboration;
research and analytics where lawfully permitted;
improving educational and training services;
maintaining records;
resolving disputes and complaints;
enforcing agreements and protecting ABHAYAM's legal rights;
recruitment and employment administration;
business administration;
website and platform security;
event administration; and
other purposes specifically communicated to the individual at or before collection.

ABHAYAM shall not use personal data for an unrelated purpose merely because the information is already available to it.

7. DATA MINIMISATION

ABHAYAM follows the principle of data minimization. We shall endeavor to collect only information that is reasonably necessary for the relevant purpose. Employees, trainers, consultants, volunteers and third-party service providers are prohibited from collecting additional personal information merely because it may be convenient or potentially useful in the future. Any request for additional categories of personal data should be reviewed and authorized by the designated responsible person within ABHAYAM.

8. LAWFUL PROCESSING AND CONSENT

Where consent is the applicable legal basis for processing, ABHAYAM shall seek consent in a manner that is:

free;
specific;
informed;
unambiguous;
capable of being demonstrated;
linked to a specified purpose; and
capable of being withdrawn.

Consent shall not be obtained through deceptive, coercive or unnecessarily complicated mechanisms. Where applicable, ABHAYAM shall provide appropriate notice identifying the personal data proposed to be processed and the purpose for processing. Where processing is based on consent, withdrawal of consent shall be facilitated through a process reasonably comparable to the process through which consent was provided, subject to lawful consequences and exceptions.

9. CHILDREN AND STUDENT DATA

ABHAYAM recognizes that student information requires heightened protection, particularly where students are children or minors. Where applicable, ABHAYAM shall obtain and verify parental or lawful guardian consent before processing a child's personal data in circumstances where such consent is legally required. ABHAYAM shall implement appropriate safeguards relating to children's data and shall not knowingly undertake processing that is unlawful or harmful to the well-being of children. ABHAYAM shall not knowingly use children's personal data for behavioral tracking, targeted advertising or similar activities where prohibited by applicable law. Parents or lawful guardians may contact ABHAYAM regarding the personal data of a child for whom they have lawful authority.

10. ACCESS CONTROL — "NEED TO KNOW" PRINCIPLE

Personal data shall be accessible only to authorized persons who require access for legitimate business, educational, operational, legal or administrative purposes.

ABHAYAM shall endeavor to implement:

role-based access;
unique user accounts;
strong authentication;
password controls;
access approvals;
access revocation when personnel leave;
periodic review of user privileges;
logging and monitoring where appropriate;
restricted access to confidential records.

Employees and contractors shall not access personal data merely because their technical role permits such access. Access shall be based on need-to-know and least-privilege principles.

11. STRICT PROHIBITION ON PERSONAL DATA MISUSE

No employee, trainer, consultant, intern, volunteer, student representative, contractor, partner or other person acting for or on behalf of ABHAYAM may:

sell personal data;
rent personal data;
trade personal data;
disclose personal data for personal benefit;
copy student databases for personal use;
export contact lists to personal devices without authorization;
upload confidential information to unauthorized cloud storage;
share student/parent/company information through unauthorized WhatsApp groups;
use personal information for personal marketing;
contact students or parents for unauthorized commercial purposes;
use personal information to solicit business outside authorized ABHAYAM activities;
disclose confidential information to competitors;
download databases without authorization;
take photographs/screenshots of confidential records without a legitimate purpose;
use personal information for harassment, intimidation or discrimination;
use ABHAYAM data to create personal mailing lists;
use personal data after termination of employment or engagement; or
permit another person to access their account or credentials.

Any such conduct may result in disciplinary action, termination of employment / engagement, contractual remedies, legal action and / or reporting to the appropriate authority, depending upon the circumstances.

12. EMPLOYEE AND STAFF CONFIDENTIALITY

Every employee, trainer, consultant, intern, contractor and authorized representative who handles personal data shall be bound by confidentiality obligations. Such obligations shall continue, where applicable, after:

resignation;
termination;
completion of contract;
completion of internship;
cessation of consultancy;
cessation of partnership; or
any other end of engagement.

A person leaving ABHAYAM shall immediately return or securely delete personal data and company information in their possession, subject to lawful retention requirements.

13. THIRD-PARTY SERVICE PROVIDERS

ABHAYAM may engage authorized third parties for functions such as:

cloud hosting;
website hosting;
learning-management systems;
payment processing;
accounting;
communication;
email;
SMS;
WhatsApp/business communication;
examinations;
certificates;
recruitment and placement;
analytics;
IT support;
cybersecurity;
document management;
professional services.

