Introduction

Welcome to https://careerbanale.com/ (“we“, “us“, “our“), a digital platform (“Platform”) operated by the Company (defined below), engaged in student recruitment, educational consultancy, and franchise enablement services. We recognize the importance of your personal data and are committed to protecting your privacy.

This Privacy Policy (“Policy”) outlines how we collect, use, disclose, retain, and secure your Personal Data in accordance with the Digital Personal Data Protection Act, 2023 (DPDPA) and the Digital Personal Data Protection Rules, as and when notified by the Government of India. It also takes into account sectoral guidelines, if applicable, and general data protection best practices.

This Policy governs your interactions with CareerBanale.com, including but not limited to when you:

Use our student counselling, admissions, and recruitment services;

Apply to partner with us as a franchisee or business associate; or/and

Access or interact with our Platform, mobile applications, communication channels, or third-party integrations connected to our Platform.

Scope and Limitations

This Policy does not apply to:

Third-party websites, tools, or services linked via our Platform;

Independent data collection, retention, or use by Franchise Partners, who act as separate Data Fiduciaries and are independently responsible for compliance with the DPDPA and its Rules.

By using our services, you acknowledge and agree to the terms of this Policy. If you do not agree with this Policy, please refrain from using the Platform.

Key Definitions

For the purposes of this Policy, the following terms shall have the meanings assigned below. Where applicable, these definitions are aligned with or inspired by the terminology used in the DPDPA:

“You”/ “you”/ “User” means any natural or legal person accessing or interacting with the CareerBana.com Platform, including but not limited to: students, parents or guardians, Franchise Partners, agents, institutional representatives, and other stakeholders.

“Personal Data” means any data about an individual who is identifiable by or in relation to such data, either directly or indirectly. This includes, but is not limited to: name, phone number, email address, academic transcripts, passport/visa details, IP address, location data, and education/career preferences.

“Franchise Partners” means independently owned and operated business entities or individuals who enter into a franchising or licensing agreement with the Company to offer student recruitment and counselling services under the CareerBanale.com brand. Franchise Partners are considered separate Data Fiduciaries under the DPDPA and are individually responsible for compliance with data protection laws.

“Data Fiduciary” means as per the DPDPA, a person or entity who determines the purpose and means of processing personal data. CareerBanale.com and its Franchise Partners may act as independent or joint Data Fiduciaries depending on the nature of data collection and processing.

“Processing” means any automated or manual operation performed on Personal Data including collection, storage, use, sharing, disclosure, or erasure.

Types of Personal Data We Collect

We collect and process various categories of Personal Data depending on your relationship with the Platform (e.g., as a student, parent/guardian, franchise partner, or representative of an institution). This data may be collected directly from you, from authorized representatives (e.g., Franchise Partners), or automatically through your interaction with our digital services.

A. Personal Data Collected from Students / Applicants:

Personal Data Collected from Franchise Partners:

Franchise Partners are required to ensure that any student data they share with us has been collected with appropriate notice and consent as per applicable data protection obligations. Improper collection, misuse, or retention beyond permitted purpose is a breach of this Policy and their contractual obligations.

Automatically Collected or System-Generated Data:

If required, we may collect additional information solely for specific lawful purposes, such as responding to government requests, ensuring academic eligibility, or delivering customized support. You will always be notified and asked for consent where applicable.

How We Use Your Personal Data

We collect and process your Personal Data only for purposes that are lawful, specific, and necessary to provide and improve our services. This includes: (a) facilitating student counselling, admissions, and application processing, which is necessary to perform the contract you enter into with us; (b) onboarding and managing our Franchise Partners in compliance with legal and regulatory requirements; (c) sending marketing communications, event invitations, and promotional updates, only where you have explicitly opted in to receive them; (d) detecting and preventing fraudulent activity, spam, misuse, or unauthorized access, which is necessary for the protection of our Platform and users; and (e) analysing Platform usage to enhance service delivery, functionality, and user experience, which is carried out on the basis of our legitimate interests. We strictly follow the principles of purpose limitation and data minimization and retain your data only for as long as necessary to fulfil the purposes stated above or as required by applicable law.

Data Sharing & Disclosure

We do not sell or commercially exploit your Personal Data. However, we may share your Personal Data with trusted third parties only as necessary to deliver our services and fulfil legal obligations, in accordance with the principles of the DPDPA and applicable contractual safeguards.

We may disclose your personal data to the following categories of recipients:

Universities and Educational Institutions: Shared strictly with your explicit and informed consent for the purpose of application processing, admission, or student onboarding.

Franchise Partners: Shared only in relation to students referred by them, and limited to the data necessary for service delivery. Franchisees act as independent Data Fiduciaries and are responsible for complying with applicable data protection obligations.

Government or Regulatory Authorities: Disclosed when required under applicable laws, including but not limited to immigration, taxation, law enforcement, or other statutory or regulatory purposes.

Authorized Third-party Service Providers: Includes CRM platforms, cloud storage vendors, payment processors, analytics providers, or communication tools who process data on our behalf under strict DPDPA compliant Data Processing Agreements and confidentiality obligations.

We ensure that all third parties receiving your Personal Data are bound by appropriate technical and organizational safeguards and are prohibited from using the data for any purpose other than as instructed by us.

Your Personal Data may be transferred to, stored, or processed in countries outside India, including but not limited to the United States, United Kingdom, Canada, Europe, New Zealand, and Australia, where our partner universities, service providers, or cloud infrastructure vendors operate. Such transfers are made either with your explicit consent, for example, when facilitating university applications, or through lawful mechanisms that comply with the DPDPA. These mechanisms include contractual clauses and data protection agreements designed to ensure that your Personal Data receives an adequate level of protection, consistent with Indian data protection standards. By using our services, you acknowledge and consent to such transfers and the associated safeguards we implement to protect your information.

Each Franchise Partner operating under the CareerBanale.com brand is required to:

Collect, process, and store Personal Data lawfully, fairly, and transparently;

Obtain valid, informed consent from students (where required under law);

Limit the use of Personal Data strictly to the purpose for which it was collected;

Not retain any personal data beyond the permitted or contractual duration;

Promptly report any actual or suspected data breach to the Company within 72 hours of becoming aware of the breach.

Non-compliance with these obligations may result in termination of the franchise relationship and liability under applicable law.

Data Security and Retention

At CareerBanale.com, we are committed to safeguarding your Personal Data through stringent security protocols and industry-standard practices. We implement robust technical and organizational safeguards to prevent unauthorized access, misuse, loss, alteration, or disclosure of data. All data transmissions across our Platform are protected using secure encryption protocols such as SSL/TLS. Access to sensitive information is tightly controlled through role-based access permissions, ensuring that only authorized personnel can handle such data. In addition, we maintain comprehensive audit trails and conduct regular monitoring to detect and address any unauthorized or suspicious activity promptly.

We retain Personal Data only for as long as necessary to fulfil the purposes outlined in this Policy or to comply with applicable legal, regulatory, or contractual requirements. Upon expiry of the applicable retention period, data is securely deleted or anonymized following our internal data destruction protocols.

In the unfortunate event of a data breach involving your Personal Data, CareerBanaLe.com is committed to acting swiftly and transparently. Where the breach is likely to result in a significant risk to your rights or freedoms, we will notify the Data Protection Board of India, as and when incorporated, and affected individuals within 72 hours of becoming aware of and confirming the breach. This notification will outline the nature of the breach, the types of Personal Data affected, and the immediate steps taken to mitigate potential harm. Notifications will be issued either via registered email or through a clearly visible notice on our platform. Additionally, all Franchise Partners are bound by contract to report any data breach impacting student data or CareerBanaLe.com systems within 24 hours of discovery, so that appropriate remedial actions can be initiated promptly.

Your Rights Under the DPDPA

As a Data Principal under the DPDPA, you are entitled to certain fundamental rights regarding your Personal Data. These include the right to access the personal information we hold about you and the right to correct any inaccuracies or outdated details. You may also request the erasure of your data, subject to exceptions required by law or contractual obligations. Furthermore, you have the right to withdraw previously granted consent for optional services such as marketing or promotional communications. If you believe your rights have been infringed or have concerns about our data handling practices, you may seek redress by contacting our designated Data Protection Officer (DPO). Additionally, you may nominate another individual to exercise your rights on your behalf in case of incapacity or legal minority. To exercise any of the above rights, you may write to us at privacy@careerbanale.com. All requests will be processed in accordance with the procedures and timelines prescribed under the DPDPA and other applicable laws.

Limitation of Liability

By accessing or using the Platform, you acknowledge and agree that CareerBanale.com (owned and operated by M SM Global Education Private Limited) provides its services, content, and tools on an “as is” and “as available” basis, without any express or implied warranties, including but not limited to warranties of merchantability, fitness for a particular purpose, accuracy, non-infringement, or continuity of service.

CareerBanale.com does not guarantee that the Platform will function without interruption, errors, or security breaches. We are not liable for any temporary unavailability, data loss, technical glitches, or inaccuracies arising from system errors or third-party service outages.

