Privacy Policy

Eigenmind Pvt Ltd

Effective Date: April 9, 2026

Last Updated: April 9, 2026

1. Introduction

1.1. This Privacy Policy ("Policy") is published by Eigenmind Pvt Ltd ("Unio," "we," "us," or "our"), a company incorporated under the laws of India, operating the educational technology platform accessible at unioedtech.com and through associated applications (collectively, the "Platform").

1.2. This Policy describes how we collect, use, store, process, share, and protect personal data and other information when you access or use our Platform, including our learning management system (LMS), self-study application, career assessment services, psychometric evaluation tools, and marketing website.

1.3. This Policy is published in compliance with the Digital Personal Data Protection Act, 2023 ("DPDPA 2023"), the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and other applicable laws of India.

1.4. By accessing or using the Platform, you acknowledge that you have read, understood, and agree to be bound by this Policy. If you are a parent or legal guardian providing consent on behalf of a minor, you confirm that you have the legal authority to do so and that you accept this Policy on the minor's behalf.

1.5. If you do not agree with any part of this Policy, you must not access or use the Platform.

2. Definitions

2.1. "Data Principal" means the individual to whom the personal data relates. Where the individual is a child, the Data Principal includes the parent or lawful guardian of such child.

2.2. "Child" means an individual who has not completed eighteen (18) years of age, consistent with the DPDPA 2023.

2.3. "Personal Data" means any data about an individual who is identifiable by or in relation to such data.

2.4. "Processing" means any operation or set of operations performed on personal data, including collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, use, alignment, combination, indexing, sharing, disclosure, restriction, erasure, or destruction.

2.5. "Platform" means the Unio website or LMS at unioedtech.com, the Unio LMS, the Unio self-study application, the Unio career and psychometric assessment tools, and any mobile applications, sub-domains, or services operated by Unio.

2.6. "Services" means the educational, assessment, analytical, and related services provided by Unio through the Platform.

2.7. "Institutional Partner" means any school, coaching institute, educational institution, or organization that has entered into a services agreement with Unio.

3. Data We Collect

Core Data Points

Account Data Name, email, phone, institution details
Academic Data Assessment responses, grades, attendance
Psychometric Data Model of Mind responses, cognitive profiles, interest patterns
Usage & Device Browser type, session duration, navigation patterns

We collect the following categories of personal data and information in connection with the operation of the Platform and the delivery of our Services:

3.1. Student Data

(a) Identity Information: Full name, date of birth, age, gender, class/grade, section, roll number, and photograph (where provided).
(b) Contact Information: Email address, phone number, and residential address (where provided).
(c) Institutional Affiliation: School or coaching institute name, board of education, and affiliated branch or location.
(d) Academic Data: Quiz scores, test results, assignment submissions, concept mastery levels, learning progression data, prerequisite completion status, and performance analytics across subjects, chapters, and individual concepts.
(e) Psychometric and Assessment Data: Responses to career and personality assessment instruments (consisting of up to 151 assessment items), computed scores across psychological variables and dimensions, personality type classifications, cognitive profile data, aptitude indicators, interest inventories, and career match predictions.
(f) Learning Behavior Data: Time spent on tasks, question attempt patterns, revision frequency, concept navigation paths, study session duration and frequency, content interaction patterns, and learning pace indicators.
(g) AI Interaction Data: Queries submitted to AI-powered study tools, AI-generated responses viewed, AI grading inputs and outputs, and AI-recommended learning paths.
(h) Parent/Guardian Information: Name, email address, phone number, and relationship to the student, collected for the purpose of obtaining verifiable parental consent and enabling parent access to student reports.

3.2. Teacher and Educator Data

(a) Name, email address, phone number, and professional qualifications.
(b) School or institute affiliation and role/designation.
(c) Content created on the Platform, including quizzes, assessments, assignments, and instructional materials.
(d) Platform usage data, including login history and feature utilization.

3.3. School Administrator Data

(a) Name, email address, phone number, and designation.
(b) Institution name, address, registration details, and board affiliation.
(c) Administrative actions performed on the Platform.