Where a third party processes personal data on behalf of ABHAYAM, ABHAYAM shall endeavor to ensure that appropriate contractual and technical safeguards are in place.

Such third parties shall receive only the information reasonably required for the relevant service. Third parties shall not be permitted to use ABHAYAM's personal data for their own unrelated purposes unless there is an independent lawful basis and appropriate disclosure.

14. ACADEMIC AND CORPORATE PARTNERS

Where ABHAYAM works with colleges, universities, schools, companies, government bodies, training partners or other institutions, personal data may be shared where reasonably necessary for the agreed educational, training, internship, placement, administrative, contractual or legal purpose. Where appropriate, the parties shall establish contractual provisions governing:

permitted use;
confidentiality;
access;
security;
retention;
deletion;
breach notification;
onward disclosure;
responsibilities of each party.

ABHAYAM shall not permit a partner to use personal data for unrelated purposes merely because the data was originally shared for an educational or professional activity.

15. DATA PROCESSORS

Where ABHAYAM appoints a Data Processor or equivalent service provider, ABHAYAM shall endeavor to ensure that:

processing is limited to authorized purposes;
confidentiality obligations apply;
reasonable security measures are implemented;
access is appropriately restricted;
subcontracting is controlled where appropriate;
security incidents are reported promptly;
data is returned, deleted or securely disposed of when no longer required; and
the processor provides reasonable assistance in responding to data-subject requests and compliance obligations.

16. DATA SECURITY

ABHAYAM shall implement reasonable technical and organizational safeguards appropriate to the nature and risk of the personal data processed. Depending upon the circumstances, safeguards may include:

encryption in transit;
encryption at rest where appropriate;
secure passwords;
multi-factor authentication;
access controls;
firewalls;
endpoint protection;
malware protection;
secure backups;
vulnerability management;
software updates;
secure configuration;
logging and monitoring;
restricted administrative privileges;
employee awareness and training;
confidentiality agreements;
physical security;
secure disposal;
incident-response procedures.

No security system can guarantee absolute security. However, ABHAYAM shall continuously work to reduce the likelihood and impact of unauthorized access, disclosure, alteration, loss or destruction.

17. DATA BREACH AND SECURITY INCIDENTS

A Personal Data Breach may include unauthorized access, disclosure, alteration, loss, destruction, theft or other compromise of personal data. Any employee, student, trainer, contractor, partner or other person who becomes aware of a suspected breach involving ABHAYAM personal data must report it immediately to the designated privacy/security contact. Personnel must not:

conceal the incident;
delete evidence;
investigate independently beyond their authority;
contact affected persons without authorization; or
make public statements concerning the incident.

ABHAYAM shall maintain an incident-response process covering, as applicable:

identification;
containment;
investigation;
risk assessment;
remediation;
documentation;
notification to affected individuals and/or authorities where legally required;
recovery; and
preventive corrective action.

18. DATA ACCURACY

ABHAYAM shall take reasonable steps to maintain personal data that is accurate and appropriate for the purpose for which it is processed. Individuals should notify ABHAYAM when important personal information changes, particularly:

name;
contact details;
educational information;
parent/guardian details;
professional information; or
other information relevant to an active service.

19. DATA RETENTION

ABHAYAM shall not retain personal data indefinitely merely because it has been collected. Personal data shall be retained only for as long as reasonably necessary for:

the purpose for which it was collected;
provision of the relevant service;
legitimate business records;
contractual obligations;
accounting requirements;
legal obligations;
dispute resolution;
fraud prevention;
audit requirements;
regulatory requirements; or
other lawful purposes.

When personal data is no longer required, ABHAYAM shall take appropriate steps to securely delete, destroy or anonymize it, subject to applicable legal or legitimate retention requirements. Different categories of information may therefore have different retention periods.

20. SECURE DELETION AND DISPOSAL

When data is no longer required, ABHAYAM shall use appropriate disposal methods, which may include:

secure digital deletion;
deletion from active systems;
destruction of physical records;
secure shredding;
removal from portable storage;
anonymization; or
other appropriate technical methods.

Simply moving information to a recycle bin or ordinary archive shall not necessarily be considered secure deletion. Backups may retain information for a limited period where technically necessary, after which the information shall be removed through the normal backup lifecycle.

21. PERSONAL DEVICES

Employees, trainers, consultants and contractors must not store ABHAYAM personal data on personal devices unless expressly authorized and appropriate security controls are implemented. Where personal devices are authorized, reasonable safeguards should include:

device password/PIN;
encryption;
screen lock;
updated operating system;
malware protection where applicable;
secure network use;
no unauthorized sharing;
secure deletion after the authorized purpose ends.

