Registered Office: HOUSE NO. 01 BACK PORTION GROUND FLOOR Block 8, Moti Nagar, Delhi, Delhi, India - 110015 — Corporate Identity Number (CIN): [CIN: U74999DL2016PTC298160]
Email: support@indiean.com | Grievance Officer: Sarah Massey, support@indiean.com | Grievance Response Time: 30 days
IndieAn Learning Private Limited and/or E Easy Solutions Private Limited (collectively referred to as "IndieAn", "Company", "we", "our", or "us") is committed to safeguarding the privacy, dignity, and legal rights of every individual who interacts with our platforms, applications, and services (collectively, the "Services").
This Privacy Policy ("Policy") sets out, in clear and unambiguous terms, how we collect, use, store, share, transfer, and protect your personal information, including any sensitive personal data or information ("SPDI") as defined under applicable law. This Policy is binding on all users of IndieAn Services and should be read in conjunction with our Terms of Service.
This Policy is governed by and shall be construed in accordance with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules"), the Digital Personal Data Protection Act, 2023 ("DPDPA"), and to the extent applicable, the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the Children's Online Privacy Protection Act ("COPPA"), and any other applicable data protection laws.
This Policy applies to:
This Policy does not apply to third-party websites or services linked from our platform. We encourage Users to review the privacy policies of such third parties independently.
For the purposes of this Policy, the following definitions apply:
| Category | Details |
|---|---|
| Data Principal | The natural person to whom the personal data relates; in the context of minors, includes the parent or legal guardian. |
| Data Fiduciary | IndieAn Learning Private Limited, which determines the purpose and means of processing personal data. |
| Data Processor | Any entity that processes personal data on behalf of IndieAn, under a contractual or legal obligation. |
| Personal Data | Any data about an individual who is identifiable by or in relation to such data, whether directly or indirectly. |
| Sensitive Personal Data or Information (SPDI) | Passwords, financial information, health data, biometric data, and other categories specified under the SPDI Rules. |
| Consent | A freely given, specific, informed, unambiguous, and revocable indication of agreement to the processing of personal data. |
| Processing | Any operation performed on personal data, including collection, recording, storage, use, disclosure, and deletion. |
| Child / Minor | Any individual under the age of 18 years, or as defined under applicable jurisdiction-specific law. |
We collect only such personal information as is necessary for the legitimate purposes described in this Policy. The categories of information we collect include:
Note: Audio recordings captured during practice sessions may constitute biometric or sensitive data under certain jurisdictions. We apply heightened protections to such data as described in Section 9.
We process personal data only where a valid legal basis exists. The applicable legal bases are:
| Category | Details |
|---|---|
| Consent (Section 5 SPDI Rules; Article 6(1)(a) GDPR) | Where you have provided express, informed, and revocable consent, including for processing of sensitive data, marketing communications, and audio data. |
| Contractual Necessity | Where processing is necessary to perform our obligations under the Terms of Service, including account creation, lesson delivery, and progress tracking. |
| Legitimate Interests | Where processing is necessary for our legitimate business interests (e.g., fraud prevention, platform security, product improvement), provided such interests are not overridden by your rights. |
| Legal Obligation | Where processing is required under applicable law, court order, or regulatory directive. |
| Vital Interests | In exceptional circumstances, where processing is necessary to protect life or physical safety. |
| Parental Consent (COPPA / DPDPA) | Where the User is a child under 13 (COPPA) or under 18 (DPDPA), processing is subject to verified parental or guardian consent. |
We use the information collected for the following purposes:
The protection of children's data is of paramount importance to IndieAn. The following provisions apply specifically to Users who are minors:
When you submit content through our Services (including audio recordings, written feedback, survey responses, or testimonials), the following terms apply:
You represent and warrant that you own or have the necessary rights to submit such content, and that it does not infringe the intellectual property, privacy, or other rights of any third party.
By submitting content, you grant IndieAn a non-exclusive, worldwide, royalty-free, perpetual, sublicensable licence to use, store, process, reproduce, adapt, translate, and analyse such content solely for the following purposes:
You retain full ownership of your content. We do not claim any proprietary rights over User-Generated Content beyond the licence granted herein. You may withdraw your consent or request removal of identifiable content at any time by contacting us at support@indiean.com.
IndieAn implements and maintains appropriate technical and organisational security measures to protect personal data against unauthorised access, alteration, disclosure, or destruction. These measures include, but are not limited to:
In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected individuals, we will notify the relevant supervisory authority and, where required, affected Data Principals, within the timeframes prescribed by applicable law (72 hours under GDPR; as prescribed under the DPDPA).
Notwithstanding the above, no system is completely immune to security threats. Users are responsible for maintaining the confidentiality of their account credentials and must promptly notify us of any suspected unauthorised access.
We do not sell, rent, or trade your personal data to any third party for their own commercial purposes. We may share personal data only in the following limited circumstances:
We engage carefully vetted third-party service providers to assist in the operation of our Services (e.g., cloud infrastructure, analytics, payment processing, customer support). Such providers act as Data Processors and are contractually bound to:
Where a User accesses IndieAn through a school, institution, or employer, we may share relevant performance and progress data with authorised institutional administrators, subject to applicable data sharing agreements.
We may disclose personal data to governmental or regulatory authorities where required by applicable law, court order, or valid legal process. We will, to the extent permitted by law, notify affected Users before such disclosure.