3.4. Technical and Usage Data

(a) Device Information: Device type, operating system, browser type and version, screen resolution, and device identifiers.
(b) Log Data: IP address, access timestamps, pages viewed, features accessed, clickstream data, referral URLs, and session duration.
(c) Performance Data: Page load times, error logs, and crash reports.

3.5. Communication Data

(a) Correspondence and communications with Unio, including emails, support requests, feedback, and survey responses.
(b) Records of consent provided or withdrawn.

3.6. Data from Third Parties

(a) Information provided by Institutional Partners about students, teachers, and staff enrolled on the Platform pursuant to services agreements.

(b) Information from authentication providers if you choose to log in via third-party authentication services.

4. How We Collect Data

4.1. Directly from you: When you register an account, complete assessments, take quizzes, interact with learning content, contact us, or otherwise use the Platform.

4.2. From Institutional Partners: When your school, coaching institute, or educational institution registers you on the Platform or provides your information to us under a services agreement.

4.3. From parents or legal guardians: When a parent or guardian creates an account on your behalf, provides consent, or submits information relating to a minor.

4.4. Automatically: Through cookies, log files, and similar technologies when you access and use the Platform.

4.5. From third-party services: Through authentication services, analytics providers, or other service providers integrated with the Platform.

5. Purposes of Data Processing

We process personal data for the following purposes, which constitute legitimate purposes under applicable law:

5.1. Service Delivery

(a) To create and manage user accounts and authenticate users.
(b) To deliver educational content, administer assessments, and provide learning analytics.
(c) To generate psychometric profiles, personality type classifications, career match predictions, and cognitive assessments.
(d) To track concept mastery, prerequisite completion, and learning progression across the curriculum.
(e) To provide AI-powered grading, study assistance, question generation, and personalized learning recommendations.
(f) To generate individual student reports, class-level analytics, and institutional dashboards for Institutional Partners.
(g) To enable communication between students, teachers, parents, and administrators through the Platform.

5.2. Product Development, Improvement, and Innovation

(a) To analyze usage patterns, learning behaviors, and assessment outcomes to improve the accuracy, effectiveness, and quality of our educational products and services.
(b) To research, develop, test, and refine assessment instruments, scoring algorithms, personality classification models, career matching systems, and learning analytics methodologies.
(c) To train, validate, improve, and develop artificial intelligence and machine learning models, including but not limited to models for automated grading, adaptive learning, question generation, concept relationship mapping, learning outcome prediction, career compatibility analysis, and workforce analytics.
(d) To develop new products, features, and services, including but not limited to career matching tools, personality compatibility analysis, workforce readiness assessments, institutional benchmarking tools, curriculum effectiveness analytics, and other educational or professional development services.
(e) To conduct internal research, statistical analysis, and trend identification to understand educational outcomes, learning efficacy, psychometric patterns, and career development trajectories.
(f) To create, use, license, and commercialize aggregated, de-identified, and anonymized datasets and insights derived from Platform usage, academic performance patterns, learning behaviors, and psychometric data, provided that such datasets do not reasonably identify any individual Data Principal.

5.3. Research and Publication

(a) To conduct and publish academic research, white papers, case studies, reports, and educational analyses using aggregated and anonymized data, for the advancement of educational science, psychometric research, learning analytics, and career development methodologies.
(b) To share aggregated, anonymized, and de-identified insights, benchmarks, trends, and analytics with Institutional Partners, educational organizations, government bodies, and the public for the purpose of advancing educational outcomes.

5.4. Communication and Support

(a) To respond to inquiries, provide technical support, and address complaints.
(b) To send service-related notifications, updates, and announcements.
(c) To communicate information about new features, products, or services that may be relevant to your use of the Platform, subject to your communication preferences.

5.5. Safety, Security, and Legal Compliance

(a) To detect, prevent, and address fraud, unauthorized access, security incidents, and technical issues.
(b) To enforce our terms of service, acceptable use policies, and other agreements.
(c) To comply with applicable laws, regulations, legal processes, or governmental requests.
(d) To establish, exercise, or defend legal claims.

5.6. Business Operations

(a) To conduct internal business planning, auditing, accounting, and administrative functions.
(b) To evaluate, negotiate, and complete corporate transactions, including mergers, acquisitions, reorganizations, asset sales, or similar transactions, in which personal data held by us may be among the assets transferred or evaluated.
(c) To share aggregated and anonymized performance data with current and prospective Institutional Partners for the purpose of demonstrating Platform effectiveness, benchmarking, and institutional decision-making.

