Privacy Policy

1. Introduction & Scope

This Privacy Policy explains how Vula Technologies Private Limited (CIN: U62013MH2025PTC446682), operating as Vula Capital, Kinetix AI, and Bookswala ("we", "our", or "us"), collects, uses, shares, and protects your personal information.

This policy applies to all our websites, SaaS portals, parent escrow dashboards, and offline corporate library services. By using our services, you consent to the data practices described in this policy, which complies with India's Digital Personal Data Protection (DPDP) Act and applicable international frameworks like the GDPR for our European travel logistics.

2. Information We Collect

Due to the regulated nature of our fintech and international travel services, we collect highly specific data categorized as follows:

• Financial & KYC Data (Parents): PAN card, Aadhaar number, bank account details, and eNACH mandate logs required by our banking and mutual fund partners to comply with RBI/SEBI Anti-Money Laundering (AML) laws.
• Travel & Logistics Data (Students & Parents): Passport copies, biometric appointment data, dietary preferences (e.g., Vegan, Jain), and highly sensitive medical declarations (e.g., allergies, ongoing medications) necessary for safe overseas travel.
• EdTech & AI Data (Students): Responses provided to the Kinetix AI SOP Builder, language proficiency test scores, course progression metrics, and behavioral analytics on the learning portal.
• Corporate Delivery Data (Bookswala): Corporate email addresses, office locations, home delivery addresses (for hybrid workers), and physical reading logs/borrowing history.

3. How We Use Your Data

We process your data strictly for the fulfillment of the services you purchased:

• To authenticate your identity and facilitate the creation of your Nodal Escrow or SEBI Mutual Fund account.
• To trigger API webhooks that release escrow funds based on your travel milestones.
• To secure international flight PNRs, hotel bookings, and submit group visa applications to foreign embassies (e.g., UK, Germany, Singapore, UAE).
• To train and personalize the Kinetix AI learning models specifically for the enrolled student's academic profile (student data is never used to train public, open-source AI models).
• To dispatch physical library books to your corporate office or residence.

4. Data Sharing & Third-Party Partners

We do not sell your personal data. We only share data with verified third parties on a strict "need-to-know" basis to fulfill your contract:

• Financial Infrastructure: Escrow-as-a-Service providers (e.g., Castler), Payment Gateways (e.g., Razorpay), and Nodal Trustee Banks (e.g., IDFC First, ICICI).
• Travel Logistics: Our master B2B fulfillment partner, Anubhav EduTours, who in turn shares necessary data with airlines, 4-star partner hotels, and VFS Global/Embassies for visa processing.
• Channel Partners: If you enrolled via a registered Mutual Fund Distributor (MFD) or Corporate HR code, your referring partner can see your high-level milestone progress (e.g., "Milestone 1 Cleared") for commission/subvention tracking, but they cannot view your raw financial data or bank account numbers.

5. Protection of Minor Data

We handle the personal data of high school students (minors under 18). Consent for the collection and processing of minor data is strictly obtained from the legal parent or guardian during the KYC onboarding phase.

Chaperones utilize the medical and dietary data of minors purely for safeguarding during the EduTour. Upon completion of the tour, physical medical declarations are securely destroyed, and digital logs are anonymized unless required for insurance claims.

6. Data Retention & Security

Your data is stored on secure AWS (Amazon Web Services) cloud servers located within the India South (Mumbai) region, ensuring Indian data sovereignty.

Retention Policies:

• Financial/KYC Data: Retained for a minimum of 5 to 7 years post-contract completion as mandated by RBI, SEBI, and Indian Income Tax regulations.
• Travel/Visa Data: Passport copies and visa documents are purged from our active databases 90 days after the cohort returns to India, minimizing long-term exposure.
• EdTech Data: Retained as long as the student's Kinetix AI account remains active, or until a deletion request is filed.

7. Your Privacy Rights

Depending on your jurisdiction, you have specific rights regarding your personal data:

• Right to Access & Portability: You may request a copy of the data we hold on you.
• Right to Rectification: You can update inaccurate data (e.g., changing your registered email) directly via your Parent Portal.
• Right to Erasure ("Right to be Forgotten"): You may request the deletion of your data. Note: We cannot delete financial KYC data required by RBI/SEBI law until the statutory retention period expires.

To exercise any of these rights, please email our Grievance Officer.

8. Cookies & Tracking Technologies

Our platforms (Vula Capital, Kinetix AI, Bookswala) use cookies to maintain secure login sessions, track AI learning progression, and prevent fraudulent concurrent logins. We do not use third-party tracking cookies for targeted behavioral advertising across the web.

9. Contact Grievance Officer

If you have any concerns regarding how your data is handled, please contact our designated Data Protection & Grievance Officer: