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DPDP Act 2023

Most of our users
are children.

That single fact changes what the Digital Personal Data Protection Act, 2023 requires of us — and it is the reason this page exists as its own notice rather than a paragraph inside the privacy policy.

Updated 14 September 2026

This notice is for the person who scrutinises it: a parent deciding whether to trust us, or a school's legal or IT function. Read it together with the Privacy Policy. Where we do not yet meet a standard, this page says so rather than implying we do.

01

Roles under the Act

Veranox Systems Private Limited is the Data Fiduciary for personal data processed through OrbitOne. The student — and, where relevant, the parent or guardian — is the Data Principal. Groq, Google, Supabase, Vercel, Cloudflare and Razorpay act as our processors for the narrow purposes set out in the Privacy Policy.

02

Children's data — Section 9

Section 9 of the Act sets three obligations where the Data Principal is a child (under 18). Stated plainly, with our current position on each:

  • ·Verifiable parental consent is required before processing a child’s data. Since 14 September 2026 we collect a parental declaration at sign-up: a guardian names themselves and affirms consent on the same screen before the account is created. We do not yet VERIFY that declaration — see section 03.
  • ·No tracking or behavioural monitoring of children. We do not do this. We measure academic performance on questions a student chose to attempt — that is service delivery the user asked for, not behavioural profiling. There are no advertising trackers, no cross-site tracking, and no third-party analytics on the learner surfaces.
  • ·No targeted advertising directed at children. We run no advertising of any kind.
03

Where we currently fall short

Parental consent is collected, not yet verified. An account for a learner under 18 asks for a parent or guardian’s name and email, and asks the guardian to affirm consent on that screen before the account exists — their name, email and the time they affirmed are recorded with the child’s account. That is a real declaration, not a bare tick-box.

What it is not yet is VERIFIED. We do not confirm that the person affirming is actually the child’s guardian — no DigiLocker check, no email confirmation sent to the guardian, no age-gating question — so it rests on the word of whoever is present at sign-up, and we say that to them on the same screen. Rule 10 of the DPDP Rules, 2025 makes verifiable parental consent enforceable from 13 May 2027; we intend to meet that bar before then, and will update this page when we do.

Until then, OrbitOne should be used with a parent or guardian’s active involvement, and a guardian can have all of a child’s data removed on request under section 08. We would rather publish this gap than let a compliance claim outrun the product.

04

Consent

We process personal data on the basis of free, specific, informed and unambiguous consent, given by clear affirmative action — creating an account. Each consent is tied to a stated purpose. Consent can be withdrawn as easily as it was given, by emailing the address in section 09.

05

Purpose limitation and minimisation

Personal data is used only for the purpose it was collected for: signing you in, measuring where you stand, scheduling your revision, answering the question you asked, and reporting progress to a guardian you linked.

On minimisation, the product is deliberately thin: an email, a first name you choose, and an exam. No phone number, no address, no school, no date of birth, no government identifier. The AI features receive the question text only — never your identity or your history.

06

Data localisation and cross-border transfer

The AI answer and tutor features send question text to Groq and Google, whose processing happens outside India. The Act permits cross-border transfer except to countries the Central Government restricts; we will stop using any provider that becomes restricted.

Practice and the 20-question check are graded entirely on your own device and involve no transfer at all — which is why they remain available, and free of this consideration, even when the AI features are not used.

07

Selective disclosure to parents

A guardian sees aggregate progress — readiness, consistency, chapter and capability strength — and never the raw record: not the questions asked, not individual wrong answers, not tutor conversations. This is minimisation applied to the people closest to the student, and it is enforced in the database, not by a promise: the only path a parent account has into a student’s record is a function that removes the raw answers before the row leaves the database, so no parent client — including a modified one — can receive them.

08

Exercising rights

A student, or a parent or guardian acting for a child, may request access to their personal data, correction of it, erasure of it, or withdrawal of consent. Email the Grievance Officer and we will action it. Practice data held on the device can also be erased by the user at any time by clearing site data in the browser.

09

Grievance redressal

Grievance Officer: Uday Vamsidhar Volety, Veranox Systems Private Limited, Chennai, Tamil Nadu, India.
Email: uday@veranox.in. Target response: 3 working days. If you are not satisfied with our response, the Act gives you the right to escalate to the Data Protection Board of India.

OrbitOne is a product of Veranox Systems Private Limited, Chennai, Tamil Nadu, India. These notices are written in plain language and will be reviewed by counsel before public scale.