22. EMAIL, WHATSAPP AND MESSAGING PLATFORMS

Because messaging platforms may involve significant privacy risks, ABHAYAM personnel must exercise particular care when transmitting personal data. Confidential student, parent, employee or corporate information shall not be transmitted through informal or personal accounts unless:

the channel has been authorized;
the transmission is necessary;
the recipient is verified; and
appropriate safeguards are available.

Sensitive documents should not be casually forwarded, downloaded or stored on personal WhatsApp accounts or personal email accounts.

23. MARKETING COMMUNICATIONS

ABHAYAM may communicate information concerning programs, courses, workshops, events, services or other relevant offerings where permitted by applicable law and based on an appropriate lawful basis. Where consent is required, marketing consent shall be obtained separately or otherwise clearly distinguishable from consent necessary to provide the requested educational or professional service. An individual may request cessation of marketing communications. Withdrawal from marketing communications shall not necessarily terminate essential administrative, contractual, educational, financial, examination or legally required communications.

24. COOKIES AND WEBSITE TECHNOLOGIES

ABHAYAM's websites may use cookies and similar technologies for purposes such as:

website functionality;
security;
analytics;
performance;
user preferences;
improving website experience.

Where required, appropriate consent or preference mechanisms shall be provided. Third-party technologies may be governed by the privacy policies of their respective providers.

25. RESEARCH, ANALYTICS AND STATISTICAL USE

ABHAYAM may use appropriately protected data for legitimate research, quality improvement, statistical analysis and educational development. Where practicable, ABHAYAM should use aggregated, anonymized or de-identified information rather than identifiable personal data. Personal data shall not be used for research purposes in a manner inconsistent with the notice, consent or other lawful basis applicable to the original collection unless otherwise permitted by law.

26. AI, AUTOMATION AND EMERGING TECHNOLOGIES

ABHAYAM may use software involving artificial intelligence, automation, analytics or machine-learning technologies for legitimate educational, administrative, operational or research purposes. Personal data shall not be uploaded to publicly accessible AI tools or unauthorized AI platforms merely for convenience. Employees, trainers, students, consultants and contractors shall not enter confidential ABHAYAM information, student databases, examination records, proprietary information or identifiable personal data into an AI service unless the service has been authorized for such use and appropriate safeguards are in place. Where an AI or automated system processes personal data, ABHAYAM shall endeavor to assess the relevant privacy, confidentiality, security and contractual risks.

27. DATA SHARING WITH GOVERNMENT OR LAW-ENFORCEMENT AUTHORITIES

ABHAYAM may disclose personal data where disclosure is:

required by law;
required pursuant to a valid legal process;
necessary to comply with a lawful governmental direction;
necessary to prevent or investigate unlawful activity;
necessary to protect the rights, property or safety of ABHAYAM or another person; or
otherwise permitted under applicable law.

ABHAYAM shall seek to limit disclosure to the information reasonably necessary for the applicable lawful purpose.

28. INTERNATIONAL OR CROSS-BORDER PROCESSING

ABHAYAM may use technology and service providers whose infrastructure or personnel may be located outside India, subject to applicable law and contractual arrangements. Where personal data is transferred or made accessible across jurisdictions, ABHAYAM shall take reasonable steps to ensure that applicable legal, contractual and security requirements are addressed.

29. DATA PRINCIPAL / INDIVIDUAL RIGHTS

Subject to applicable law, individuals may have rights relating to their personal data, including rights concerning:

access to information about processing;
correction or updating;
withdrawal of consent where consent is the applicable basis;
erasure where applicable;
grievance redressal;
nomination, where applicable;
information concerning processing and sharing;
other rights available under applicable law.

The availability and scope of a particular right may depend upon the applicable legal basis, purpose of processing and statutory exceptions. ABHAYAM shall not impose unnecessary procedural barriers on legitimate privacy requests.

30. HOW TO MAKE A PRIVACY REQUEST

A Data Principal, parent/legal guardian or other authorized person may submit a privacy request by contacting:

Privacy / Data Protection Contact
ABHAYAM SKILL TRAINING ACADEMY LLP
12, Sumeru, GF-1, Sir M N Krishna Rao Road, Basavanagudi

Bengaluru. KA 560004, Bharat
Website: www.abhayamskills.com

Email: reachus@abhayamskills.com
Phone: +91 8951052782

Requests should contain sufficient information to enable ABHAYAM to identify the relevant individual and understand the request. ABHAYAM may take reasonable steps to verify the identity or authority of the person making a request before disclosing or modifying personal information.