6. Legal Basis for Processing

6.1. Consent: We process personal data primarily on the basis of your informed consent, obtained at the time of registration or prior to data collection.

6.2. Performance of Contract: Where processing is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract.

6.3. Legitimate Uses: Where processing is necessary for certain legitimate uses as specified under the DPDPA 2023 and rules made thereunder.

6.4. Legal Obligation: Where processing is necessary for compliance with a legal obligation to which we are subject.

6.5. Consent for Minors: For users who are Children (under 18 years of age), we obtain verifiable consent from a parent or lawful guardian before processing their personal data, in accordance with Section 9 of the DPDPA 2023.

7. Protection of Children's Data

Student Data Protection Commitments

✓Parental or institutional consent is required before any psychometric assessment.
✓Students and parents can view all collected data through the parent dashboard.
✓Data can be exported in full at any time (CSV/PDF formats).
✓Data deletion requests are honored within 7 business days.

7.1. Presumption of Minor Status. Unio's Platform is designed for students in Classes 8 through 12, who are typically between 13 and 17 years of age. All student users are presumed to be Children under the DPDPA 2023 unless verifiably established otherwise.

7.2. Verifiable Parental Consent. We obtain verifiable parental or guardian consent before collecting, processing, or storing any personal data of a Child. Consent is obtained through one or more of the following mechanisms:

(a) A written consent form signed by the parent or lawful guardian, submitted physically or electronically.
(b) Institutional consent obtained through the student's school or coaching institute, where the institution acts as an authorized representative and has obtained parental consent as part of its enrollment or onboarding process, pursuant to a data processing agreement with Unio.
(c) Digital consent obtained through a verified parent account on the Platform, including verification of the parent-child relationship.

7.3. No Behavioral Tracking or Targeted Advertising. We do not engage in behavioral tracking of Children for advertising purposes. We do not serve targeted advertisements to Children. We do not profile Children for any purpose other than the delivery of educational services and the generation of educational and career-related assessments and reports.

7.4. No Sale of Children's Data. We do not sell personal data of Children to any third party, for any purpose, under any circumstances.

7.5. Data Minimization for Children. We collect only such personal data from Children as is reasonably necessary for the provision of our educational Services and the fulfillment of the purposes described in this Policy.

7.6. Parental Rights. Parents and lawful guardians have the right to:

(a) Review the personal data collected from their Child.
(b) Request correction of inaccurate personal data.
(c) Request deletion of their Child's personal data, subject to applicable legal retention requirements.
(d) Withdraw consent for future collection or processing of their Child's personal data.
(e) Access their Child's assessment reports, learning analytics, and psychometric profiles.

7.7. Parental Access. Parents may exercise their rights by contacting us at support@unioedtech.com or through the parent account interface on the Platform.

8. Data Sharing and Disclosure

8.1. We do not sell personal data. Unio does not sell individually identifiable personal data to any third party.

8.2. Institutional Partners. We share student data with the student's enrolled school or coaching institute, limited to: (a) students enrolled through that institution, and (b) the data necessary for the institution to fulfill its educational responsibilities, including academic performance, assessment results, and learning analytics.

8.3. Parents and Guardians. We share a student's personal data, assessment results, and reports with their parent or lawful guardian.

8.4. Service Providers. We engage third-party service providers who process data on our behalf to support the operation of the Platform. These include:

(a) Cloud Infrastructure: Google Cloud Platform (GCP), with data hosted in the asia-south1 (Mumbai, India) region.
(b) Email Services: Transactional and service-related email delivery providers.
(c) Analytics Services: Platform analytics tools used to understand usage patterns and improve the Platform.
(d) Payment Processors: For processing subscription and service fees.

All service providers are bound by contractual obligations to process personal data only on our instructions and in accordance with applicable data protection laws.

8.5. Aggregated and De-Identified Data. We may share, publish, license, or otherwise make available aggregated, de-identified, or anonymized datasets, analyses, insights, benchmarks, and research findings derived from data collected through the Platform. Such datasets do not contain information that reasonably identifies any individual Data Principal and are not subject to the restrictions applicable to personal data under this Policy.

