Thank You for using the Letsmile Website! Your privacy is important to us. To better protect Your privacy, and to help ensure a rewarding experience for all users, we provide this privacy policy.
1. Scope:
1.1. This website under the name and style “Letsmile” (“Website”) is developed and made available by Letsmile Private Limited, with its registered office at No. 302A, Oswal Chambers, Kolkata 700001 and which may mean and include any of our affiliates, associates, assignees or successors-in-interest as determined by us at our sole discretion and without requiring any prior notice or intimation, from time to time (“Company”, “we” or “us” or “our”) and is committed to protecting and respecting Your privacy.
1.2. Anyone below 18 (eighteen) years of age is assumed to be a child (“Child”) and requires parental consent to use the Website. The parents/legal guardian of the Child or users above 18 (eighteen) years of age are hereinafter referred to as “You” or “Your”.
1.3. This policy (this “Privacy Policy”), together with the terms and conditions for the use of the Website (“Terms and Conditions”), outlines the Website’s privacy practices regarding the collection, use and safeguard of Your information through the Website and the Services offered thereupon.
1.4. Your clicking of the “I agree” button and submission of personal information or if You are a minor, the submission of Your personal information either by Your parents (or Your guardian) or by You with the permission of Your parents (or guardian) to the Website will be deemed as Your acceptance of this Privacy Policy.
1.5. This Privacy Policy is an electronic record in terms of the Information Technology Act, 2000 (as amended/re-enacted from time to time) (“IT Act”) and rules thereunder, and, amongst others, is published in accordance with the provisions of Rule 3 (1) of the Information Technology (Intermediaries Guidelines) Rules, 2011, as well as Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, which mandates for publishing of rules and regulations, privacy policy and terms of use for access or usage of a website or any online application. This Privacy Policy is an electronic record, generated by a computer system and does not require any physical or digital signatures.
2. Changes to the Privacy Policy:
2.1. We are obligated to protect Your information in accordance with applicable laws, and regulations.
2.2. This Privacy Policy is subject to modification based on changes in the business, legal and regulatory requirements and will be updated online. We will make all efforts to communicate any significant changes to this Privacy Policy to You. You are encouraged to periodically visit this page to review the Privacy Policy and any changes to it. Your continued use of the Website or the Services thereunder following the posting of any amendment to this Privacy Policy shall constitute Your acceptance of such amendment.
3. Your Consent
3.1. Before we can provide You with access to the Website and its Services (as highlighted in the Terms and Conditions), we require Your consent. Under the applicable laws, we cannot collect, process or store any information pertaining to You without Your consent. Without Your consent, we will not be able to collect and process the necessary information, without which we cannot provide access to our Services available through our Website.
3.2. In case the User is a minor, You, as the parent/guardian, are the primary account holder. This means that:
3.2.1. You are the person primarily responsible for ordering Services and paying any fees or other charges made to us.
3.2.2. You are responsible for deciding whether to share Your Child’s content with us and third parties.
3.2.3. You are responsible for the active monitoring of Your Child’s content. Children are expressly prohibited from including any personally identifiable information in any content that they post to our website unless or until their parents or legal guardians give permission. You agree that You will only allow Your child to include any personally identifiable information in their content with Your consent. We shall therefore assume that any personally identifiable information posted by Your Child has been done so with Your express permission.
4. Personal Information we collect:
4.1. Personal Information is defined as information that can be used to identify You or Your Child and may include details including but not limited to:
4.1.1. You or Your Child’s contact details such as Your child’s name, age, gender, contact information, educational background and any other personally identifiable information;
4.1.2. Your transactions details including the payment details for Services (with an exception to Your financial information such as credit card number, cardholder name, expiration date and CVV or other information as required for internet banking or other payment instruments).
4.1.3. Your session log information on our Website which includes Your navigation within the Website, source of traffic, IP address (from which we can approximately determine user location), browser type, browser language, operating system, date and time of request.
4.1.4. Your communications with us on the Website.
4.2. Insofar as sensitive Personal Information is concerned, such Sensitive Personal Information may include information relating to Your password, financial information such as bank account or credit card or debit card or other payment instrument details. When you subscribe to our Services and visit and use our Website and avail our Services, Sensitive Personal Information may be collected for the purpose of enabling payment for Services.
4.3. The following is the manner in which we collect, use, share and retain Personal Information:
4.3.1. Collection
4.3.1.1.Most of the Personal Information we process is provided by You directly to us when You register to use our Website and/or Services. This also includes the Personal Information and/or sensitive personal data (as defined by the applicable law) collected automatically and in the background by us when You use our website. Certain information might be collected automatically as You or the child navigate through the Website (which may include usage details, IP address, device ID and type, Your browser type and language, the operating system used by the device, access times, and information collected through cookies, web beacons and other tracking technologies).