31. GRIEVANCE REDRESSAL

Any individual who believes that their personal data has been improperly collected, used, disclosed, accessed, retained or otherwise handled may submit a grievance to ABHAYAM. Grievances should preferably contain:

name;
contact details;
description of the concern;
relevant date/time;
supporting information, if available;
requested resolution.

ABHAYAM shall maintain an appropriate grievance-handling process and respond within the period required by applicable law. If the individual remains dissatisfied, they may have further rights or remedies available under applicable law.

32. AUTHORITY TO HANDLE PERSONAL DATA

Only authorized personnel may collect, access, modify, download, disclose, transfer or delete personal data on behalf of ABHAYAM. Managers and department heads are responsible for ensuring that their teams follow this Policy. Any suspected misuse must be escalated immediately.

33. DATA CLASSIFICATION

ABHAYAM may classify information according to its sensitivity.

Public Information: Information intentionally made publicly available.
Internal Information: Information intended for authorized internal use.
Confidential Information: Information that could cause harm, disruption or privacy impact if improperly disclosed.
Restricted / Highly Confidential Information: Information requiring heightened controls, including certain student records, identity information, financial information, authentication information, personnel records, contractual information and other information designated by ABHAYAM.

Restricted information shall receive the highest level of access control and protection reasonably appropriate to the circumstances.

34. RECORDING AND MONITORING

ABHAYAM may maintain appropriate records and system logs for:

security;
attendance;
training;
examination;
quality assurance;
audit;
fraud prevention;
dispute resolution;
compliance.

Where CCTV, access-control or other monitoring systems are used at ABHAYAM premises, appropriate notices and safeguards shall be implemented.

35. STUDENT DATABASES AND CONTACT LISTS

Student, parent, alumni and participant databases are the property of ABHAYAM insofar as they constitute ABHAYAM's organizational records and are subject to applicable privacy rights. No employee, trainer, consultant or partner may copy or retain such databases for personal use. Upon cessation of engagement with ABHAYAM, all such databases must be returned or securely deleted as directed by ABHAYAM, subject to lawful retention.

36. PLACEMENT AND INTERNSHIP DATA

Where ABHAYAM facilitates internships, placements, employment opportunities or career services, relevant student information may be shared with authorized employers, recruiters or partner organizations where there is an appropriate lawful basis. Only information reasonably relevant to the relevant opportunity should be shared. ABHAYAM shall not authorize employers or recruiters to use student information for unrelated purposes merely because the information was provided for placement purposes. Students may be required to provide additional information directly to prospective employers where necessary for recruitment.

37. CORPORATE CLIENT INFORMATION

ABHAYAM may process information relating to corporate clients, employees nominated for training, business contacts, representatives and organizational stakeholders. Such information shall be treated as confidential and used only for legitimate business, contractual, training, administrative and legal purposes. ABHAYAM shall not disclose confidential corporate information to unrelated third parties without appropriate authorization or lawful basis.

38. CONFIDENTIALITY OF ACADEMIC RECORDS

Academic results, assessment records, attendance, feedback, disciplinary information and other student records shall be treated as confidential.

Such information shall be disclosed only to:

the student;
authorized parent/legal guardian where applicable;
authorized ABHAYAM personnel;
authorized academic institutions;
authorized employers/recruiters where legitimately required;
regulators or authorities where legally required; or
other authorized persons with an appropriate lawful basis.

39. THIRD-PARTY LINKS

ABHAYAM's website or communications may contain links to third-party websites, platforms or services. ABHAYAM is not responsible for the privacy practices of independent third parties. Users should review the privacy policies of third-party services before submitting personal information.

40. FRAUD, IMPERSONATION AND UNAUTHORISED REPRESENTATION

ABHAYAM shall take reasonable measures to prevent misuse of its identity and personal data entrusted to it. No individual may represent themselves as an authorized ABHAYAM representative for the purpose of collecting personal information unless formally authorized. If a person receives suspicious communication claiming to be from ABHAYAM, they should independently verify the communication through ABHAYAM's official contact channels.

41. DATA BREACH NOTIFICATION

Where a personal data breach occurs, ABHAYAM shall assess the incident and take such actions as may be required under applicable law, including appropriate notification to affected Data Principals and/or competent authorities where legally required. Notifications may include, as appropriate:

nature of the breach;
likely consequences;
measures taken to address the breach;
steps individuals should take to protect themselves; and
contact details for obtaining further information.