8.6. Legal Requirements. We may disclose personal data if required to do so by law, regulation, legal process, or governmental request, or where we believe in good faith that disclosure is necessary to: (a) comply with a legal obligation; (b) protect and defend our rights or property; (c) prevent fraud or address security issues; or (d) protect the personal safety of users or the public.

8.7. Business Transfers. In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, personal data may be transferred as part of that transaction. We will notify affected Data Principals of any change in ownership or control of their personal data.

8.8. With Your Consent. We may share personal data with third parties where you have provided specific consent for such sharing.

9. AI and Automated Decision-Making

Our Psychometric Pledge

"We use psychometric data only to generate career predictions and cognitive profiles for that specific student."
"We never sell psychometric data to third parties: not recruiters, not advertisers, not other schools."
"We never use individual psychometric data for marketing purposes."

9.1. Use of AI Systems. Unio uses artificial intelligence and machine learning technologies as integral components of the Platform. These systems are used for:

(a) Automated Grading: AI-powered evaluation of student responses, including subjective and descriptive answers, using domain-aware grading models.
(b) Psychometric Scoring and Classification: Automated computation of scores across psychological variables, personality dimensions, cognitive profiles, and career match predictions based on assessment responses.
(c) Adaptive Learning Recommendations: AI-driven identification of learning gaps, prerequisite requirements, and personalized study paths based on individual concept mastery data.
(d) Question Generation: AI-assisted creation of practice questions and assessments aligned with curriculum concepts and cognitive operation levels.
(e) Study Assistance: AI-powered study agent that responds to student queries and provides explanations.
(f) Learning Analytics: Automated analysis of learning patterns, performance trends, and predictive indicators of academic outcomes.

9.2. Nature of Automated Decisions. The AI systems described above produce outputs that are educational, informational, and advisory in nature. Career predictions, personality classifications, and learning recommendations are generated to assist students, parents, and educators in making informed decisions. They are not deterministic and do not constitute binding decisions about a student's academic standing, admission, employment, or life opportunities.

9.3. Human Oversight. Assessment results and AI-generated outputs are available for review by teachers, school administrators, and parents. Unio does not make significant decisions affecting a student's rights or opportunities based solely on automated processing without the opportunity for human review.

9.4. Model Training and Improvement. Data collected through the Platform, including assessment responses, grading inputs and outputs, learning behaviors, and usage patterns, is used to train, validate, and improve our AI and machine learning models. This processing is essential to maintaining and enhancing the accuracy, fairness, and effectiveness of our AI systems. Where feasible, model training is performed using aggregated or de-identified data.

9.5. Transparency. Students, parents, and Institutional Partners may request an explanation of the logic, significance, and general methodology behind any automated assessment, score, prediction, or recommendation generated by the Platform. Such requests may be directed to support@unioedtech.com.

10. Data Retention

10.1. General Retention Principle. We retain personal data for as long as necessary to provide our Services, fulfill the purposes described in this Policy, comply with our legal obligations, resolve disputes, enforce our agreements, and support our legitimate research, product development, and business purposes, and for a reasonable period thereafter.

10.2. Active Accounts. Personal data associated with active accounts is retained for the duration of the account's existence and active use of the Platform.

10.3. Institutional Subscriptions. Student and teacher data associated with Institutional Partner subscriptions is retained for the duration of the subscription and for a reasonable period thereafter to allow for renewal, data export, continuity of service, and fulfillment of ongoing educational and research purposes.

10.4. Assessment Data. Psychometric assessment responses, computed scores, personality classifications, career match data, and associated reports are retained for the period necessary to provide ongoing career guidance value, support longitudinal research, and enable returning users to access their historical data. Given the long-term nature of career development and the educational value of longitudinal psychometric data, this retention period may extend for the useful life of the data.

10.5. Academic and Learning Data. Academic performance data, concept mastery records, learning progression data, and quiz/assessment histories are retained for the period necessary to provide continuous educational services, support longitudinal learning analytics, and fulfill research and product improvement purposes.

