Privacy Policy

1. Introduction

Ekalavya Careers (“we”, “our”, “us”) is committed to protecting personal data and respecting privacy. We build tools that describe how a person learns and grows, and much of what we hold is about children. We treat that as the highest-care category of data we handle.

This Privacy Policy explains:

• What data we collect, and who it comes from
• How we use it, including where AI is involved
• Who can see it
• Your rights under the Digital Personal Data Protection Act, 2023 (India)

Our approach follows a Human-First Design philosophy, where data is used to support a person’s growth, not to exploit it.

2. Who This Policy Covers

• Visitors to our website
• Individuals taking our careers assessments
• Students enrolled in our coaching programs
• Schools using the Swatwam schools platform, and their principals, teachers, co-ordinators and observers
• Parents and guardians of children at those schools
• Students at those schools
• Institutional partners such as colleges and companies

3. Our Two Different Roles

Which role we hold decides who is accountable for the data, and it differs between our two products.

3.1 Careers users — we are the Data Fiduciary

When an individual signs up with us directly for an assessment or a coaching program, we decide the purposes and means of processing. We are the Data Fiduciary and answer to you directly.

3.2 Schools — the school is the Data Fiduciary, we are the Data Processor

When a school uses the Swatwam schools platform, the school is the Data Fiduciary for its roster, its staff records and everything its staff record about a child. We process that data on the school’s instructions, under our agreement with the school.

This has practical consequences for parents:

• The school, not us, decides which features are switched on, which year groups take an assessment, and who at the school may see a child’s record
• The school, not us, obtains the consent of a child’s parent or guardian
• A request to correct or erase a child’s data normally goes to the school first. We will act on it when the school instructs us, and we will help you reach the right person if you write to us instead

4. Definitions

• Personal Data: Any data about an identifiable individual
• Data Principal: The individual whose data is collected. For a child, this includes the parent or lawful guardian acting on their behalf
• Data Fiduciary: Whoever decides why and how personal data is processed — us for careers users, the school for school data
• Data Processor: Whoever processes data on a Fiduciary’s behalf — us, for school data
• Consent: Freely given, informed, specific, and unambiguous agreement

5. Data We Collect From Careers Users

5.1 Personal information

• Name, age, gender
• Contact details such as email and phone number
• Academic information

5.2 Assessment data

• Career interests
• Psychometric and assessment responses
• Motivation, preferences, and learning patterns
• Reports and career profiles generated from those responses, including AI-generated career profiles reviewed by a coach

5.3 Payment and technical data

• Whether you have paid for a program, and when. We do not collect or store card, UPI or bank account details — payment is collected outside this platform
• IP address, device and browser information
• Website usage data including cookies

6. How We Use Careers Data

• Deliver personalized assessments and reports
• Provide coaching and mentorship
• Improve our services and user experience
• Communicate updates and program information
• Ensure platform security and fraud prevention

We do not sell personal data to third parties, and we do not use assessment responses to target advertising.

7. Legal Basis and Consent

We process personal data based on:

• Consent — taken explicitly before an assessment or enrollment
• Legitimate use — service delivery and compliance with legal obligations

You have the right to:

• Give, withdraw, or manage consent at any time
• Request deletion of your data

To withdraw consent or raise a request, contact hello@swatwam.com (use subject line: Data Privacy Request).

8. What the School Gives Us

A school uploads or enters its own records so the platform knows who is in it. For each child this may include:

• Name, admission number, class and division
• Date of birth, gender
• Home address and blood group
• An emergency contact name and phone number
• Guardian names, relationship, email addresses and phone numbers
• The child’s own email address, where the school records one for older students

For staff, the school provides:

• Name, email address and role at the school
• Which classes and subjects they teach, and their timetable

The school decides what to enter. We do not require the optional fields, and a school may run the platform without them.

9. What Staff Record About a Child

The platform is built around an observation ledger: short written notes about specific moments a teacher, parent, co-ordinator or observer noticed. An observation may carry:

• What was seen, in the recorder’s own words, and its context
• Which development areas it speaks to — Learner Agency, Thinking, Relationships, Wellbeing, Growth
• An optional development level: emerging, developing, proficient or flourishing
• Skills and values seen in the moment, and how strongly each showed, where the school has that feature switched on
• Photographs, where the school has photographs switched on
• Who recorded it, in what role, and when the moment occurred

Alongside observations, the platform may hold:

• Portfolio entries — a project, club, competition or piece of service, and what the child themselves did in it
• Exam and test marks, stored as marks obtained out of marks available. Marks are never converted into a development level
• Teacher trait ratings — a teacher’s judgement of learning styles and multiple intelligences. These are a judgement, not a test result
• Interests recorded by a teacher or parent
• Homework and notices the school issues, and any attachments on them

10. Photographs of Children

• Photographs are only available to a school that has bought photograph storage, and only staff who may already see the child can upload one
• Images are re-encoded and resized on upload; a full image and a thumbnail are kept
• They are stored in cloud object storage under a key specific to the school and the child, so that everything belonging to one child can be removed in a single operation
• Photographs are not used to train any model, are not shared with any other school, and are not published anywhere public
• We apply no facial recognition, no biometric extraction and no automated identification to any image

Each school holds a storage allowance and can see what it is using. A parent who does not want their child photographed should tell the school, which controls whether the feature is used at all.