In the event of a merger, acquisition, restructuring, or sale of all or substantially all of our assets, personal data may be transferred to the successor entity. We will provide notice to affected Users and ensure that the acquiring entity is bound by data protection obligations equivalent to those under this Policy.
We may share your personal data with any third party with your explicit, prior, and informed consent, which you may withdraw at any time.
IndieAn operates primarily in India. Where we transfer personal data to countries outside India or outside the European Economic Area (as applicable), we ensure that:
Users may request details of the international transfer safeguards applicable to their data by contacting support@indiean.com.
We retain personal data only for as long as is necessary for the purposes described in this Policy, or as required by applicable law. The following principles govern our retention practices:
| Category | Details |
|---|---|
| Active Account Data | Retained for the duration of your account's active status. |
| Educational / Progress Records | Retained for [X] years following account closure, unless earlier deletion is requested. |
| Audio Recordings | Deleted within [X] days of capture, unless retained under separate consent for model training purposes. |
| Legal / Compliance Records | Retained for the minimum period required by applicable law (e.g., tax, audit, or dispute resolution obligations). |
| Marketing Data | Retained until consent is withdrawn or for [X] years, whichever is earlier. |
| Backup Data | Securely purged within [X] days of primary data deletion. |
You may request deletion of your data at any time (see Section 13). Where deletion is not immediately possible due to legal obligations or backup cycles, we will restrict further processing and notify you accordingly.
Subject to applicable law and certain exceptions, you have the following rights in respect of your personal data:
| Category | Details |
|---|---|
| Right of Access | To request a copy of the personal data we hold about you and information about how it is processed. |
| Right to Correction | To request correction or updating of inaccurate or incomplete personal data. |
| Right to Erasure | To request deletion of your personal data where it is no longer necessary, consent is withdrawn, or processing is unlawful. |
| Right to Withdraw Consent | To withdraw consent for any processing activity at any time, without affecting the lawfulness of prior processing. |
| Right to Restriction | To request that we limit the processing of your data in certain circumstances. |
| Right to Object | To object to processing based on legitimate interests, including for direct marketing purposes. |
| Right to Data Portability | To receive your data in a structured, commonly used, machine-readable format and to transmit it to another controller. |
| Right to Nominate | Under the DPDPA, to nominate another person to exercise your rights on your behalf. |
| Right to Grievance Redressal | To lodge a complaint with our Grievance Officer or a relevant Data Protection Authority. |
To exercise any of the above rights, please submit a written request to our Grievance Officer at support@indiean.com. We will respond within 30 calendar days. We may request identity verification before fulfilling any request.
Where your request is refused, we will provide written reasons and information on how to appeal or escalate the matter.
IndieAn uses cookies, web beacons, pixel tags, and similar tracking technologies on our web platforms to enhance functionality, analyse usage, and deliver personalised experiences. The types of cookies we use include:
| Category | Details |
|---|---|
| Strictly Necessary | Essential for the operation of the platform (e.g., session management, authentication). Cannot be disabled. |
| Functional | Enable enhanced features such as language preferences and user settings. |
| Analytical / Performance | Used to understand how Users interact with our Services (e.g., Google Analytics). Data is aggregated and anonymised where possible. |
| Marketing / Targeting | Used, with your consent, to deliver relevant promotional content. |
You may manage your cookie preferences through our Cookie Consent Manager (available on our web platform) or through your browser settings. Please note that disabling certain cookies may impair platform functionality.
IndieAn employs automated processing and AI-driven systems to provide personalised learning feedback and music analysis. Where such automated processing has a significant effect on you (e.g., generating a performance score that impacts your learning pathway), you have the right to:
We will always disclose where AI-generated outputs are being presented to Users, and will implement safeguards to prevent discriminatory or unfair outcomes from automated systems.
We may send you the following types of communications:
We will honour opt-out requests within [10] business days. Opting out of marketing communications does not affect the delivery of transactional notifications.
In accordance with the Information Technology Act, 2000 and the DPDPA, IndieAn has appointed a Grievance Officer to address any complaints, queries, or concerns relating to this Policy or the processing of personal data.
Grievance Officer: Sarah Massey, Head of Human Resources
Email: support@indiean.com
Response Time: We will acknowledge your complaint within 48 hours and resolve it within 30 calendar days.
Escalation: If you are unsatisfied with our response, you may escalate the matter to the Data Protection Board of India (under the DPDPA) or the relevant supervisory authority in your jurisdiction (e.g., the Information Commissioner's Office under GDPR).
We may amend this Policy from time to time to reflect changes in our data practices, product features, or applicable law. We will notify you of material changes through:
If a change materially reduces your rights or significantly alters how we use your data, we will seek your fresh consent before applying the change to your existing data.
Continued use of the Services after the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree to the revised Policy, you must discontinue use of the Services and may request deletion of your account and data.
This Policy is governed by the laws of India. Any dispute arising from or in connection with this Policy shall be subject to the exclusive jurisdiction of the courts in Noida, Uttar Pradesh, India.
Before initiating formal legal proceedings, we encourage Users to first attempt resolution through our Grievance Redressal Mechanism (Section 17). We are committed to resolving complaints fairly and efficiently.
For all privacy-related inquiries, requests, or concerns, please contact:
IndieAn Learning Private Limited | E Easy Solutions Private Limited
HOUSE NO. 01 BACK PORTION GROUND FLOOR Block 8, Moti Nagar, Delhi, Delhi, India - 110015
Email: support@indiean.com
Grievance Officer Email: support@indiean.com
Response Time: Within 48 hours (acknowledgement); within 30 days (full resolution)