10.6. Anonymized and Aggregated Data. Data that has been fully anonymized or aggregated such that it does not identify or permit identification of any individual is not subject to retention limits and may be retained and used indefinitely for research, analytics, product development, and any other lawful purpose.

10.7. Post-Deletion Processing. Upon deletion of personal data pursuant to a valid request, we may retain anonymized or aggregated derivatives of such data that do not identify or permit identification of any individual.

10.8. Legal Retention Requirements. Notwithstanding the above, we may retain personal data for longer periods where required by applicable law, regulation, or legal proceedings.

11. Data Storage and Security

Encryption at rest (AES-256)Encryption in transit (TLS 1.3)Regional Hosting (Mumbai, India)

11.1. Data Residency. All personal data collected through the Platform is stored on servers located in India, specifically in Google Cloud Platform's asia-south1 region (Mumbai, India). We do not transfer personal data outside of India except where expressly required and permitted under applicable law, and subject to appropriate safeguards.

11.2. Encryption. All data transmitted between your device and the Platform is encrypted using HTTPS/TLS protocols. Data stored on our servers is encrypted at rest using industry-standard encryption methods.

11.3. Access Controls. We implement role-based access controls (RBAC) to ensure that personal data is accessible only to authorized personnel who require access for the performance of their duties. Per-organization data isolation ensures that Institutional Partners can access only the data of their own enrolled users.

11.4. Infrastructure Security. Our infrastructure is hosted on Google Cloud Platform, which maintains industry-leading security certifications including ISO 27001, SOC 1/2/3, and PCI DSS. We leverage GCP's built-in security features including network firewalls, DDoS protection, and intrusion detection.

11.5. Backup and Recovery. We maintain automated backups with point-in-time recovery capabilities to protect against data loss.

11.6. Incident Response. We maintain incident response procedures for identifying, assessing, and responding to data security incidents. In the event of a personal data breach that is likely to result in a risk to the rights of Data Principals, we will notify the Data Protection Board of India and affected Data Principals in accordance with the requirements of the DPDPA 2023.

11.7. Security Limitations. While we implement reasonable and appropriate security measures, no method of electronic storage or transmission over the Internet is completely secure. We cannot guarantee the absolute security of your personal data.

12. Cookies and Similar Technologies

12.1. What Are Cookies Cookies are small text files placed on your device when you visit a website. They are used to make websites function, function more efficiently, and provide reporting information.

12.2. Cookies We Use

(a) Strictly Necessary Cookies: These cookies are essential for the operation of the Platform. They enable core functionality such as user authentication, session management, security features, and load balancing. The Platform cannot function properly without these cookies. These cookies do not require consent.
(b) Functional Cookies: These cookies enable the Platform to remember choices you make (such as your language preference, class selection, or display settings).
(c) Analytics Cookies: These cookies collect information about how users interact with the Platform, including pages visited, features used, time spent, and error encounters. Information is used in aggregate.
(d) Performance Cookies: These cookies collect information about the performance of the Platform to help us monitor and improve Platform performance.

12.3. Cookies We Do Not Use

(a) We do not use advertising or marketing cookies.
(b) We do not use cookies to serve targeted advertisements.
(c) We do not use third-party cookies for the purpose of behavioral tracking of Children.

12.4. Managing Cookies You may manage your cookie preferences through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling strictly necessary cookies may impair the functionality of the Platform.

12.5. Local Storage and Similar Technologies In addition to cookies, we may use local storage, session storage, and similar browser-based technologies for authentication tokens, user preferences, and offline functionality. These technologies are subject to the same principles described in this section.

13. Your Rights Under DPDPA 2023

As a Data Principal under the DPDPA 2023, you have the following rights:

13.1. Right to Access. You have the right to obtain confirmation as to whether your personal data is being processed and, where that is the case, to request a summary of your personal data and the processing activities undertaken with respect to such data.

13.2. Right to Correction. You have the right to request the correction of inaccurate or misleading personal data, and the completion of incomplete personal data.

13.3. Right to Erasure. You have the right to request the erasure of your personal data where the data is no longer necessary for the purpose for which it was collected, or where you withdraw your consent. Erasure is subject to applicable legal retention requirements and our legitimate interests. Upon a valid erasure request, we will delete your identifiable personal data; however, anonymized and aggregated derivatives that do not identify you may be retained.

