Privacy Policy

1. About This Policy

This Privacy Policy is published in accordance with:

• The Information Technology Act, 2000 (as amended)
• The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011
• The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021
• Applicable provisions of the Digital Personal Data Protection Act, 2023 (DPDPA)

This Policy applies to all visitors, users, and individuals who access our website, submit enquiry forms, or engage with our services in any manner.

Jolly Reading is operated by Megha Vyas, a certified Jolly Phonics and Jolly Grammar Trainer based in India, offering online phonics teacher training programmes through the website jollyphonicsonline.com.

2. Information We Collect

2.1 Information You Provide Directly

When you submit an enquiry form on our website, we collect:

• Full name
• Email address
• WhatsApp / mobile number
• Course interest (Basic or Advanced Phonics Training)
• Any message or query you choose to include

2.2 Information Collected Automatically

When you visit our website, we automatically collect:

• IP address — used for security, fraud prevention, and approximate location identification
• Browser type and version
• Device type (mobile, desktop, tablet)
• Pages visited and time spent
• Referring URL — the page you came from before visiting our site
• Date and time of visit

2.3 Information from Third-Party Services

We use Google Analytics, Google Tag Manager, and Google Ads on our website. These services may collect additional data about your browsing behaviour in accordance with Google's own Privacy Policy.

3. How We Use Your Information

We use the information we collect for the following purposes:

• To respond to your enquiry and provide information about our phonics teacher training courses
• To contact you via phone, email, or WhatsApp regarding your consultation request
• To process your enrolment in our training programmes
• To send course-related communications including batch dates, schedules, and updates
• To improve our website and user experience based on usage analytics
• To measure advertising effectiveness through Google Ads conversion tracking
• To comply with legal obligations under applicable Indian law
• To prevent fraud and ensure security of our systems
• To maintain records of transactions and communications as required by law

We will not use your personal information for any purpose not listed above without obtaining your prior consent.

4. Legal Basis for Processing

We process your personal data on the following legal grounds:

• Consent: When you submit our enquiry form, you consent to us contacting you regarding our services. You may withdraw this consent at any time by contacting us.
• Contractual Necessity: When you enrol in our courses, processing your data is necessary to fulfil our contractual obligations to you.
• Legitimate Interests: We process certain data based on our legitimate business interests, including improving our services and preventing fraud, provided such interests are not overridden by your rights.
• Legal Obligation: We may process your data where required to comply with applicable Indian laws and regulations.

5. Sharing of Information

We do not sell, trade, rent, or commercially exploit your personal information to any third party.

We may share your information only in the following limited circumstances:

• Service Providers: We use Google Workspace (Google Sheets, Google Forms) to store enquiry data. Google acts as a data processor on our behalf and is bound by appropriate data protection agreements.
• Legal Compliance: We may disclose your information if required to do so by law, court order, or governmental authority under the Information Technology Act, 2000 or any other applicable Indian legislation.
• Business Transfer: In the event of a merger, acquisition, or sale of our business, your data may be transferred to the successor entity, subject to the same privacy protections.
• Protection of Rights: We may disclose information to protect the rights, property, or safety of Jolly Reading, our users, or others.

6. Cookies and Tracking Technologies

Our website uses the following tracking technologies:

6.1 Google Tag Manager

We use Google Tag Manager (GTM-KWHQH3G7) to manage tracking scripts on our website. GTM itself does not collect personal data but enables other tracking tools to function.

6.2 Google Analytics

We use Google Analytics to understand how visitors interact with our website. This service collects anonymous usage data including pages visited, time on site, and device type. Google Analytics uses cookies to track user sessions.

6.3 Google Ads Conversion Tracking

We use Google Ads to run paid advertising campaigns. When you visit our website through a Google Ad and submit an enquiry form, a conversion event is recorded to measure the effectiveness of our advertising.

6.4 Your Cookie Choices

You can control cookies through your browser settings. Most browsers allow you to refuse or delete cookies. However, disabling cookies may affect the functionality of our website. You may also opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on.

7. Data Retention

We retain your personal information for the following periods:

• Enquiry data (name, email, phone, IP) — retained for 3 years from date of submission or last interaction
• Enrolled student data — retained for 7 years from date of course completion as required for educational and tax records
• Website analytics data — retained for 26 months as per Google Analytics default settings
• Communication records (emails, WhatsApp) — retained for 2 years

After the applicable retention period, your data will be securely deleted or anonymised. You may request earlier deletion of your data by contacting us, subject to our legal obligations.

8. Your Rights

Under applicable Indian law and in accordance with the Digital Personal Data Protection Act, 2023, you have the following rights with respect to your personal data:

• Right to Access: You may request a copy of the personal information we hold about you.
• Right to Correction: You may request correction of any inaccurate or incomplete personal information.
• Right to Erasure: You may request deletion of your personal data, subject to our legal obligations to retain certain records.
• Right to Withdraw Consent: Where we process your data based on consent, you may withdraw that consent at any time. This will not affect the lawfulness of processing prior to withdrawal.
• Right to Nominate: Under the DPDPA 2023, you have the right to nominate another individual to exercise your rights in the event of your death or incapacity.
• Right to Grievance Redressal: You have the right to file a complaint with our Grievance Officer (details in Section 13).

To exercise any of these rights, please contact us using the details in Section 14. We will respond to your request within 30 days of receipt.

9. Data Security

We implement reasonable and appropriate technical and organisational measures to protect your personal information against unauthorised access, loss, alteration, disclosure, or destruction.

Our security measures include:

• SSL/TLS encryption on our website (HTTPS)
• Access controls limiting who can view your submitted data
• Secure storage of form data in Google Workspace with restricted access
• Regular review of our data collection and storage practices

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security.

10. Third-Party Services

Our website uses the following third-party services. Each operates under its own privacy policy:

• Google Analytics — Google Privacy Policy
• Google Ads / Google Tag Manager — Google Privacy Policy
• Google Workspace (Sheets) — Google Privacy Policy
• WhatsApp Business — WhatsApp Privacy Policy
• Google Fonts — Fonts are loaded from Google servers. Google may collect basic request data.

We are not responsible for the privacy practices of these third-party services. We encourage you to review their respective privacy policies.

11. Children's Privacy

Our services are directed exclusively at adult educators, teachers, and education professionals. We do not knowingly collect personal information from individuals under the age of 18 years.

If you believe that a minor has submitted personal information to us without parental consent, please contact us immediately at the details provided in Section 14 and we will take prompt steps to delete such information.

12. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time. Changes will be effective immediately upon posting the updated policy on this page with a revised effective date.

We will notify users of material changes by:

• Updating the "Last Updated" date at the top of this page
• Sending an email notification to users who have submitted enquiries, where reasonably practicable

Your continued use of our website after any changes to this Privacy Policy constitutes your acceptance of the revised policy. We encourage you to review this page periodically.

13. Grievance Officer

In accordance with the Information Technology Act, 2000 and the Information Technology (Intermediary Guidelines) Rules, 2021, we have appointed a Grievance Officer to address complaints and concerns regarding the processing of personal data:

Any complaint or concern regarding the processing of your personal information should be submitted in writing to the Grievance Officer. We are committed to resolving all legitimate complaints promptly and fairly.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

We aim to respond to all privacy-related enquiries within 7 business days.