We expressly disclaim any liability for contractual, academic, financial, or other decisions made by Users based on interactions through the Platform, including engagements with universities, colleges, Franchise Partners, counsellors, or service providers listed on the Platform. Information provided by third-party institutions, agents, or users (including course details, reviews, and representations) is not independently verified, and you are strongly advised to perform your own due diligence.

CareerBanale.com shall not be held responsible for any links or content hosted on third-party websites that may be accessed through our Platform. Inclusion of such links is for convenience only and does not constitute endorsement or recommendation. You are responsible for ensuring the safety and authenticity of any external websites or services you access.

To the fullest extent permitted by applicable law, CareerBanale.com, the Company, and its parent company, affiliates, officers, employees, partners, and licensors shall not be liable for any indirect, incidental, punitive, consequential, or special damages, including loss of data, revenue, business opportunities, goodwill, or profits, arising from your use of or inability to use the Platform.

You agree to indemnify and hold harmless CareerBanale.com, the Company, its directors, officers, employees, Franchise Partners, and agents from any claims, liabilities, losses, damages, or expenses (including legal fees) arising from your use of the Platform, your violation of this Policy, or your infringement of any third-party rights, including intellectual property rights.

Cookies & Tracking Technologies

CareerBanale.com utilizes cookies and similar tracking technologies to improve your browsing experience, ensure secure Platform functionality, and gain insights into how Users interact with our services. These tools help us tailor content, maintain seamless login sessions, and optimize platform performance based on User engagement trends.

We primarily use the following types of cookies:

Essential Cookies, which are necessary for core functions such as User authentication, secure access, and form submissions, and

Analytics Cookies, which collect anonymized usage data, such as page views, session durations, and interaction metrics, often through third-party tools like Google Analytics. These analytics help us better understand user behaviour and refine our offerings accordingly.

You have the option to manage or disable cookies at any time through your browser settings. However, please be aware that disabling certain essential cookies may limit the functionality of key features and impact your overall experience on the Platform.

Children’s Privacy

CareerBanale.com does not knowingly collect Personal Data from individuals under the age of 18 years, unless such data is provided with appropriate parental or guardian consent, or when permitted under applicable law (e.g., for lawful academic engagement). If we become aware of any unauthorized collection of a minor’s data, we will take prompt steps to delete such information promptly.

Unacceptable Use

CareerBanale.com is committed to maintaining a safe, respectful, and lawful digital environment. Users are strictly prohibited from using the Platform to upload, share, transmit, or disseminate any content or engage in any activity that is malicious, unlawful, or harmful to others. This includes, but is not limited to: distributing illegal or offensive content (such as child pornography, hate speech, or defamatory material); violating the intellectual property rights of others by sharing copyrighted content without authorization; engaging in harassment, bullying, or stalking behaviour; promoting pyramid schemes or other fraudulent solicitations; and impersonating individuals or misrepresenting affiliations for deceptive purposes. Users are solely responsible for ensuring that their activities on the Platform comply with applicable laws and community standards. Any breach of these guidelines constitutes a serious violation of our Terms of Use and Privacy Policy, and may, at our sole discretion, result in immediate suspension or permanent termination of access to CareerBanale.com, along with potential legal consequences where applicable.

Policy Updates

We reserve the right to amend or update this Policy at any time in response to evolving legal requirements, technological advancements, or changes to our services. Any updates will be published with a revised “Last Updated” date. We encourage you to review this Policy periodically. Your continued use of the Platform constitutes acceptance of the revised Policy.

Governing Law

By using the Platform, you consent and agree that this Privacy Policy shall be construed in accordance with and governed by the laws of India. You further agree that any dispute, claim, or controversy arising in connection with your use of the Platform shall be subject to the exclusive jurisdiction of the competent courts situated at New Delhi, India. Each party hereby irrevocably submits to the jurisdiction and venue of such courts for the resolution of any matter for which judicial relief is sought. The legal entity responsible for the Platform is MSM Global Education Private Limited, a company with its principal place of business at Ground Floor, Plot No. 18, Sector 32, Gurugram, Haryana 122003 (the “Company”).

Grievance Mechanism

At CareerBanale.com, we take your privacy and data concerns seriously. If you believe that your Personal Data has been mishandled or if you have any grievance regarding our data processing activities, you may write to our designated Data Protection Officer at privacy@careerbanale.com within 15 days of becoming aware of the issue. We are committed to acknowledging all grievances within 7 working days and aim to resolve them within a maximum of 30 days from the date of receipt, in accordance with the DPDPA. If you are not satisfied with our response or resolution, you have the right to escalate the matter to the Data Protection Board of India through the appropriate grievance redressal portal as prescribed under applicable law.