42. ACCOUNTABILITY

ABHAYAM shall maintain appropriate internal accountability mechanisms for privacy and data protection, which may include:

privacy policies;
standard operating procedures;
access-control procedures;
confidentiality agreements;
employee training;
vendor due diligence;
data inventories;
retention schedules;
incident-response procedures;
privacy reviews;
audits;
contractual safeguards;
corrective actions.

43. PRIVACY BY DESIGN

Where practicable, ABHAYAM shall consider privacy and security requirements when designing or implementing:

new courses;
online forms;
student portals;
websites;
applications;
databases;
learning systems;
examination systems;
AI systems;
research projects;
corporate training platforms; and
new partnerships.

Privacy and security shall be considered before, rather than only after, the collection or processing of personal data begins.

44. PROHIBITION ON UNAUTHORISED COMMERCIALISATION

ABHAYAM shall not sell personal data or knowingly permit personal data collected for educational, training, counselling, academic, corporate or administrative purposes to be commercialized by employees or unauthorized third parties. Any lawful commercial processing must be separately assessed and appropriately disclosed.

45. ACCOUNTABILITY OF PERSONS HANDLING DATA

Any person who is granted access to ABHAYAM personal data is individually responsible for using that access only for authorized purposes. Unauthorized access shall not be excused merely because:

the person technically had access;
the information was easy to obtain;
the person believed the information might be useful;
another employee had previously shared it;
the information was stored on a company system; or
the person intended to use it for personal benefit.

Access permission does not constitute permission for unrestricted use.

46. BREACH OF THIS POLICY BY PERSONNEL

Violation of this Policy may result in appropriate action, including:

warning;
withdrawal of system access;
suspension of access;
disciplinary action;
termination of employment;
termination of consultancy;
termination of contract;
recovery of losses where legally permissible;
reporting to authorities;
civil proceedings; and/or
criminal proceedings where applicable.

The action taken shall depend upon the seriousness and circumstances of the violation and applicable law.

47. PROTECTION OF ABHAYAM'S CONFIDENTIAL INFORMATION

This Policy also applies, where relevant, to confidential information belonging to ABHAYAM, including:

student databases;
proprietary training material;
curriculum;
assessments;
question banks;
research information;
business plans;
financial information;
contracts;
partner information;
intellectual property;
software credentials;
internal policies;
strategic information;
confidential corporate information.

Personal data protection and protection of ABHAYAM's confidential information shall be treated as complementary obligations.

48. CHANGES TO THIS POLICY

ABHAYAM may periodically update this Policy to reflect:

changes in law;
regulatory requirements;
technology;
business practices;
security requirements;
new services;
organizational changes.

Material changes shall be communicated through an appropriate channel where required. The latest version published through the official ABHAYAM website shall be treated as the current version, subject to applicable law.

49. SEVERABILITY

If any provision of this Policy is determined to be invalid, unlawful or unenforceable, the remaining provisions shall continue to operate to the extent permitted by law.

50. GOVERNING LAW

This Policy shall be interpreted in accordance with the laws of India, including applicable data-protection, information-technology, contractual and other applicable laws. Nothing in this Policy is intended to exclude, restrict or waive any statutory right or remedy that cannot lawfully be excluded, restricted or waived.

51. CONTACT DETAILS

For privacy, data-protection, correction, deletion, consent withdrawal or grievance-related matters:

ABHAYAM SKILL TRAINING ACADEMY LLP

12, Sumeru, Sir M N Krishna Rao Road, Basavanagudi, Bengaluru. KA 560004.

Website: www.abhayamskills.com

Privacy / Data Protection Email: reachus@abhayamskills.com

General Contact: +91 8951052782

Grievance Contact: +91 8951052782

Data Protection Contact / Officer, where applicable: Mr. Shyam Agasthya, CEO

52. DECLARATION

ABHAYAM SKILL TRAINING ACADEMY LLP is committed to protecting the privacy, confidentiality and security of the personal data entrusted to it. Personal data shall be treated as information entrusted to ABHAYAM for a legitimate purpose and shall not be treated as a freely transferable organizational asset. Every person working with or representing ABHAYAM who has access to personal data is expected to protect that information, use it only for authorized purposes and immediately report suspected misuse, unauthorized access or data breaches.

ABHAYAM's commitment is simple: collect responsibly, use lawfully, access carefully, protect rigorously, retain only when necessary, and delete securely when the purpose has ended.

ABHAYAM SKILL TRAINING ACADEMY LLP

Policy Version: 1.0
Effective Date: 26 September 2026

Next Review: At least annually or earlier if required by law, regulation, technology or material organizational change.

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