11. Voice Observations

Where a school has enabled voice observations, a teacher may speak an observation instead of typing it.

• The audio is sent to our transcription provider, Deepgram, which transcribes it and does not use it to train its models
• The recording is then kept for two days, so the person who made it can play it back and check what they wrote against what they said. After two days it is deleted automatically
• Only the person who recorded it can listen to it. A recording made by a teacher is not available to a parent, and one made by a parent at home is not available to school staff
• They can delete it sooner, at any time, and deleting it removes the audio from our storage
• The transcript is shown to the teacher to read and correct before anything is saved. Only the corrected text becomes part of the child’s record, and it stays after the recording has gone
• We retain the length of the clip in seconds, because that is what the school is billed on
• A teacher chooses the language they are speaking — English, Marathi or Hindi — and nothing is sent until they ask for it to be transcribed
• We do not record classrooms, and there is no ambient listening. Recording starts and stops on a deliberate press, and stops itself after three minutes

12. Assessments in Schools

Where a school has bought assessments, it also chooses which year groups are offered one. Nobody is enrolled until the school switches their grade on.

• Students are offered the Holistic Career Assessment from Grade 10 upward. There is an age floor enforced on our servers, not just in the interface
• Teachers are offered the Professionals variant, about their own strengths and motivation
• Parents are offered Strengths Discovery, about what they bring to the conversation at home

A completed assessment produces a report, and optionally an AI-generated career profile. A report is withheld until a coach has reviewed and approved it. Until then nobody outside the reviewing coach and our own staff can open it. A principal cannot approve their own school’s reports.

A teacher’s or parent’s own assessment result is theirs. It is not shown to the principal as a staff record or a parenting score.

13. Where AI Is Used — and Where It Is Not

We use a third-party large language model provider for a small, named set of tasks. Data sent for these tasks is not used by us to train models.

AI is used to:

• Write the narrative of a child’s Holistic Development Profile from the observations already recorded, including the plain-words summary a parent reads
• Suggest one weekly focus for a child, where the school has that feature enabled
• Draft lesson plans and self-directed learning guides for staff
• Transcribe a spoken observation
• Generate a career profile from a completed assessment

AI is deliberately not used to:

• Decide a child’s development level. Levels, trends and confidence are computed in our own code from the recorded evidence. The model writes the words; it does not choose the rating
• Make any decision about a child on its own. Nothing is communicated to a family until a person at the school has read it and released it
• Grade, rank or score children against each other
• Profile anyone for advertising

A teacher may disagree with a computed level and record their own reading beside it. An approving reviewer may rewrite the summary a parent reads. Both are stored alongside the generated text rather than replacing it, so it is always visible that a person disagreed with the model.

14. Who Can See What

Visibility is denied by default and enforced on our servers, not merely hidden in the interface.

• A teacher sees the children in the classes assigned to them, and among observations, only the ones they wrote themselves
• A parent sees only their own children. Among observations, they see only the ones they wrote themselves — not a teacher’s notes, and not another parent’s
• A parent sees a child’s profile only once the school has released it. Before that, our server returns nothing derived from it
• A student with an account sees only their own record
• A principal, co-ordinator or observer may see every child in their own school, and no child in any other school
• Our own staff may access a school’s data to support it, to review assessment reports, and to bill it. Access is limited to named roles

Curriculum material and self-directed learning guides are staff-only; a parent sees nothing of them.

15. When a Parent Is Told Something

• Profiles are regenerated automatically each week for children with enough new observations. This is silent — nobody is emailed
• We do not email anyone about a profile. When the school releases one, a prompt appears on the parent’s home screen inside the app the next time they sign in; they dismiss it once and it is gone
• Nothing about a child is sent by email, so no part of a profile travels through an unencrypted mailbox. The next release raises a fresh prompt
• Where the school has enabled observer approval, only the school’s nominated observer — plus our staff supporting them — may release a profile. A parent can never release one to themselves

16. Corrections and the Audit Trail

The observation ledger is an audit trail about a child, so it is not silently rewritable.