13.4. Right to Withdraw Consent. Where processing is based on consent, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal. Withdrawal of consent may result in the termination of certain Services that require such data for operation.

13.5. Right to Grievance Redressal. You have the right to register a grievance with our Grievance Officer. If your grievance is not resolved to your satisfaction, you have the right to file a complaint with the Data Protection Board of India.

13.6. Right to Nominate. You have the right to nominate another individual to exercise your rights under the DPDPA 2023 in the event of your death or incapacity.

13.7. How to Exercise Your Rights. To exercise any of the above rights, please contact us at:

Email: support@unioedtech.com
WhatsApp: +91 8920677364

We will respond to your request within thirty (30) days of receipt. We may request additional information to verify your identity before processing your request.

14. Data Principal Obligations

14.1. Under the DPDPA 2023, Data Principals have certain obligations, including:

(a) To provide accurate and complete personal data when registering for or using the Platform.
(b) Not to impersonate another person or suppress material information when providing personal data.
(c) Not to register a false or frivolous grievance or complaint with Unio or the Data Protection Board of India.
(d) To comply with applicable laws, including provisions of the DPDPA 2023.

15. Cross-Border Data Transfers

15.1. All personal data collected through the Platform is stored and processed in India.

15.2. We do not transfer personal data to any country or territory outside India unless such transfer is: (a) necessary for the performance of our Services; (b) made to a country or territory permitted by the Central Government of India under the DPDPA 2023; and (c) subject to appropriate contractual safeguards.

15.3. In the event that cross-border transfer becomes necessary (for example, due to changes in infrastructure requirements), we will update this Policy and ensure compliance with all applicable provisions of the DPDPA 2023 and rules made thereunder.

16. Third-Party Links and Services

16.1. The Platform may contain links to third-party websites, applications, or services that are not operated or controlled by Unio. This Policy does not apply to such third-party services.

16.2. We are not responsible for the privacy practices of third-party services. We encourage you to review the privacy policies of any third-party services before providing personal data to them.

17. Changes to This Policy

17.1. We may update or amend this Policy from time to time to reflect changes in our data processing practices, legal requirements, or business operations.

17.2. When we make material changes to this Policy, we will:

(a) Update the "Last Updated" date at the top of this Policy.
(b) Post the revised Policy on the Platform at unioedtech.com/privacy.
(c) Notify registered users via email or through in-Platform notifications.
(d) Where required by law, obtain fresh consent for any new processing purposes.

17.3. Your continued use of the Platform after the posting of changes constitutes your acceptance of the revised Policy.

18. Grievance Officer

18.1. In accordance with the DPDPA 2023 and the Information Technology Act, 2000, we have appointed the following Grievance Officer:

Name: Manan Verma

Designation: Grievance Officer and Data Protection Officer

Email: support@unioedtech.com

Phone/WhatsApp: +91 8920677364

18.2. The Grievance Officer will acknowledge your grievance within forty-eight (48) hours of receipt and will endeavor to resolve the grievance within thirty (30) days from the date of receipt.

18.3. If you are not satisfied with the resolution of your grievance, you may file a complaint with the Data Protection Board of India as constituted under the DPDPA 2023.

20. Data Processing Agreements

20.1. Where Unio processes personal data on behalf of Institutional Partners (schools, coaching institutes, and educational institutions), we enter into data processing agreements that define:

(a) The categories of personal data to be processed.
(b) The purposes and duration of processing.
(c) The obligations and rights of both parties regarding data protection.
(d) Security measures to be implemented.
(e) Provisions for data return or deletion upon termination of the agreement.

20.2. Institutional Partners are responsible for ensuring that they have obtained all necessary consents, including parental consents, from their students and staff before providing personal data to Unio.

21. Governing Law and Jurisdiction

21.1. This Policy shall be governed by and construed in accordance with the laws of India.

21.2. Any disputes arising out of or in connection with this Policy shall be subject to the exclusive jurisdiction of the courts of New Delhi, India.

22. Contact Us

For any questions, concerns, or requests regarding this Policy or our data processing practices, please contact us:

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