4.3.1.2.Note that we may collect Personal Information for the purposes of behavioral advertising. We may also allow third-party behavioral trackers in areas intended to be used by children.
4.3.1.3.We may also receive Personal Information about You from third parties and publicly available sources of information.
4.3.2. Usage
4.3.2.1.The Website seeks this information either to (i) validate and process Your request for the Services of the Website or information; (ii) to improve the quality of the Website; (iii) to assist You to determine which Services best meet Your needs; or (iv) to facilitate our internal business operations, including the fulfilment of any legal and regulatory requirements; or (vi) to perform quality audits and training of Trainers (as defined in the Terms and Conditions); or (vii) to evaluate, develop and improve our Services; or (viii) for market analysis and market research; (ix) to handle enquiries and complaints; or (xi) to enable You to avail of our Services, and ensure efficient customer care experience and develop new features.
4.3.3. Sharing
4.3.3.1.We may disclose Personal Information to our affiliates when necessary to perform Services on our behalf or on Your behalf. Please note that we or our affiliates may market or advertise to You as a result of such sharing unless You explicitly opt-out by sending an email from your registered email-id to the Grievance Officer, as displayed on the Website.
4.3.3.2.We may also share Your Personal Information or Sensitive Personal Information with external organizations or individuals if we believe that access, use, preservation or disclosure of the information is reasonably necessary to:
(a) detect, prevent or otherwise address fraud, security or technical issues;
(b) protect against harm to the rights, property or safety of our customers or the public, as required or permitted by law.
4.3.4. Regulatory Disclosures:
In the event we are required to respond to court orders or other legal process or any tax authorities, Your Personal Information may be disclosed pursuant to such court orders or legal process or tax authorities, which may be without notice to You. We may further disclose Your Personal Information to such third parties to whom it transfers its rights and duties under any agreement entered into with such third parties and may also disclose Your Personal Information to any of its affiliates or related entity.
4.3.5. Retention
The information so collected shall be retained only for a limited duration necessary to fulfil the purposes outlined herein unless a longer retention period is required or permitted by law and only for the purposes defined above. Once the purpose is achieved, all Personal Information is deleted in a safe and secure mode. We have adopted reasonable security practices and procedures as required under applicable law and have included strategic, operational, managerial, technical and physical security and encrypted controls to safeguard and protect Your data and information. Please note that we shall not sell any Personal Data belonging to You and/ or Your Child, for the purpose of marketing, advertising, or any other third-party use, except in accordance with express consent obtained from You. However, we may retain certain Personal Information for as long as required or permitted by law.
5. Non-Personal Information:
5.1. Non-Personal Information is defined as any data that does not personally identify You or Your Child and may include unique system or hardware identifiers, system or application software, and peripherals.
5.2. Any Non-Personal Information, when clubbed with Personal Information shall be treated as Personal Information.
5.3. The following is the manner in which we collect, use, share and retain Non-Personal Information.
5.3.1. Collection: You agree that the Website may collect diagnostic, technical, usage related information, for the usage purposes described below. This information, once collected, is anonymized in a manner that does not personally identify You.
5.3.2. Usage: The above mentioned information is gathered periodically to provide and improve the Website and Services therein, facilitate the provision of software updates, and other services to You (if any) and to verify compliance with the terms of this Policy.
5.3.3. Sharing: To enable the Website partners and third-party developers to improve their software, hardware and Services designed for use with the Website, we may also provide any such partner or third-party developer with a subset of diagnostic information that is relevant to that partner’s or developer’s software, hardware and/or Services, as long as the diagnostic information is in a form that does not personally identify You. We will not be liable for transfer of any personal identification information resulting from loss or distribution of data, the delineation or corruption of media storage, power failures, natural phenomena, riots, act(s) of vandalism, sabotage, terrorism or any other event beyond our control.
5.3.4. Retention: The information so collected shall be retained only for a limited duration necessary to fulfill the purposes outlined herein unless a longer retention period is required or permitted by law and only for the purposes defined above. Once the purpose is achieved, all information is deleted in a safe and secure mode.
6. Cookies:
Information collected by cookies and other technologies are treated as Non-Personal Information. However, to the extent that IP addresses or similar identifiers are considered Personal Information by local law, we treat any information linked to such identifiers as Personal Information. Similarly, to the extent that Non-Personal Information is combined with Personal Information, we will treat the combined information as Personal Information. We do not use cookies to save Personal Information for unauthorized purposes.
7. Access, Correction and Deletion:
7.1. The Website strives hard to keep its records updated and accurate with Your latest information. You shall be responsible to ensure that the information or data You provide from time to time is and shall be correct, current and updated and You have all the rights, permissions and consents to provide such information or data.