• Whoever recorded an observation may edit or delete it until a profile has been built from it, and not afterwards
• An edit keeps the previous text and stamps when it was changed, so “this was changed after the fact” is always answerable
• A parent may correct their own child’s roster details — the family’s own facts. A teacher may not
• A parent who disputes what a teacher recorded should raise it with the school. The school can act on it; we will not alter a school’s record without the school’s instruction

17. What We Never Do With a Child’s Data

• We never sell it
• We never use it for advertising, and we do not run behavioural advertising or tracking directed at children
• We never share one school’s data with another school, or with any other family
• We never use a child’s observations, photographs or profile to train our own or a third party’s models
• We never turn a child’s record into a public ranking, league table or single score

18. Retention, Leavers and Deletion

• School data is retained for as long as the school remains a customer, because a developmental record is only useful across years
• A staff member or student who leaves can be deactivated, which revokes their access while leaving the history they contributed intact and attributed
• When a child leaves, or where a school instructs deletion, we delete or return that child’s records, including their photographs, within a reasonable period
• On termination of a school’s agreement we delete or return school data on the school’s instruction, subject to any retention the law requires
• Careers data is retained only as long as needed to deliver the service and meet legal and regulatory requirements

Billing and usage records — what a school was charged for, and when — are kept for the period accounting and tax law requires. These contain no observations and no personal detail about a child.

19. Data Storage and Security

• Data is encrypted in transit
• Passwords for school accounts are stored only as a salted scrypt hash. We never store, log or return a plaintext password, and no member of our staff can read one
• Sign-in sessions for school accounts are short-lived and signed, and carry nothing private
• Repeated failed sign-in attempts are throttled
• Role-based access controls are applied on the server for every page and every API route
• Regular monitoring and security review

20. Who Else Processes Data

We use a small number of service providers, each bound to appropriate data protection terms and used only for the purpose listed:

• Application hosting — running the website and API
• Database hosting — storing records
• Authentication provider — sign-in for our careers users and for schools that use it. Pilot school accounts sign in with a password held by us and never reach it
• AI provider — narrative generation, weekly suggestions, lesson planning, career profiles and transcription
• Cloud object storage — photographs and school attachments
• Email provider — invitations to join a school. Nothing about a child’s profile is ever emailed

Within a school, data is also visible to the school’s own staff, to coaches and mentors delivering the service, and to our support staff as described in section 14.

We do not share data for advertising, resale, or unauthorized use. We may disclose data where the law requires it, and will tell the school or the individual unless we are prohibited from doing so.

21. Cross-Border Data Transfers

Some of the providers above process data outside India. In particular, our AI and transcription provider and our cloud object storage operate internationally, so observation text, assessment responses, spoken observations and photographs may be processed outside India.

• Transfers comply with applicable data protection laws
• Providers are bound by contract not to use the data for their own purposes, including model training
• We will not transfer data to any territory the Central Government restricts under the DPDP Act

22. Data of Children

For anyone under 18 years of age:

• Verifiable parental or guardian consent is required. For a school, the school obtains this as part of enrolment
• Data is processed strictly for the benefit of the child
• We do not carry out tracking, behavioural monitoring or targeted advertising directed at children

Parents or guardians have the right to:

• Access the child’s data
• Request correction or deletion
• Withdraw consent, which for school data is exercised through the school

23. Your Rights Under the DPDP Act

You have the right to:

• Access your personal data
• Correct inaccurate or incomplete data
• Request erasure of your data
• Withdraw consent
• Nominate someone to exercise your rights on your behalf
• Seek grievance redressal

For careers data, write to us directly. For school data, write to your school first — we act on the school’s instructions. If you write to us instead, we will acknowledge you and pass the request to the right person at the school.

24. Grievance Redressal

In accordance with the Digital Personal Data Protection Act:

• Grievance Officer: Atul Veer
• Email: hello@swatwam.com
• Response Timeline: As per applicable legal requirements

25. Data Breach Notification

In the event of a data breach:

• We will notify the Data Protection Board and affected individuals as required by law
• Where school data is affected, we will notify the school without undue delay so it can inform its families
• Immediate corrective actions will be taken

26. Cookies and Tracking

We use cookies to:

• Keep you signed in
• Improve website functionality
• Understand aggregate usage trends

We do not use advertising cookies or third-party ad networks. You can manage or disable cookies through your browser settings, though sign-in will not work without the session cookie.

27. Updates to This Policy

We may update this Privacy Policy from time to time.

Updates will be published on this page with a revised effective date. Where a change materially affects how school or children’s data is handled, we will also tell the school directly. Continued use of our services constitutes acceptance of the updated policy.

28. Contact Information

Ekalavya Careers

Website: swatwam.com

Phone: +91 9766118092

Email: hello@swatwam.com