7.2. You may note that deletion of certain information or withdrawal of consent may lead to cancellation of Your access to the Website or Your access to certain features and Services of the Website. Additionally, we may not be able to process Your request of correction, updating or deletion, in case the same is not supported by valid documents or data retention is required by the applicable law or law enforcement requests or under any judicial proceedings or it is extremely difficult to implement (such as requests related to backup copies or if a new system is required to process the request or change of technical design) or risks the privacy of other users.
8. Security Information
8.1. We have put in place appropriate methods and managerial procedures to safeguard and secure such Personal Information. We only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the user. You may request to review, update, amend or delete Your Personal Information previously submitted on the Website, by sending an email for such request to letsmile.prachi@gmail.com .
8.2. We use commercially reasonable precautions to preserve the integrity and security of Your information against loss, theft, unauthorised access, disclosure, reproduction, use or amendment.
8.3. The information that is collected from You may be transferred to, stored and processed at any destination within and / or outside India. By submitting information on the Website, You agree to this transfer, storing and / or processing. The Company will take such steps as it considers reasonably necessary to ensure that Your information is treated securely and in accordance with this Privacy Policy.
8.4. In using the Website, You accept the inherent security implications of data transmission over the internet. Therefore, the use of the Website will be at Your own risk and the Company assumes no liability for any disclosure of information due to errors in transmission, unauthorised third party access or other acts of third-parties or acts or omissions beyond its reasonable control and You agree not to hold the Company responsible for any breach of security.
8.5. In the event the Company becomes aware of any breach of the security of Your information, it will promptly notify You and take appropriate action to the best of its ability to remedy such a breach.
9. Exclusion
9.1. The Company also protects Your Personal Information off-line other than as specifically mentioned in this Privacy Policy. Access to Your Personal Information is limited to employees, agents or partners and third parties, who the Company reasonably believes will need that information to enable the Company to provide Services to You. However, the Company is not responsible for the confidentiality, security or distribution of Your own Personal Information by our partners and third parties outside the scope of our agreement with such partners and third parties.
10. Processing of the Data
We, our affiliates or any third party or any third-party service providers with whom we have entered into contractual arrangements may also process any personal and/or usage related information collected from You for the specific purposes mentioned under this Privacy Policy and the Terms and Conditions. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk of our processing of Personal Information such as (i) only sharing and providing access to Personal Information to the minimum extent necessary, subject to appropriate contractual restrictions including confidentiality restrictions where appropriate, and on an anonymized basis wherever possible; (ii) using secure servers to store Personal Information; and (iii) verifying the identity of any individual who requests access to Personal Information prior to granting them access to such information.
11. Data Transfer
11.1. Your information collected through the Website may be stored and processed in India or any other country in which we or our subsidiaries, affiliates or service providers maintain facilities.
11.2. We may transfer, in full compliance with applicable laws, any information that we collect about You, including Personal Information, to affiliated entities, or to other third parties across borders and from Your country or jurisdiction to other countries or jurisdictions around the world. These countries may have data protection laws that are different to the laws of Your country and, in some cases, may not be as protective. We have taken appropriate safeguards to require that Your information will remain protected in accordance with this Privacy Policy such as entering into signed agreements to ensure the adequate protection of Your Personal Information.
12. Liabilities:
12.1. We shall not be liable for any indirect, incidental, consequential, special or exemplary damage(s) arising due to loss of data or use arising out of or in connection with Your access or use of or inability to access or use the Website including but not limited to any sub- domains.
12.2. We shall not be liable for any third-party products, software or service provided to You. You shall assume all risks arising out of or resulting from any transaction undertaken by You with such third party on the Website and You agree that we shall not be responsible or liable for any loss to You due to Your usage of such third-party application.
13. Sale of Assets, Merger, Acquisition
We may share Your information with our parent, subsidiaries and/or affiliates for internal purposes. The Company also reserves the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Website or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including, during the course of any due diligence process. You will be notified via email and/or a prominent notice on our Website of any change in ownership.
14. Third Party Services:
Please note that Your internet service provider, operating system provider, third-party applications, social media platforms and websites that You access may also collect, use and share information about You and Your usage. We cannot control how these third parties collect, use, share or secure this information. For information about third-party privacy practices, please consult their respective privacy policies.
15. Queries and Complaints:
Should You have questions about the Privacy Policy or information collection, use and disclosure practices in relation to the Services, You may contact our Grievance Officer at:
Grievance Officer
Email: letsmile.prachi@gmail.com
The Grievance Officer shall redress Your grievances expeditiously. Except where required by law, we cannot ensure a response to questions or comments regarding topics unrelated to the terms of these Terms and Conditions or the Privacy Policy.